Privacy policy

1. Who We Are

 The Platform and related services are provided by FJDYNAMICS PTE. LTD. and its applicable affiliates. VIRTUX INNOVATIONS PTE. LTD. has its registered address at 101 Thomson Road, #28-03A United Square, Singapore 307591. The entity responsible for processing your personal data may vary depending on your country or region and the specific products or services you use.

For processing activities described in this Policy for which we independently determine the purposes and means of processing personal data, we act as the data controller, personal information handler, or an equivalent responsible entity under applicable data protection laws. Please refer to "How to Contact Us" and the applicable supplementary jurisdictional terms for the relevant responsible entity and contact details.

Where we process personal data solely on behalf of and according to the instructions of a business customer, partner, or other third party, that business customer, partner, or third party may be the controller of the relevant personal data. We will process the data in accordance with our agreements with them and applicable laws.

2.What Personal Data We Collect

When you use the Platform and/or services, we may ask you to provide personal information. We will explain what information is requested and why when we ask for it. Certain personal information is necessary for the basic functions of the Platform; if you decline to provide it, the corresponding functions may be unavailable. You may choose whether to provide other personal information collected to improve your experience. Declining to provide such information will not affect your use of basic functions, and we will not refuse to provide services on that basis. Examples of information we ask you to provide directly include:

· Account-related data you provide when creating an account, including your account name, password, email address, and mobile phone number.

· Any information you provide in connection with contacting our customer support.

· Customer-related data you provide when using lead, opportunity, channel, and similar functions on the Platform, including customer name, address, individual name, email address, and mobile phone number.

· Buyer- and seller-related data you provide when using purchasing, sales, and similar functions on the Platform, including payment method, names, addresses, email addresses, and mobile phone numbers.

· Device-related data you provide when using technical support functions on the Platform, including device version number, online status, and serial number.

Materials submitted for customer support or after-sales service may contain people's locations, images, or voices, or incidentally record employees, contractors, visitors, minors, or other individuals. If such materials constitute sensitive personal data, special categories of personal data, or other specially protected data in a particular context, we will process them only to the extent necessary to enable the relevant product functions, safeguard device and site safety, troubleshoot faults, or provide after-sales service. We will obtain explicit or separate consent, provide necessary notices, or take other necessary measures as required by applicable laws. Please avoid submitting information of this kind that is unrelated to the relevant products or services.

We use the relevant information you provide only to the extent necessary for customer support, troubleshooting, remote diagnostics, repair, warranty service, safety incident handling, and other after-sales services.

When you use the Platform and/or services, we may also automatically collect various types of information from you. Some information is collected anonymously, while other information is subsequently linked to information you have already provided. We consider information to be personal data if it is linked to your account information or can be traced to a specific individual. Information automatically collected during your use of the Platform and/or services includes:

· IP address.

· Geolocation information inferred from your IP address.

· Basic hardware and operating system information.

· Event data generated by changes or updates to user account information.

· Transaction data relating to purchases of paid functions on the Platform.

· Cookie data about how you use our website (see "How We Use Cookies and Similar Technologies" below).

Cookies, local storage, session tokens, and similar technologies may generate or record login and session status, language and function preferences, and similar information. Depending on the actual integration, we will identify the relevant third parties, processing purposes, and information types in a Cookie or SDK list, product interface, or another appropriate location, and provide ways to consent, decline, or disable them as required by law. Unless we have another lawful basis and have provided the necessary notice or obtained consent, we will not use precise device operation data, site images, videos, or remote operation records for advertising or cross-context profiling.

Some device data may be stored only on your device, local terminal, or in a storage environment under your own control. We receive such data only when you actively upload it, enable a relevant synchronization function, or when it is genuinely necessary to provide the relevant service.

3. Device Data and Your Control 

Some products may generate operation, work, location, log, image, video, or other technical data on the device. Depending on the product and function, some information may be stored only on the device, local terminal, or in an environment under your own control.

Where we can obtain data only after you actively upload or synchronize it, authorize access, or enable the relevant function, we will provide corresponding settings or choices according to the specific product functions.

The scope of data we can actually access depends on the products and functions you use, your account settings, and your choices.

4. How We Use Your Personal Data

This section provides more detail about the types of personal information we collect from you and why we collect them. For users residing in the United Kingdom or the European Economic Area (the "Relevant Jurisdictions"), it also states the legal bases on which we rely to process your data.

