Privacy and Cookies Policy – MODON CUSTOMER PORTAL APP

Effective Date: October 8, 2025

Last Updated: October 8, 2025

1. Introduction

Digital Partners Global (the “Company,” “we,” “us,” or “our”) is a limited liability company registered in Dubai, United Arab Emirates. Our Company recognizes the fair and lawful collection, controlling and, when incident, the processing of your personal data and is committed to comply with the provisions of this Policy throughout its activity and services.

We are committed to safeguarding personal data in accordance with the Federal Decree Law No. 45 of 2021-Regarding the Protection of Personal Data, also known as the Personal Data Protection Law or PDPL and, where incident and applicable, the General Data Protection Regulation (EU) 2016/679 (“GDPR”), the California Consumer Privacy Act of 2018 (“CCPA”), as amended by the California Privacy Rights Act (“CPRA”), and other applicable data protection laws.

This Privacy and Cookies Policy (“Policy”) describes how we collect, use, disclose, store, and protect your information when you access or use:

• Our website(s) (the “Domain”), and/or
• Our software application(s), including the Customer Portal mobile application (the “App”), specifically designed for MODON.

By using the Domain, the App, or our services, you acknowledge that you have read, agreed with and understood this Policy.

2. Definitions

• User / You: Any individual who accesses or uses the Domain or the App.
• Personal Data (PDPL): any information related to or belonging to a natural person, either identified or identifiable, being understood that such information may be used as stand-alone information or in conjunction with other types of data, allowing the identification of a natural person (generally called “data subject”).
• Personal Data (GDPR): Any information relating to an identified or identifiable natural person (“data subject”).
• “Sensitive Data” / “Special categories of personal data” (PDPL): Personal Data on or referring to ethnic or racial origin; health data; religious, political or social beliefs; biometric data; genetic data; political opinions; bank account numbers or credit / debit card data (enumeration non limitative).
• Sensitive Data / Special Category Data (GDPR): Includes racial or ethnic origin, religious or philosophical beliefs, political opinions, trade union membership, genetic or biometric data, health information, or sexual orientation.
• Personal Information (CCPA/CPRA): Information that identifies, relates to, describes, or could reasonably be linked to a California consumer or household.
• Sale / Share of Personal Information (CCPA/CPRA): Disclosing personal information to a third party for monetary or other valuable consideration, including cross-context behavioural advertising.
• IP Address: Your “IP Address” is a number that is automatically assigned to the computer that you are using by your Internet Service Provider (ISP). An IP Address may be identified and logged automatically in our records when you access the Domain or the App. Such information is useful to us in order to calculate and monitor the level of usage of our Domain / App, administer them and further understand the demographics of our overall Users.

3. Categories of Data We Collect

We may collect the following categories of data:

Personal Data / Personal Information:

• Identification: name, title, company, job function, email address, and contact details.
• Digital identifiers: IP address, login credentials, cookie identifiers, and device ID.

Sensitive Data:

• We do not intentionally collect or process Sensitive Data.

Other Information:

• Browser/device information, operating system, app usage logs, and demographic insights derived from aggregated data. Specifically, such information does not reveal your specific identity or does not directly relate to an identifiable individual. This might include, for instance, Domain or App usage data; information collected through cookies, pixel tags, and other technologies; demographic data and resulting data from aggregating Personal Data with non-personal data.

4. How We Collect Data

• Directly from You: when you register, contact us, subscribe, or otherwise interact with our services.
• Automatically: via cookies, analytics tools, usage tracking, and log files.
• From Third Parties: such as business partners, social media platforms, or public databases. We may also collect data from other sources, such as Your events participation in relation to our services.

Other data and information. Directly or via third party service providers, we may collect the below types of data:

• Through Your Browser or Device: Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Macintosh), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version, and the name and version of the Domain or App you are using.
• Through Your Use of the Apps: When you download and use the App in your terminal, we and our service providers may gather and monitor usage data, including the date and time your device accesses our servers, as well as the information and files downloaded to the App, linked to your device’s unique identifier.
• Through Cookies and Other Similar Technologies: We may use third parties to serve advertisements or links to other websites that may be of interest to you, based on information collected about your use of our Domain and App.  By using these, you expressly acknowledge and agree that third party companies may place or recognize a unique cookie on your browser (including through the use of pixel tags and web beacons).
• Through Aggregation of Data: Aggregated data does not personally identify you or any other User, however we may do such aggregation to determine a specific concentration of Users in a geographical area.

