PRIVACY POLICY

We, the BTOMIC Group LLC, located in the United States, (hereinafter “BTOMIC”, “we”, “us”) are committed to protecting your privacy while continuously improving the services we offer you.

The BTOMIC Privacy Policy (hereinafter the “Privacy Policy”) intends to give you all the information regarding the processing (e.g. collection, use, recording, storage or transfer) of any personal data that we may collect through our online platforms (website, applications, social networks) (hereinafter the “BTOMIC Platforms”) or when you fill out the

BTOMIC Client Form (hereinafter the “Client Form”) in our boutiques or customer service centers, when we organize an event, or through any other form of interaction.

The Privacy Policy does not apply to the personal data collected by other third party websites or applications that may provide links to or be accessible from any of the BTOMIC Platforms. We are not responsible or liable for the privacy policies and practices of third-party websites and applications.

2.1 WHAT IS PERSONAL DATA AND HOW DO WE COLLECT IT?

We may collect personal information about you (as an identified natural person) or which allows us to identify you (hereinafter your “Personal Data”) in various ways and circumstances:

• When you visit any of our BTOMIC Platforms, particularly when you register on our websites or fill out our Contact Us Form;
• When you visit our own boutiques, points of sale or offices;
• When you purchase a BTOMIC product or request customer service;
• When you interact with us via email or telephone;
• When you fill out any forms in our boutiques, customer service centers or during BTOMIC events, including the Client Form (printed or electronic);
• Through some of our commercial and advertising partners (always with your explicit consent).

2.2 WHAT KIND OF PERSONAL DATA DO WE COLLECT?

• Information about your identity (first name, surname, nationality);
• Contact information (mailing address, email address and telephone number);
• Information about purchases and payments (credit card information and information required by anti-money-laundering laws);
• Other personal information, including information regarding your preferences and personal and/or professional interests, demographic category, your experiences with our products and contact preferences, your professional situation (position, company/employer, professional contact details), your interests (sports, leisure) and your lifestyle;
• Customer service information (such as customer service requests, comments, feedback, complaints and repair history);
• Information concerning your application (education, training and professional experience).

We may also collect other types of information (that may constitute Personal Data) by automated means, or indirectly from you or from third parties (websites or social networks) such as:

• Information relating to the use of BTOMIC Platforms, including your IP address and other browsing data (including the browser and type of device used) through the use of cookies or similar technology installed on your device. Certain cookies are needed to ensure that BTOMIC Platforms function properly, and others are used for analytic purposes, which help us to provide you with more customised services and a better digital experience. For more information about cookies and how to change your preferences, please consult our cookie usage policy;
• Information that you share publicly on social networks as part of your interaction or not with BTOMIC.

2.3 ON WHICH GROUNDS DO WE COLLECT YOUR PERSONAL DATA?

• We undertake to process your Personal Data only if and to the extent that at least one of the following legal bases applies:
• You have given your consent to process some of your Personal Data for one or more specific purposes
• Processing is necessary for the performance of a contract (related to your purchase, repair order or other services) or in order to take action, at your request, prior to entering into such a contract
• Processing is necessary for compliance with a legal obligation to which we are subject
• Processing is necessary for the purposes of the legitimate interests that we pursue (e.g. security purposes, personalized maintenance advice, personalized offers of products and services).

3.1 FOR WATCH PURPOSES DO WE USE YOUR PERSONAL DATA?

We process your personal data for the following purposes:

• If you fill out a contact form providing your name, email-address, telephone number, preferences, etc., we use your data for answering your questions, sending you information or performing other tasks you ask us to;
• If you register an account with us, then we process the data required to open that account, for example your name, address, email-address, password, profile picture, third party account data (if you register using your Facebook account, for example), etc. to allow your registration and management of your account;
• If you use our interactive features, we process the data required to use these features to allow you and manage their use, for example, your name and email-address to appear in a ranking and to send you updates regarding the online game in which you participated;
• If you are an existing customer, we may send you advertisement about our products and services using, for example, your name and postal address;
• If you subscribe to a service like our newsletter by providing us with your email-address and name, then we use this data for sending you our newsletter;
• If you participate in a marketing promotion, then we use the data we require from you to allow your participation, for example, to manage your invitation for an event or to determine and contact the winner of a contest;
• If you order a product, material or a service, we need and process the data required to fulfill your order, such as your name, telephone number, delivery address, credit card information, email-address, etc., for example to confirm your order, process your payment, check credit scoring, deliver the ordered items and contact you for delivery purposes;
• If you answer one of our queries and provide us personal data such as name, age, occupation, etc., then we use this data to analyze the query results and draw conclusions therefrom;
• If you consent to receive marketing information where prompted, then we use your data to send you promotional materials and other communications, to communicate with you about, and administer your participation in, special events, contests, sweepstakes, programs, offers, surveys and market research, to provide advertisements to you about our products and services, to tailor your use of the Website, marketing experience, and communications according to your preferences and our terms;
• If you interact with us on third party social networks, then we process your data for such interaction with you on these networks (our interactions with you on a third party social network would be subject to that network's privacy policies and terms of use);
• We process your personal data also to comply with and enforce applicable legal requirements, our Terms of Use, relevant industry standards, contractual obligations and our policies;

3.2 HOW DOES TARGETED ADVERTISING WORK AND HOW DO WE USE IT?

Targeted advertising works through third-party tools, technologies and services such as advertising agencies and analytics providers. It enables us to tailor our communications and advertising offers to your personal interests and preferences, and to manage the effectiveness of our marketing strategy.