Information you provide to us, directly or through third parties:

Data category	Purpose	Typical data	Primary basis for processing
Account and contact information	Creating and completing accounts, login verification, and customer service	Account ID, account name, password, email address, mobile phone number	Performance of a contract / provision of services
Customer and channel information	Providing lead, opportunity, and channel management functions	Customer name, address, individual name, email address, mobile phone number	Performance of a contract / provision of services
Purchasing, sales, and payment information	Providing purchasing, sales, and online payment functions	Payment method; names, addresses, email addresses, and mobile phone numbers of buyers and sellers	Performance of a contract / provision of services
Device and customer support information	Providing device technical support, troubleshooting, and after-sales services	Device version number, online status, serial number, and information you submit to customer support	Performance of a contract / provision of services

 

Personal information automatically collected or generated as part of the services:

Personal Data	Purpose	Typical data	Primary basis for processing
Network, location, and technical information	Improving Platform version information and ensuring product and service functions operate properly	IP address, IP-based geolocation, basic hardware and operating system information	Performance of a contract / provision of services
Account event and transaction data	Providing account maintenance and services relating to paid functions	Account change or update events, transaction data for purchases of paid functions	Performance of a contract / provision of services
Cookies and similar technologies	Maintaining login and session status and saving language and function preferences	Cookie data, local storage, session tokens, and preference settings	Performance of a contract / provision of services; consent where legally required

 

5. Cookies and Similar Technologies

We may use cookies and similar technologies, such as web beacons, log files, scripts, and eTags ("Cookies"), to improve your service experience. Cookies are small files that allow us to provide certain features and functions when placed on your device.

(1) Cookies

To keep the Platform website operating properly, make your experience easier, and recommend content that may interest you, we store Cookies, Flash Cookies, or other local storage provided by your browser or associated applications on your computer or mobile device. These generally contain identifiers, site names, numbers, and characters and are collectively referred to as "Cookies". Cookies enable websites to store your preferences or information about goods and/or services in your shopping cart.

Where supported by your mobile device or browser add-on services, you can change the extent to which you accept Cookies or reject our Cookies. Doing so may, in some cases, affect your ability to use our products and/or services securely and may require you to change user settings each time you use the Platform and/or services.

(2) Similar technologies

In addition to Cookies, we use web beacons, pixel tags, ETags, and similar technologies on our website. For example, emails we send may contain links to content on our website. If you click a link, we track that click to understand your product or service preferences and proactively improve your customer service experience. A web beacon is typically a transparent image embedded in a website or email. Pixel tags in emails allow us to determine whether an email has been opened. If you do not want your activity tracked in this way, you may unsubscribe from our mailing list at any time.

An ETag (entity tag) is an HTTP protocol header transmitted between a browser and server and can be used as an alternative to Cookies. ETags help us avoid unnecessary server load, improve service efficiency, and save resources and energy. We may also use ETags to record your identity so that we can better understand and improve our products or services. Most browsers let you clear cached data through their settings. However, disabling ETags may affect your ability to enjoy a better product and/or service experience.

6. How We Manage Your Personal Data

Your personal data may be stored or processed in different countries or regions depending on the products and services you use and your location. We determine storage locations in accordance with applicable laws and take the appropriate measures described in "Local Storage and Cross-Border Access to Your Personal Data" when cross-border transfers are involved.

We retain your personal data only for as long as necessary to achieve the processing purposes described in this Policy, unless a different period is required or permitted by law.

When determining specific retention periods, we consider: (1) the time required to provide the relevant products or services; (2) the duration of our business relationship with you; (3) the form, volume, and sensitivity of the data; (4) security, fraud prevention, and dispute resolution needs; and (5) applicable legal, tax, accounting, supervisory, and limitation-period requirements.

Where the law requires specific retention periods for particular categories of data, we comply with those requirements.

Once we no longer have a legitimate business need to process your personal data and its retention period has expired, we will delete or anonymize it. If deletion or anonymization is not possible, we will pseudonymize and/or securely store the data and isolate it from any further processing until it can be deleted or anonymized.

We strive to protect your personal data from unauthorized access, use, disclosure, alteration, destruction, damage, loss, or other unlawful processing by strengthening administrative and technical safeguards, such as access controls, encryption, and staff training. No network environment is completely secure. If a personal data security incident occurs, we will fulfill our notification obligations. Notices may include the basic circumstances and potential impact of the incident, measures we have taken or will take, and recommendations to help you prevent and reduce risks. We will endeavor to notify you promptly by telephone, email, push notification, or other means. In certain circumstances, we may publish a notice on our official website. We will also report our handling of the incident as required by regulatory authorities.

If you know or have reason to believe that your personal data has been lost, stolen, misappropriated, or otherwise compromised, or that it has actually or potentially been misused, please contact us promptly.

