CLARIFICATION STATEMENT REGARDING THE PRIVACY POLICY AND PROCESSING OF THE PERSONAL DATA

A summary of some of the important points in our Privacy Policy and our Clarification Statement Regarding the Processing of Personal Data (“Privacy Statement”) will be provided below in this section. This summary is merely for reference purposes and does not form a part of our Privacy Statement.

At Rockads for Business, we pay attention to the requests of our users and undertake to protect the principles of privacy and fair use that support our values to provide a transparent and secure service. We want you to be sure that your personal data is safe with us.

This Privacy Statement explains the following:

• how do we collect your personal data;
• which personal data do we collect;
• how do we use your personal data;
• for what purposes do we process your personal data;
• with whom do we share your personal data; and
• your rights and preferences regarding your personal data

Last date of update: December 27, 2023

Privacy Statement

According to applicable law, our company Rockads ME FZ LLE (“Company”) may process your personal data under the title of “Data Supervisor” within the framework of the limitation determined by applicable law and for the purposes mentioned in applicable law. We would like to inform and enlighten you about our personal data processing activities. The terms "Rockads", "we" or "our” refer to Rockads ME FZ LLE. This Privacy Statement applies to all of our applications, services, games, features, software and website (collectively, the "Services"), unless stated otherwise.

This Privacy Statement explains how we, as the data controller, will use personal data about you and the steps we take to ensure your personal data is kept safe and confidential. Our Privacy Statement should be read along with our Terms of Services.

The term "Personal Data" refers to any information relating to an identified or identifiable natural person. The personal data within the scope of this Privacy Statement are the personal data of the business and/or customers of your business that you have shared with us so that we can provide services to you, and for which you have already provided their express consent by duly clarification in accordance with the relevant legislation.

2The term "processing” means all kinds of operations performed on data, such as obtaining, recording, storing, keeping, changing, rearranging, disclosing, transferring,taking over, making available, classification or prevention of use personal data completely or partially automatically or non-automatically provided that it is a part of any data recording system including but not limited to those regulated in applicable law.

1. Who are we - Data Supervisor

Pursuant to applicable law, as Rockads, in the capacity of data controller, we will be able to process, save, store, classify, update and disclose/transfer personal data to third parties where permitted by the legislation and/or limited to the purpose for which they are processed in connection with the purposes described below, in a limited and measured way, in accordance with the law and honesty, ln an accurate and up-to-date manner.

2. Which personal data do we collect

We collect personal data you provide to us when registering and/or using our Services. In this context, in respect of the persons, we collect the details of name-surname, address, e-mail address or telephone number and in respect of the companies we collect the details of company/business name/title, business e-mail address, Business Name and logo to be displayed, your tax number, your profile photo and information to be provided by you (your contact details and communication information (such as name and e-mail address); username, surname and password; business phone number, profile information (such as profile photo and biography); and other data you choose to provide to us (such as data to identify a lost account))

Please be reminded that it is your responsibility to ensure and control that any information, content, material or data you provide to us is accurate, complete and not misleading.

We do not publish or disclose non-public persons or personal data without your express and final consent where we are required by law to obtain your consent

You can choose to share with us the contact information, such as your customers' data, names and numbers, which you have shared with us and whose explicit consent has been provided by you, by duly clarification, in accordance with the provisions of the relevant legislation and in accordance with your express consent. However, we do not keep your any information to make it public or searchable. For the avoidance of doubt, you confirm and undertake that the customer data shared with us is duly collected, processed and transferred to us by you in accordance with the provisions of the relevant legislation and that you have informed the relevant persons in advance about the transfer to be made to us, and you confirm and undertake that you have obtained the express consent of the persons concerned, by means of a duly clarification provided by you, in accordance with the provisions of the relevant legislation, for processing, using and sharing the personal data of the aforementioned persons inside and outside the country by our Company as specified in this Privacy Statement, therefore we declare that our Company has no responsibility in this regard. In this context, you confirm and undertake that you are responsible and liable for all claims, applications, compensations or complaints that can arise within the scope of the data of your customers, which you have shared with us in order to be able to provide services to you, and whose explicit consent has been obtained by you after duly clarification provided to said consumers by you in accordance with the provisions of the relevant legislation, our Company is not responsible for any claims, including but not limited to any claims, applications, compensations or complaints sent to us in this context and you confirm and undertake that you are aware of the fact that we reserve the right to recourse to you for any damage we suffer, in case our Company is subject to any judicial and/or administrative sanctions in this regard.