5. Legal Basis for Processing (GDPR and PDPL)

We process Personal Data only where a valid legal basis exists:

Consent: e.g., for marketing communications or use of cookies.

Contractual Necessity: to provide requested services.

Legal Obligation: to comply with applicable laws.

Legitimate Interests: to improve services, prevent fraud, and maintain security, provided such interests do not override your rights.

6. Purposes of Processing

We use Personal Data for the following purposes:

• Service delivery and account management.
• Communication of administrative and contractual information.
• Marketing, subject to consent or opt-out rights.
• Fraud prevention, security monitoring, and legal compliance.
• Business analysis, product development, and performance measurement.

7. Data Sharing and Disclosure

We do not sell or rent Personal Data. We may share data with:

• Service Providers: cloud hosting, analytics, payment processors, and IT support.
• Legal Authorities: where required by law or regulatory obligations.
• Business Transfers: in the event of mergers, acquisitions, or restructuring.

You must acknowledge that not all data we collect about Users is Personal Data. In relation to data that qualifies as Personal Data, we may collect:

• Identification data, for example, name, contacts, a company that you represent or own or are affiliated with;
• Data relating to academic qualifications, for example, job title, qualifications, certifications;
• Professional and work experience data, for example, function, job description, company, office address, employer information;
• Professional activity data, for example, business activities, information relating to processes and files, data relating to due diligence, data related to your interaction with other Users.

8. International Data Transfers

Personal Data may be transferred outside the country of collection, including to jurisdictions that may not provide equivalent data protection. Where required, we implement safeguards under the statutory provisions. By using our service, you expressly consent that your Personal Data is or may be stored into a SQL database and will be deployed into a Salesforce system under the subscription and account of a third party associated with Us (i.e. Modon). In terms of additional protection, our services provide password hashing or any other methods that are reasonably acceptable to us from time to time. By using our Domain and / or App, you expressly acknowledge and agree that Salesforce or associated parties with Us (i.e. Modon) are not under our control therefore we assume no liability for their actions.

9. Data Retention

We retain Personal Data only for as long as necessary to fulfil the purposes outlined in this Policy or as required by law, generally for five (5) years from collection.

10. Security

We have developed and constantly implement contingency measures, including security controls to prevent unauthorized access to our systems. While we take reasonable precautions to protect data from loss, misuse, unauthorized access, alteration, and disclosure, it's important to understand that no security measures can guarantee complete protection against breaches or hacking. You must also be aware that certain data is stored in cloud structures that are finally under the control of third parties. As a result, there is always some level of risk when sharing personal information online. If you believe that the security of your account has been compromised, or if you feel your interaction with us is no longer secure, please notify us immediately.

11. Your Rights

Under PDPL:

• You may withdraw the consent to this Policy and underlying processes at any time. However, such withdrawal will not affect the lawfulness of any processing occurring prior to such withdrawal and made in compliance with this Policy. In case of total withdrawal of your consent, you may not be able to use our services and this implies termination of provision of our Services with immediate effect, according to our Terms and Conditions (please insert hyperlink). Any further usages of the Domain and / or App will imply recollection of Personal Data, subject to this Policy.
• You may opt-out of receiving marketing messages from us by sending an email to us or unsubscribing to our email marketing materials, stating your request. Please note that if you opt-out of receiving marketing-related emails from us, we may still send you important administrative messages such as updates on our Terms and Conditions, updates in this Policy etc.
• You may wish to know what Personal Data we collect or have about you and we agree to provide you such data, via a machine readable format;
• You may notify us with a request to rectify, amend or correct the Personal Data we collect or have about you and we will inform you as soon as these tasks have been completed;
• You may notify us with a request to delete or stop processing your Personal Data, case in which we will notify you when the processing of Personal Data has ceased;
• You may notify us on your decision to process Personal Data only according to specific purposes (for example to receive only App related information, and for no other purposes). We engage to comply with such request and inform you in writing of the required changes, as and if needed.