7. How We Share Your Personal Data

We may share personal data with applicable entities within our group to the extent necessary for global service delivery, account management, technical support, information security, internal management, and other purposes described in this Policy. Where sharing your personal information with third parties is genuinely necessary, we will provide a consolidated list specifying recipients' names and contact details, the types of information shared, the purposes and methods of sharing, and the security measures taken. You can consult the personal information sharing list within the Platform. These circumstances include:

(1) Third parties supporting our services, including payment and logistics partners and cloud service providers that process information described in this Policy on their servers to provide services or support related communications. Through contracts, data protection agreements, and other appropriate measures, we require these providers to process personal data in accordance with our instructions, agreed purposes, and applicable laws.

(2) Companies within our group that process your personal information to operate services around the world. All such group companies may use your personal information only in accordance with this Policy.

(3) We may share your personal information to safeguard security, comply with the law, or respond to requests from regulators, judicial bodies, law enforcement agencies, and other third parties. For example:

In some circumstances, we are legally required to disclose information about you to competent authorities, for example to comply with legal obligations or procedures, enforce our terms, address security or fraud issues, or protect our users. Under valid legal processes, such as subpoenas, court orders, or search warrants, disclosures may occur with or without your consent and with or without notice to you. Legal processes often prohibit us from notifying you of such disclosures. Where a government agency does not provide the required subpoena, court order, or search warrant, we may seek your consent before responding to its request. We may also disclose your information to:

· Enforce our terms and conditions and other agreements, including investigating potential breaches.

· Detect, prevent, or otherwise address security, fraud, or technical issues.

· Protect the rights, property, or safety of ourselves, our users, third parties, or the public as required or permitted by law, including exchanging information with other companies and organizations to prevent fraud and reduce credit risk.

(4) Third parties acquiring all or most of our business. We may disclose your information where: (a) we sell, transfer, merge, consolidate, or restructure any part of our business, merge with or acquire another business, or establish a joint venture, in which case we may disclose your data to potential buyers, new owners, or other parties involved in the business change; or (b) we sell or transfer any of our assets, in which case information we hold about you may be among the assets sold and may be transferred to potential buyers, new owners, or other parties involved in the sale or transfer.

(5) Third-party SDK providers. To enable you to use the Platform's functions and services normally, we embed the following authorized partner SDK or similar application in the Platform:

Application Name	Third Party Name	Data Collected	Purpose	Data Processing	Third Party Privacy / Terms
Klaviyo APIs	Klaviyo	Email address; product(s) of interest	Marketing communications and related Website marketing functions, where permitted	Processed through Klaviyo services	https://www.klavi yo.com/legal/api-terms

 

We conduct rigorous security testing of application programming interfaces (APIs) and software development kits (SDKs) through which authorized partners obtain personal information. We agree on strict data protection measures with these partners to ensure that they collect and process your personal data in accordance with our agreements and this Policy.

8. Local Storage and Cross-Border Access to Your Personal Data

For cross-border transfer arrangements applicable to specific countries or regions, please refer to "Supplementary Terms for Specific Jurisdictions".

As a general principle, we store your personal data on local servers or in data centers in your country or region.

Where necessary to provide technical support, after-sales services, system maintenance, security, or other necessary services, our affiliates, technical support teams, or service providers in other countries or regions may access the relevant data remotely to the extent necessary.

In some jurisdictions, such remote access from abroad may constitute a cross-border transfer or international data processing. We will take necessary contractual, technical, and organizational measures under applicable laws and complete any legally required notification, consent, filing, certification, assessment, or other compliance procedures.

Unless otherwise required by law or separately authorized by you, overseas parties accessing the data will not thereby store your personal data separately in their own countries or regions.

 

9. Your Rights

The laws of certain jurisdictions grant specific rights to service users, as described in this section.

This section applies to users in the Relevant Jurisdictions. If you are outside those jurisdictions, please refer to the supplementary jurisdictional terms for details of your rights and how to exercise them.

The subsections "Access", "Rectification", and "Erasure" also apply to users in Canada.

Access

You have the right to access personal information we hold about you and learn how we use it and with whom we share it.

Portability

You have the right to receive a copy of certain personal information we process about you. This includes information processed with your consent or under our contract with you, such as for customer support, as detailed in "How We Use Your Personal Information". You have the right to receive it in a structured, commonly used, machine-readable format. Subject to certain exceptions, you may also ask us to transfer it to another party. We will provide further information if you make such a request.

If you ask us to transfer personal data to a third party, please include details of that party. We can transfer data only where technically feasible. We may be unable to provide personal information if doing so would adversely affect another person's rights or privacy, for example by disclosing their information or our trade secrets or intellectual property.

Rectification

You can update your account information at any time by logging in to the Platform. If you believe information we hold about you is inaccurate or incomplete and needs to be changed, please notify us as described in "How to Contact Us".