Data that can be collected automatically

In addition, when you use our Services, we may automatically collect data from you and/or your device, that may be considered personal data under applicable data protection laws, in case you have given your express consent:

• Data and analytics about your use of our Services;
• Your IP address, computer and mobile device identifiers (information such as your device ID, advertising ID, MAC address, IMEI (International Mobile Device Code));
• Data about your device, such as device name and operating system, browser type and language;
• Data we collect with cookies and similar technologies;
• Extensive geolocation information based on your IP address;
• Precise geolocation data (GPS with your permission); and
• Data about your use of our Services, such as in-app interactions and usage metrics.)

Advertising IDs are non-permanent, non-personal identifiers and are only associated with your device. Similar technologies include pixel tracking between ads. These technologies allow companies (including marketers and advertisers) to recognize your device when you use their websites and applications.

Data about your device means your device type, device model, device manufacturer, device operating system and language, and other technical data such as screen size or processor or information about a combination of these data available from the device to a developer to check the compatibility of the device with a particular application.

Some of this information may be collected through the use of cookies and/or similar technologies (such as "SDKs" or software development kits), as further described below.

3. Purpose of processing your personal data – how do we use your personal data?

We may use your personal data in the following ways and purposes, always subject to your prior consent and subject to your preferences in the application settings:

1. To enable you to access and use our Services. For example;

• To create user accounts and profiles;
• To control the up-to-date status of the data within the scope of the services to be provided;
• To provide you with the correct versions of our applications;
• To fulfill our obligations under any applicable contract and to perform the service; and
• To contact you via commercial electronic messages.

We additionally process your personal data when we need to comply with a legal obligation or if we have a legitimate interest in processing. Rockads's legitimate interests include protection and maintenance the security and technical infrastructure of our Services in order to understand and improve our Services and to implement our technical and customer support.

Where we process your personal data based on your explicit consent, you can withdraw your consent and/or review your profile preferences at any time through our Privacy Management Center.

2. For the purposes of personalizing and improving our Services. For example;

• Responding to your customer support requests;
• Receiving error messages about any issues you or your customers/device or devices may encounter with our Services so that we can fix errors and interoperability issues;
• Detection and prevention of illegal activities
• Monitoring application installations/calls answered or rejected to measure the impact of our marketing campaigns;
• Conducting optional user feedback surveys;
• Enabling you to remember our Services on your next visit;
• Contacting you for promotions, prizes, upcoming events and other news about the products and services we offer.

We may use your business customers' personal data, for which you have already duly provided clarification and obtained their explicit consent, in accordance with the business and/or relevant legislation, to share with you information about your interaction with our services, such as the activity of other users with whom you have a common link directly or indirectly and to provide you with notifications about profile visits, profile tags added or viewed, and any associated profile directory searches made through our functions and/or in-app features.

3. To contact you, including some or all of the following:

• Providing you with in-app offers and rewards based on your interaction with our Services;
• Delivering targeted, relevant ads to you;
• Sending you marketing communications and/or newsletters about prizes and promotions if you subscribe;

4. For the purpose of conducting research such as analysing market trends and customer demographics;

5. For the purpose of complying with legal obligations, including preventing and/or detecting fraud or making disclosures to authorized institutions if required under applicable laws, without seeking your explicit consent.

When you use our services, you can choose not to allow the use of your personal data for marketing purposes. If and when you give your consent, you can withdraw your consent at any time and at no cost.

4. With Whom We Share Your Personal Data - Transfer of Your Personal Data

Personal data of your business customers, for which you have already obtained their express consent by providing them with a duly clarification in accordance with the legislation regarding your personal data processed within the scope of the above-mentioned purposes, may be transferred to, shared with the following persons and/or the right to access your personal data may given to the following persons, in accordance with the basic principles stipulated in the applicable law and within the personal data processing conditions and purposes specified in the applicable law.

For the avoidance of doubt, you confirm and undertake that the customer data shared with us is duly collected, processed and transferred to us by you in accordance with the provisions of the relevant legislation and that you have informed the relevant persons in advance about the transfer to be made to us, and you confirm and undertake that you have obtained the express consent of the persons concerned, by means of a duly clarification provided by you, in accordance with the provisions of the relevant legislation, for processing, using and sharing the personal data of the aforementioned persons inside and outside the country by our Company as specified in this Privacy Statement, therefore we declare that our Company has no responsibility in this regard.