Under GDPR (EU/EEA):

• Right of access to your data.
• Right to rectification or erasure (“right to be forgotten”).
• Right to restriction of processing.
• Right to object to processing.
• Right to data portability.
• Right to withdraw consent at any time.

Under CCPA/CPRA (California Residents):

• Right to know what categories of personal information we collect, use, disclose, or sell/share.
• Right to request deletion of your personal information.
• Right to opt out of the sale or sharing of personal information.
• Right to correct inaccurate information.
• Right to limit the use of sensitive personal information.
• Right to non-discrimination for exercising your rights.

For California residents, you may also exercise rights via a “Do Not Sell or Share My Personal Information” link on our website (if applicable).

We will verify your identity before fulfilling requests and respond within the timelines mandated by law.

Requests may be submitted to kdalil@dpg.email.

12. Cookies and Tracking Technologies

We use cookies and similar technologies for:

• Functionality and performance optimization.
• Analytics and audience measurement.
• Personalized marketing and advertising (with consent where required).

You may disable cookies in your browser settings. Under CCPA/CPRA, you have the right to opt out of cookies used for cross-context behavioural advertising.

Google Analytics and similar technologies offered by Google Inc. provide website traffic statistics, traffic source analysis, and conversion tracking. These technologies utilize cookies, and their operations are solely determined and controlled by the respective companies, not by us.

If and when we decide to use such technologies, the purpose would be to enhance our platforms integration, marketing and sales purposes, metrics and analysis, provision of our services. By accessing the Domain and / or the App, you consent to the data processing requirements as per this Policy (in so far as we do processing) and of third party providers such as Google Inc. (for their part of the processing activities).

13. Third-Party Links and Services

Our Domain and App may link to external websites, services, or social media platforms. These third parties maintain independent privacy practices, which we do not control. We disclaim responsibility for third-party privacy policies.

14. Policy Updates

We may revise this Policy from time to time. Updates will be posted on the Domain and/or the App, and the “Last Updated” date will reflect the changes. Continued use of our services constitutes acceptance of the revised Policy.

15. Contact Information

For questions, concerns, or to exercise your rights under PDPL, GDPR or CCPA/CPRA and general data queries, please contact us at:

kdalil@dpg.email

432 AMC Boulevard B Building, Ajman Media City

For EU residents, you may also lodge a complaint with your local Supervisory Authority. For California residents, you may appoint an authorized agent to submit CCPA requests on your behalf.

Annex 1

Do Not Sell or Share My Personal Information

Effective Date: October 8, 2025

Under the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA), California residents have the right to direct businesses not to sell or share their personal information.

We respect your privacy choices and provide you with the ability to opt out of such practices.

1. What Does “Sell” or “Share” Mean?

For purposes of California law:

“Sell” means disclosing personal information to a third party for monetary or other valuable consideration.

“Share” means disclosing personal information to a third party for cross-context behavioral advertising (for example, targeted advertising across different websites or apps).

We do not sell personal information for money. However, we may share personal information with advertising, marketing, and analytics partners, which may constitute “sharing” under the CPRA.

2. Your Rights

As a California resident, you have the right to:

• Opt out of the sale or sharing of your personal information.
• Request that your personal information not be disclosed to third parties for targeted advertising purposes.
• Change your privacy preferences at any time.

3. How to Exercise Your Rights

You may opt out of the sale or sharing of your personal information by:

• Clicking the “Do Not Sell or Share My Personal Information” link available on our website or within the App.
• Submitting a request via email at: kdalil@dpg.email
• Calling us at: +971 55 448 1593 (Khalid Dalil)

When you submit a request, we may need to verify your identity before processing it. You may also designate an authorized agent to exercise your rights on your behalf.

4. Cookies and Targeted Advertising

Certain cookies and tracking technologies used on our Domain and App may involve sharing data with advertising and analytics providers. By opting out, such cookies will be disabled to the extent required under California law.

5. Non-Discrimination

We will not discriminate against you for exercising your rights under the CCPA/CPRA. You will continue to have access to our services, though certain features that rely on personalized advertising may be limited.

6. Contact Us

If you have questions or would like further information about your privacy rights, please contact us at:

kdalil@dpg.email

432 AMC Boulevard B Building, Ajman Media City