Erasure

You can delete your account and have the right to request deletion of your personal data that we store. You may also contact us to request deletion of your account and/or personal data. We will handle your request within the period required by applicable laws. Deleted accounts cannot be restored. We may retain certain information to meet legal requirements or for security purposes, and may retain certain information anonymously.

We may need to retain personal information where relevant data protection laws provide reasonable grounds, such as defending legal claims or protecting freedom of expression. We will notify you in such cases. If you ask us to delete information made public on the service and there are grounds for deletion, we will take reasonable steps to try to inform other parties displaying or linking to that information that they should also delete it.

Restriction of Processing to Storage Only

In certain circumstances, you have the right to require us to stop processing personal information we hold about you, except for storage. However, we may use it again if we have legitimate grounds under relevant data protection laws, such as establishing legal claims or protecting others. If we agree to stop processing the information, we will try to inform any third parties to whom it has been disclosed and ask them to stop processing it as well.

Withdrawal of Consent

Some processing may be based on your consent. You may withdraw consent at any time, without affecting processing carried out before withdrawal or any other existing legal basis for that processing.

If your consent is required to process personal information and you do not provide it or withdraw it, we may be unable to provide the expected services.

Objection

Where processing is based on our legitimate interests rather than a legal obligation, you may object at any time on grounds relating to your particular situation. We will stop processing unless there are compelling overriding grounds or the data is necessary to establish, exercise, or defend legal claims. If you do not want your personal data used for marketing, you may email infosec@fjdynamics.com at any time to change your preferences.

Complaints and Legal Action

If you wish to complain about how we process your personal information, please contact us first. We will endeavor to address your concerns as soon as possible. If you believe we have breached relevant data protection laws, you may complain to the data protection authority in your country or region of residence or work.

You may also take legal action concerning any infringement of your rights in connection with the processing of your personal data.

Announcements

We may send announcements or other administrative notices when we consider it necessary, such as when temporarily suspending access for maintenance, security, or privacy reasons. You cannot opt out of these service-related announcements, as they are not promotional.

Advertising

If we use automated decision-making to send you information, conduct commercial marketing, or make decisions that significantly affect your personal rights and interests, we will ensure transparency and fair and impartial outcomes and provide non-personalized options or ways to decline. You have the right to ask us to explain the relevant processing rules and to refuse decisions made solely through automated decision-making. You may contact us through the methods in "How to Contact Us" to request that personalized advertising or promotional information no longer be sent to you.

How to Exercise Your Rights

You can exercise your rights using the contact methods in "How to Contact Us". We will handle requests within the periods required by applicable laws. We reserve the right to refuse a request if it affects the rights or privacy of others. If a request is manifestly unfounded or excessive, we reserve the right to charge a reasonable fee or refuse to act.

We may need information from you to verify your identity and establish your entitlement to these rights.

10.How We Protect Children's Personal Data

Our products and services are primarily intended for adults and business users, not specifically for children. We will not knowingly collect children's personal data in violation of applicable laws. Where the relevant products or services genuinely require processing of children's personal data, we will obtain valid authorization from parents or guardians, or take other necessary safeguards, under the laws of the child's country or region. If we discover that children's personal data has been collected without appropriate authorization, we will delete it or take other necessary measures in accordance with the law.

11. How This Policy Is Updated 

 We may update this Policy from time to time. If it is revised, we will promptly publish the new version prominently on this webpage. For material changes, we will provide more prominent notice, such as by email, text message, or website pop-up.

12. How to Contact Us

If you have comments, suggestions, or questions about this Policy, or requests or inquiries concerning your personal data, you may contact us using the details below. As a general rule, we respond within 30 days.

Contact: Data Protection Officer

Email: infosec@fjdynamics.com

Address:101 Thomson Road, #28-03A United Square, Singapore 

Postal code: 307591 

This version of the Privacy Policy was updated on September 15, 2026 and takes effect on September 15, 2026.

13. Supplementary Terms for Certain Jurisdictions

The laws of certain jurisdictions provide additional terms for service users, as described in this section.

If you are a user in one of the jurisdictions below, the terms listed under that jurisdiction apply in addition to the preceding terms of this Policy. In the event of a conflict, the supplementary terms for your jurisdiction prevail.

United Kingdom (UK GDPR and the Data (Use and Access) Act 2025)

This subsection applies to UK users. Under the Data (Use and Access) Act 2025 (DUAA), our processing of UK users' personal data is subject to the following arrangements under the UK GDPR and DUAA: for automated decisions significantly affecting you, we will provide meaningful human intervention, information, and the right to object; we will obtain your consent before using Cookies other than necessary and low-risk Cookies, such as those for statistical analysis, preferences, security, and fraud prevention; some processing may rely on recognized legitimate interests; and we will respond to data subject access requests within a reasonable and proportionate scope.