This way, we can first create a summary of your preferences based on the information you have provided and your purchase history.

We can then create custom audiences (made up of people who have filled out the Client Form, visited our website or interacted on BTOMIC Platforms or on platforms operated by third-party applications and/or social networks - such as Google, Facebook, Instagram) through cookies or by converting your email address (as well as other information communicated via our Client Form) into a unique (anonymized) value that can be matched, by these third-party applications and/or social networks, with a user of their platforms. This process enables targeted advertising of our products and services to be shown to you (and, where applicable, other users with a profile similar to yours) on these platforms according to your personal interests and preferences.

By means of other targeting technologies, we may be required to share, with said third-party applications or social networks, data that allows you to be identified, including data on how you interacted with BTOMIC Platforms (e.g. viewing a product and adding it to the shopping basket) following said targeted advertising on these third-party applications or social networks, in order to measure and optimize our advertising.

You can choose not to receive advertising and/or not to allow these analytics tools and other targeting technologies by deselecting the "cookies for targeted advertising" category via the cookie control tool. However, we do not control third-party targeting technologies, even if they are associated with BTOMIC Platforms or our advertising. We therefore suggest that you read the general terms and conditions of use, user policies, privacy policies, and other practices of third-party applications and social networks regarding the collection, storage, and sharing of your Personal Data.

3.3 HOW LONG CAN YOUR PERSONAL DATA BE RETAINED?

Unless required by law or because of security constraints stipulating another period, we may retain or process your Personal Data for as long as is necessary to achieve the purposes described above (the retention periods provided for each purpose are also specified above) insofar as you do not withdraw your consent to its processing (for one or more purposes) or exercise your right to object before the expiry of one of these periods (by any of the means described below in the “How can you contact us?” section). Your Personal Data will be retained in accordance with legal obligations, available technologies and costs of implementation.

3.4 DOES WE SHARE YOUR PERSONAL DATA TO THE THIRD PARTY? IF SO ,WITH WHOM?

We may only share your Personal Data with third parties in the few following cases:

• Service providers supporting us in our business operations (e.g. to deliver products, allow payment authorization, for the organization of events or to send our BTOMIC e-newsletter, to support, manage and maintain our BTOMIC Platforms, mitigate risk, help prevent fraud and promote trust and safety);
• Third parties, courts or regulators or any other third parties if it is required by law or in connection with a legal claim or proceeding or to combat fraud.

We expect all these third parties to provide necessary guarantees of confidentiality and security and to take appropriate organizational and technical measures in compliance with the applicable laws. Our service providers may only process the Personal Data we share with them according to and within the limits of our instructions.

4.1 WHAT RIGHTS DO YOU HAVE REGARDING YOUR PERSONAL DATA?

• The right of access: You have the right to know what Personal Data has been collected about you and how such Personal Data has been processed;
• The right to rectification: You have the right to request changes to inaccurate Personal Data;
• The right to object: You may declare that you do not want your Personal Data processed (in whole or in part) at any time;
• The right to be forgotten: You may exercise this right particularly when you no longer consent to the processing of your Personal Data. You have the right to withdraw your consent anytime (by any of the means described below under the “How can you contact us?” section). The right to be forgotten is not an absolute right and only applies in certain circumstances;
• The right to restrict processing: You have the right to limit the processing of your Personal Data, i.e. limit the way we use your Personal Data. This is an alternative to exercising your right to be forgotten. This right is not an absolute right and only applies in certain circumstances;
• The right to be informed: You have the right to obtain any and all information regarding the processing of your Personal Data that is clear, correct, comprehensive and easy to access;
• The right to data portability: You have the right to transfer (or to ask for the transfer of) your Personal Data from one electronic processing system to another electronic processing system;
• The right in relation to automated decision making or profiling You have the right not to be subject to a decision based solely on automated processing, such as profiling;
• The right to lodge a complaint: You have the right to lodge any complaint that you may have with a supervisory authority.

These rights may be subject to exceptions or limitations (e.g. when your Personal Data has been processed for security purposes or stored for legal or contractual obligations) and must account for available technology and the cost of implementation.

In certain cases, we will need to verify your identity before processing a request you may have based on the above-mentioned rights.

4.2 HOW CAN YOU CONTACT US?

Through the “Contact Us” form (www.btomic.com/page/contact-us);

By writing to the BTOMIC Customer Service Office either by email (service@btomic.com) or by posted letter (Sheridan, WY 82801 USA);

By signing the consent withdrawal in the Client Form (only to withdraw your consent).

We reserve our right to change this Privacy Policy at any time. A notification regarding any substantial changes to this Privacy Policy will be posted on our BTOMIC Platforms. Notwithstanding, it is your responsibility to stay abreast of any changes made to our Privacy Policy.