When you use any of our services, we may disclose your personal data and the personal data of your business customers to the following parties, for which you have already obtained your customers’ express consent by providing them with a duly clarification

• To authorized law enforcement, regulatory, governing bodies, government agencies, courts or other third parties, whom we believe requires to obtain disclosure, without seeking your express consent
• Any person to whom you have given express consent; and
• to third party services providers and partners who provide a specific Service on our behalf, perform data storage or data processing services, including those located outside your territory and to assist us in analysing how our Services are performing. These third parties have access to your Personal Data only for the strict purpose to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
• d) Your information regarding the payment and payment methods (including payment institutions, PSP (payment service provider), payment broker, payment service provider, technical integrator) of the Services, including those located outside of your region, is the performance, development and analysis of the core service we provide under our Terms of Service agreement; and information on payment and payment methods are transferred to our Business Partners as a third party so that our Company, as data controller, can fulfill its legal obligation.

In addition, your personal data may and will be transferred abroad and processed by our Group Companies, third party service providers and partners located outside the borders of your country, based on your approval. By accepting our terms of Service, you are deemed to have consented to the processing and transfer of your personal data abroad. If you do not accept the processing and transfer of your personal data abroad, you may choose not to use our Services.

5. Transfer of Your Personal Data Abroad

Our services are global in nature and your business data and/or the personal data of your business customers, for which you have already duly provided clarification and obtained their express consent in accordance with the relevant legislation, may be transferred to countries other than your country of residence in accordance with your express consent and processed in these countries based on your express consent. These countries may have data protection laws that differ from those of your own country. We take all measures to provide adequate and appropriate measures to protect your data as described in our Privacy Statement.

As Rockads, the data supervisor, we are a company established abroad, therefore we hereby state that your personal data that you have shared during your use of our services and the personal data of your business customers, for which you have already duly provided clarification and obtained their express consent, will be automatically transferred abroad and your data will be processed and stored abroad. Therefore, if you do not agree to the transfer of your personal data abroad, please do not use our Services.

Appropriate safeguards available to our business partners include standard contractual clauses approved by the EU Commission and Privacy Protection certification if transferred to the USA.

6. Collection Method and Legal Reason of Your Personal Data

In accordance with the business and/or relevant legislation, the personal data of your business customers, for which you have already duly provided clarification and obtained their express consent, are collected by Rockads through different channels, in writing or electronically, and based on the above-mentioned purposes, in order to carry out our activities. In this context, in respect of the personal data in question, pursuant to applicable law:

Approval/Explicit Consent: We will collect and process the personal data of your business customers, for which you have already duly provided clarification and obtained their explicit consent in accordance with the business and/or relevant legislation, only if you have given us your explicit and positive approval/consent to act in this way if necessary.

Legitimate Interests: We may use and process some of the personal data of your business customers, for which you have already duly provided clarification and obtained their express consent in accordance with the business and/or relevant legislation, where we have reasonable and legitimate commercial grounds to do so. Our legitimate interests in processing the personal data of your business customers, for which you have already duly provided clarification and obtained their express consent in accordance with the business and/or relevant legislation, include enabling you to access and use our Services, and administering our technical and customer support for the delivery of our Services.

Legal obligations –We may need to process your personal data when we need to comply with a legal obligation.

Provided that it is directly related to the establishment or performance of the contract, it is necessary to process the personal data of the parties to the Service Contract - We may need to process your personal data when we provide Services to you or when we communicate with you about the Service. It includes that the receive and administering premium services and packages offered under the Rockads Terms of Service; and processing personal data to handle payment processes.The personal data you have shared will be processed and transferred abroad based on your express consent.

• Which cookies do we use?

A cookie is a very small text file placed on your computer or device. We and our partners use cookies and similar technologies to provide and personalize our Services, analyse usage, target ads, and prevent fraud. You can disable cookies in your browser or device settings, but in this case some parts of our Services may not work properly. To review our cookie policy and for detailed information, please visit our website.

• Which advertisements do we display on our Services?

  The advertisements you see displayed on our services are provided by certain third-party advertisers on our behalf. No information that identifies you, such as your name, address, email address or phone number, is used to provide such advertisement. These third-party advertisers may place a cookie in your browser to display the most relevant advertisements to you. This cookie does not collect personal data about you and is not linked to any identifiable information about you. By using our services, you consent to the use of such third-party cookies for these purposes.

• What measures do we take for the safety of your personal data?

  The security of your personal data is very important to us. Therefore, where appropriate, we use HTTPS to keep your information secure. However, no data transmission over the Internet can be guaranteed to be completely secure.

  We do our best to keep the personal data you disclose to us secure. However, we cannot guarantee the security of any information you send us, which is completely at your own risk. By using our services, you accept the risks inherent in providing information online and you may not hold us responsible for any security breaches.

• How long do we keep your personal data?

  Our company acts in accordance with the obligations stipulated in all relevant legislation, especially the applicable law.

  We will store your personal data only as reasonably necessary to fulfill the purposes set out in this Privacy Statement and for our legitimate interests, such as complying with our legal obligations, resolving litigation, and enforcing our contracts, unless a longer holding period is required or permitted by law.