California

This subsection applies to California residents covered by the California Consumer Privacy Act of 2018 ("CCPA").

Collection and disclosure of personal information

In the preceding 12 months, we have collected and disclosed the following categories of personal information from or about you or your device:

· Identifiers, such as account ID, password, IP address, device ID, email address, and mobile phone number.

· Internet or other electronic network activity information about your use of the Platform and/or services, including logging in and other device information described in the main body of this Policy. This information is collected directly from you and your device.

· Commercial information about transactions within the Platform and/or services, such as the services purchased and their prices. This information is collected directly from you and your device.

· Other information described in Section 1798.80(e), collected directly from you as our consumer.

We collect personal information to:

· Provide services, maintain your account, and perform related functions.

· Improve our services, including their functions.

· Support security and verification, including preventing and detecting fraud.

· Resolve and correct technical issues and vulnerabilities.

For more information on the use of each type of personal information, see "What Personal Data We Collect" and "How We Use Your Personal Information".

We disclose personal information to the following types of entities:

· Other companies in our group that process personal information to operate the services.

· Other companies providing or supporting services on our behalf, which are contractually prohibited from retaining, using, or disclosing personal information for purposes other than providing services to us.

· Regulators, judicial bodies, and law enforcement agencies.

· Entities acquiring all or most of our business.

In the preceding 12 months, we have not sold California residents' personal information for monetary or other valuable consideration, or shared it for cross-context behavioral advertising.

Rights under the CCPA

If you are a California resident, you have the right to:

· Ask us to disclose, free of charge, the following information collected during the preceding 12 months covered by your request:

· Categories of personal information collected about you.

· Categories of sources of that information.

· Purposes for collecting your personal information.

· Categories of third parties to whom we disclose it, categories of information disclosed where applicable, and purposes of disclosure.

· Specific pieces of personal information collected about you.

· Ask us to delete personal information collected from you, subject to CCPA exceptions.

· Ask us to correct your personal information; opt out of its sale or sharing for cross-context behavioral advertising; limit our use and disclosure of sensitive personal information, such as precise geolocation, government identification numbers, financial accounts, racial or religious information, biometrics, or health information; and receive or transfer personal information in a portable format where technically feasible.

· Be free from unlawful discrimination for exercising CCPA rights, including different levels or quality of service or denial of goods or services.

We aim to fulfill all verified CCPA requests within 45 days. If necessary, we will extend this by another 45 days and explain the extension.

How to exercise your rights

You can first log in to your account to manage your data. If you are a California resident covered by the CCPA, you may also contact us through our website or email infosec@fjdynamics.com to exercise rights concerning other data, where applicable.

Nevada

Under Nevada law, Nevada residents who purchase our goods or services may opt out of the "sale" of "covered information" for monetary consideration to a person who would license or sell it to others, as those terms are defined under Nevada law. Covered information includes names, addresses, email addresses, telephone numbers, and identifiers that allow an individual to be contacted online or offline. As described above, we share information with certain third parties that we believe can offer promotions and deals for products and services that may interest you through the other methods described above. We do not consider this sharing to constitute a sale under Nevada law. However, if you are a Nevada resident who has purchased our goods or services, you may email infosec@fjdynamics.com to request that we record your opt-out preference. We may take reasonable steps to verify your identity and the authenticity of the request.

Mainland China

Consent

We will not collect or use your personal information without your consent, and you may withdraw consent at any time. After you withdraw consent, we will no longer collect or use your personal information. Withdrawal does not affect the validity of processing carried out with your consent before withdrawal.

Parental and guardian consent

If you are under 14, do not use the services for any purpose until your parent or guardian has agreed to this Policy on their own behalf and yours. We will not knowingly collect personal information from children under 14 without such consent.

Your rights

We protect your rights as a personal information subject under Chinese privacy laws, including access, copying, correction, and deletion; requesting transfer to a designated personal information handler when statutory conditions are met; requesting an explanation of our processing rules; withdrawing consent; requesting account cancellation; refusing decisions made solely through automated decision-making; and submitting complaints or reports to authorities responsible for personal information protection regarding our processing activities. See "How to Exercise Your Rights" above for more information.

Chinese Mainland

Consent

We will not collect or use your personal information without your consent where consent is required by law, and you may withdraw consent at any time. After withdrawal, we will no longer collect or use the relevant personal information on the basis of that consent. Withdrawal does not affect the validity of processing carried out before withdrawal.

Consent of Parents and Holders of Parental Responsibility

If you are under 14, do not use the Website or services for any purpose until your parent or guardian has agreed to this Policy on their own behalf and yours. We will not knowingly collect personal information from children under 14 without such consent.

Your Rights

We protect your rights as a personal information subject under Chinese privacy laws, including access, copying, correction, and deletion; requesting transfer to a designated personal information handler when statutory conditions are met; requesting an explanation of our processing rules; withdrawing consent; requesting account cancellation; refusing decisions made solely through automated decision-making; and submitting complaints or reports to authorities responsible for personal information protection regarding our processing activities. See "How to Exercise Your Rights" above for more information.

Hong Kong, China

As a data subject in Hong Kong, China, you have statutory rights regarding personal data we hold about you, to the extent permitted by applicable laws and regulations.

You may make data subject access requests to receive a copy of data we process about you, request corrections, and refuse the use of your personal data for direct marketing. We may charge a fee for fulfilling access requests.

Japan

The operator processing your personal information may share it as follows:

 Items of personal information shared

The personal information described in "What Personal Data We Collect".

 Scope of parties sharing personal information

Companies in the operator's group, including companies joining the group after this Policy is established.

 Purposes of use by parties sharing personal information

The purposes described in "How We Use Your Personal Information".

 The operator responsible for managing personal information will take necessary and appropriate measures to prevent leakage, loss, or damage and ensure its secure management. If you have questions about these measures, please email infosec@fjdynamics.com.

Canada

If you are in Canada and would like written information about the policies and practices of service providers outside Canada, please contact us through our website or email infosec@fjdynamics.com.

Where our service providers may access your personal information, we require privacy and security standards comparable to ours. We protect its confidentiality and security through contracts and other measures and prevent its use for purposes outside this Policy.

Russia

If you use the Platform and/or services in Russia, your use signifies agreement to the following:

· You confirm that you are at least 18.

· Your information will be processed under this Policy for the purposes of Russian Federal Law No. 152-FZ of July 27, 2006 on Personal Data, as amended, or any replacement legislation. Where legitimate interests, service optimization, or contract performance are involved, you agree that, for Russian law purposes, this agreement may serve as consent to processing. It also covers Cookies insofar as they constitute personal data under Russian law.

· Your information may be transferred across borders to any country or region where we have databases or branches.

We will collect and store Russian users' personal information in databases located in Russia. Before overseas transfers, we will fulfill notification procedures with the Federal Service for Supervision of Communications, Information Technology and Mass Media (Roskomnadzor) and comply with its overseas transfer requirements.

For the purposes of federal marketing and advertising legislation, we may share advertising or marketing information with you unless you opt out.

The subsections "Access", "Rectification", "Erasure", "Restriction of Processing to Storage Only", "Objection", and "Advertising" under "Your Rights" apply to users in the Russian Federation.

We will notify you of material changes and obtain your separate consent again to those changes.

You may email infosec@fjdynamics.com to contact us. Please include "Russia" in the subject line.

South Africa

1. Personal information of legal entities

In addition to the personal data collected under this Policy, we process data concerning South African legal entities that may constitute personal information under South Africa's Protection of Personal Information Act. Examples include company or other legal entity names, addresses, telephone numbers, email addresses, registration numbers, and names of company contacts.

2. Purposes and legal bases

Purposes include identifying customers and potential customers, marketing or selling products to customers, and negotiating and entering into contracts with customers.

Generally, we process this information on the basis of performance of contracts with customers, consent from the relevant customer or legal entity, or the legitimate interests of ourselves or third parties receiving the information.

Specific purposes include marketing and selling our products and services, supporting customers' access to and use of our products, training users, responding to customer or user inquiries, improving products and services, and advising users about product functions, new versions, or maintenance.

Legal entities' personal information may be shared with third parties and transferred outside South Africa. Please refer to the relevant provisions of this Policy.

3. Laws authorizing or requiring collection

Legislation that may require processing of personal information about individuals or legal entities includes the Financial Intelligence Centre Act, 2001; Income Tax Act, 1962; and Companies Act, 2008.

4. Sensitive personal information

Where applicable, information concerning religious or philosophical beliefs, race or ethnicity, trade union membership, political opinions, health or sex life, biometrics, or criminal activity, including photographs or video records, may constitute sensitive or special personal information under South African laws and regulations.We will obtain guardian consent before processing personal data of children under 18. Children's personal data is treated as special personal information and receives stricter protection. We use special personal information for purposes described in this Policy or otherwise notified to you from time to time.

5. Contact us

If you have questions or concerns, contact us using the details below or those in "How to Contact Us". We will respond within a reasonable period, not exceeding 30 days, and may require identity verification.Contact: support@fjdtrion.com

Mexico

Age restrictions

You may not use the services unless you are at least 18 or have obtained your parent or guardian's agreement to this Policy on their own behalf and yours.