• Age Limit

  We do not deliberately collect or request personal data from anyone under the age of 18 or deliberately allow such persons to use our Services. If you learn that your child has provided us with personal data without your consent, you can alert our customer support team from here. If we learn that we have collected personal data from children under the age of 18, we will immediately take steps to delete such data as soon as possible.

• Management of your privacy preferences and your Rights as a Relevant Person We want you to be in control of your privacy preferences, so to make this as easy as possible, we've developed a few features and a well-equipped Privacy Management Center within our application, depending on your region.

Pursuant to the applicable law, in case you sent your requests regarding your rights in question, as personal data owners, in writing accompanied by your identification documents and a written petition containing your explanations about your right that you want to exercise, to our Company's address Fujairah Creative Tower P.O. Box 4422 Fujairah U.A.E. or to our customer support team, your request will be evaluated by Rockads and finalized within 30 (thirty) days at the latest as stipulated within the scope of applicable law. Although it is essential that no fee is charged for the requests, Rockads reserves the right to charge a fee based on the fee schedule determined by the applicable personal data protection authority.

As a "Data Supervisor” we declare that you have the following rights within the scope of applicable law: to be informed whether your personal data has been processed by applying to our Company; if your data is processed, to learn the purpose of processing and whether it is used in accordance with its purpose; to learn about the third parties to whom your personal data has been transferred in the country or abroad; to request the correction of your personal data if it is processed incompletely or incorrectly; to request deletion or destruction of your personal data in the event that the reasons requiring its processing disappear; to request the notification of the transactions made to the third parties to whom your personal data has been transferred; to object to the emergence of a result against you by analyzing it exclusively through automated systems and to request the compensation of the damage in case you suffer damage due to the processing in violation of the applicable law.

Within the scope of your right to receive information, you can obtain information under the framework of the above-mentioned information and access the Data Owner Application Form in the Website.

Headquarters: Fujairah Creative Tower P.O. Box 4422 Fujairah U.A.E.

E-mail: [email protected]

Access, Editing, Deletion and Movement

You can access and edit your basic profile information and preferences from the Rockads app. You can also obtain a copy of the information not found in our application in a portable format for you to carry or store wherever you desire.

We will require you to verify your identity or provide additional information about your account before allowing you to access or update your personal data. We may also refuse your request to access or update personal data for various reasons, such as whether the request is illegal or if doing so will affect the protection of other users in the Rockads community.

In addition, we would like to state that you have the following rights within the scope of current and valid data protection legislation:

• Right to access: your right to request copies of personal data from us;
• Right to rectification: your right to request us to correct personal data if it is inaccurate or incomplete;
• Right to delete: your right to request the deletion and removal of personal data from our systems;
• The right to limit our use of your personal data: your right to prevent us from using personal data or to limit the methods we use it;
• Right to data movement: your right to request that we move, copy or transfer personal data;

Access, Editing, Deletion and Movement

You can access and edit your basic profile information and preferences from the Rockads app. You can also obtain a copy of the information not found in our application in a portable format for you to carry or store wherever you desire.

We will require you to verify your identity or provide additional information about your account before allowing you to access or update your personal data. We may also refuse your request to access or update personal data for various reasons, such as whether the request is illegal or if doing so will affect the protection of other users in the Rockads community.

In addition, we would like to state that you have the following rights within the scope of current and valid data protection legislation:

• Right to access: your right to request copies of personal data from us;
• Right to rectification: your right to request us to correct personal data if it is inaccurate or incomplete;
• Right to delete: your right to request the deletion and removal of personal data from our systems;
• The right to limit our use of your personal data: your right to prevent us from using personal data or to limit the methods we use it;
• Right to object:your right to object to the processing of personal data, including where we use it for our legitimate interests.
• Changes to Our Privacy Statement

  We reserve the right to change or modify this Privacy Statement at any time. Any changes to our Privacy Statement will be posted on this page along with the revision date. If there are material changes to our Privacy Statement, we may also notify you by other means, such as by e-mail. Where required by law, we will obtain your consent to implement such changes.If you do not accept any changes, please do not continue to use our Services.

• Information Information Relating to Children

  Our Services are intended for general audiences over the age of 18 years old. We do not knowingly collect information from children under the age of 18 years old. If you are not over 18 years old then do not download or use our services. If you believe that we may have personal information from or about a child under the age of 18 years old, please contact us at the applicable email [email protected] (please include your name, mailing address, and email address). Note that we'll attempt to delete the account of any child under the age of 18 that's reported to us as soon as possible. You are responsible for any and all account activity conducted by a minor on your account.