Types of personal information we use

For clarity, Sections 2, "What Personal Data We Collect", and 4, "How We Use Your Personal Information", provide full details of the personal data we use. Accordingly, for the purposes of the Federal Law on the Protection of Personal Data Held by Private Parties (FLPPDHPP, effective March 21, 2025, replacing the former LFPDPPP) and other applicable provisions, we provide complete information about the personal data we use.

Purposes of processing

Certain purposes described above are optional, including personalized recommendations and advertisements. We may also use personal data for optional purposes to email information we believe may be relevant to you. You may object to processing for optional purposes as described under "Your rights" below.We may also use personal data to fulfill legal obligations or competent authorities' requirements, uphold or defend our rights before authorities or courts, respond to personal data requests, and carry out the transfers described in Sections 6, "How We Manage Your Personal Data", 7, "How We Share Your Personal Data", and 8, "Local Storage and Cross-Border Access to Your Personal Data".

Consent to transfers

Generally, we do not require your consent for the transfers described in Sections 6, "How We Manage Your Personal Data", 7, "How We Share Your Personal Data", and 8, "Local Storage and Cross-Border Access to Your Personal Data". However, consent is required to transfer your personal data to third parties acquiring all or substantially all of our business.

By using the Platform and/or services and providing personal data, you consent to the transfers above that require consent. You may exercise the relevant rights described under "Your rights" below.

Your Rights

The subsections "Access", "Rectification", "Erasure", "Objection", and "Restriction of Processing to Storage Only", including restrictions on use and disclosure, and "Advertising" under "Your Rights" above also apply to users in Mexico.

You may also withdraw consent previously given for processing your personal data.

To exercise your rights, contact us through our website or email infosec@fjdynamics.com.

For more information about your rights and the applicable methods, procedures, and requirements for exercising them, email infosec@fjdynamics.com.

Cookies

We collect browsing and device information through Cookies, some of which may be personal data, as detailed above. You can adjust browser settings to reject or disable Cookies. As browsers differ, please consult your browser's instructions. Rejecting, disabling, or deleting Cookies may prevent use of some service functions. See "How We Use Cookies and Similar Technologies" for further information.

France

Your Rights

Instructions concerning processing of personal data after your death:You may give us general or specific instructions on the retention, deletion, and disclosure of your personal data after your death.

Specific instructions apply only to the processing activities they identify, and carrying them out requires your explicit consent.

You may change or revoke your instructions at any time.

You may designate a person to carry out your instructions. If you die, we will inform that person of your instructions, and they may require us to implement them. If no person is designated, or the designated person has died, your heirs may learn of your instructions and require us to implement them, unless otherwise provided.To give such instructions, contact us through our website or email infosec@fjdynamics.com.

Brazil

This subsection applies to users in Brazil.

Withdrawal of consent

Where we use personal information based on consent, you may withdraw consent previously given to collection, use, and disclosure, subject to contractual or legal restrictions. To withdraw consent, email infosec@fjdynamics.com to contact us and terminate your account. This may affect our ability to provide services.

Parental and guardian consent

If you are under 18, do not use the services for any purpose until your parent or guardian has agreed to this Policy on their own behalf and yours. We will not knowingly collect information from children under 18 without consent. If you believe we have obtained such information without parental or guardian consent, contact us promptly. We will immediately investigate and delete it.For processing based on consent, we will provide specific and clear notice of the processing purpose before collection and obtain your freely given, informed, and unambiguous consent. You may withdraw consent at any time without affecting the validity of prior processing.

Colombia

This subsection applies to users in Colombia.

Data subject rights

Under applicable laws, you may:

• Freely access your personal data.
• Know about, update, and correct your personal data when it is inaccurate, incomplete, fragmented, misleading, or processed without authorization or unlawfully.
• Request proof of authorization for processing, unless exempted by law.
• Complain to the Superintendence of Industry and Commerce of Colombia.
• Withdraw authorization and/or request deletion when there is no legal or contractual reason to retain the data.
• Refuse authorization to process sensitive personal data.

As a general principle, we do not process personal data of minors under 18. Such processing takes place only where the data is public in nature, authorization has been obtained from a legal representative, and the child's best interests have been considered. Providing sensitive personal data is not mandatory.

Australia

This subsection applies to users in Australia.

Overseas recipients

We take reasonable steps to ensure third parties outside Australia receiving your personal information handle it consistently with Australian privacy laws. However, you acknowledge that we have no control over, and accept no responsibility for, the acts or omissions of such recipients.

Access

You may access personal information we hold about you and learn how we use and share it. You can log in to access information you provided for your account. If you believe we hold other personal information about you, email infosec@fjdynamics.com.

Rectification

You may correct inaccurate personal information we hold about you. You can log in to your Platform account to access that information. If you believe other information we hold about you is inaccurate, email infosec@fjdynamics.com.

Children

For minors under 18, we assess capacity to consent based on maturity and understanding. Where a minor lacks sufficient capacity, we will obtain consent from a parent or legal guardian for account registration and use of the Platform.

Your Rights

If you are dissatisfied with our response to an access or correction request or a privacy complaint concerning your personal information, email infosec@fjdynamics.com.

Philippines

Minimum age requirements

Children under 13 require verifiable parental or guardian consent to use the Platform. Consent for information society services for minors aged 13 to 15 is subject to the corresponding rules. All persons under 18 receive special protection.

Your Rights

You have the following rights:

• Information: in certain circumstances, to know whether your personal data is being or has been processed, including automated processing and profiling.
• Objection: in certain circumstances, to object to processing, including direct marketing, automated processing, or profiling.
• Access: in certain circumstances, to seek reasonable access to personal information upon request.
• Rectification: in certain circumstances, to identify errors and require correction, unless the request is unreasonable.
• Erasure or blocking: in certain circumstances, to disable, withdraw, block, delete, or destroy your personal information.

 

Consent

By agreeing to this Policy, you consent to:

• Our collection and processing of personal information as described in "How We Use Your Personal Information".
• Our sharing of personal information with third parties, companies in our group, and third parties acquiring all or part of our business, in accordance with this Policy and for its stated purposes.
• The possible transfer or storage of personal information outside the Philippines as described in "How We Manage Your Personal Data", "How We Share Your Personal Data", and "Local Storage and Cross-Border Access to Your Personal Data".

 

Türkiye

For matters concerning Türkiye's Personal Data Protection Law ("DPL") and its subordinate regulations, contact infosec@fjdynamics.com and include "Türkiye" in the subject line.For overseas transfers of personal information, we will rely on adequacy decisions, standard contracts, or binding corporate rules and make filings with the Turkish Personal Data Protection Board as required by law, or meet the conditions for a statutory exception.Under Article 11 of the DPL, you have statutory rights regarding personal information we hold. As a data subject in Türkiye, you may apply to the controller, to the extent permitted by applicable laws and regulations, to:

• Learn whether your personal data has been processed.
• Obtain information about the processing if it has occurred.
• Learn its purposes.
• Learn which third parties in Türkiye or abroad will receive the data.
• Request correction of incomplete or inaccurate data.
• Request deletion or destruction under the conditions in Article 7 of the DPL.
• Refuse consent to automated processing and seek certain remedies under the DPL.

 

United Arab Emirates

You consent to collection, use, disclosure, export, and storage of your personal information under this Policy, including for personalized advertisements during your use of the services.We may voluntarily report cybersecurity incidents that constitute crimes under UAE laws, such as cybercrime legislation, to the relevant authorities for investigation. We may also voluntarily report incidents to the UAE Computer Emergency Response Team ("CERT"), a security awareness organization that provides incident recording procedures and advice about known cybersecurity threats in the UAE.

Children

For users in the UAE, we follow the Federal Personal Data Protection Law (Federal Decree-Law No. 45 of 2021) and the Child Digital Safety Law effective January 1, 2026 when processing data. We will obtain guardian consent before processing personal information of children under 18, with age calculated according to the Hijri calendar. However, minors aged 18 to 21 may obtain a court order allowing specific commercial transactions. Minors over 7 may also conduct commercial transactions with guardian approval.

South Korea

Children under 14 may use the Platform for any purpose only after a parent or guardian has agreed to this Policy, both on their own behalf and on behalf of the child. We will not knowingly collect personal information from children under 14 without such consent. If you believe we hold such information without parental or guardian consent, please contact us. We will immediately investigate and delete it.

Mandatory retention periods under South Korean law

Records	Relevant law	Retention period
Records concerning conclusion and termination of contracts	Act on Consumer Protection in Electronic Commerce	5 years
Records concerning payments and other provision of funds	Act on Consumer Protection in Electronic Commerce	5 years
Records concerning consumer complaints and dispute resolution	Act on Consumer Protection in Electronic Commerce	3 years
Records concerning labeling and advertising	Act on Consumer Protection in Electronic Commerce	6 months
Service access logs	Protection of Communications Secrets Act	3 months
Telecommunications logs	Protection of Communications Secrets Act	12 months

Destruction of personal information

We destroy personal information when it is no longer needed, such as when its retention period has expired and its processing purpose has been achieved, unless retention is required by law or regulation. Inactive accounts with no login or use for one consecutive year will be stored separately or deleted after advance notice.

Destruction procedures

• Procedure: we destroy information requiring destruction in accordance with our data deletion and retention protocols.
• Method: electronic information is destroyed by low-level formatting or similar methods to ensure it cannot be copied; hard-copy information is shredded or incinerated.

Contact infosec@fjdynamics.com and include "South Korea" in the subject line.