Data Protection Statement of Posalux Group

Version effective as of August 2023

Posalux Group Policy on Personal Data Protection

Posalux places great value on honesty and transparency and we are committed to buildingstrong, lasting relationships with our customers and suppliers, based on trustand mutual interest. In line with this philosophy, we believe that it is essential that your personal data is protected. This policy on personal data protection is therefore designed to provide you with information about how we collect and process this data.

By giving your prior consent, you agree that we may collect and use your personal data as described in this Policy and we may transfer your personal dataabroad (including to other non-EU countries).

What is the scope of application of this personal data protection policy?

This personal data protection policy applies to all websites and applications, and to any other initiative of a Posalux Group company which involves the collection of personal data (the "Media"). This Policy does not, therefore, apply to third-party websites, including any websites mentioned in our Media via a weblink.

Who collects my personal data (who is responsible for data processing)?

Your personal data is collected by Posalux SA, rue F. Oppliger 18, 2504 Biel Bienne, Switzerland, and its direct or indirect affiliates, subsidiaries and branches ("The Posalux Group").

What data do we collect from you?

With your prior consent, when you use our Media, we may collect and process all or some of the following data:

the data which you provide to us when you complete forms, when you download online content, when you subscribe to online services (e.g. social network pages and applications) or when you write to us, during conversations and in the context of business contacts:

·  Your first name and surname;

·  Your company address (and potentially your homeaddress also) and email address;

·  Your gender;

·  Your business phone number (and potentially yourhome phone number), landline and mobile;

·  Your address;

·  Your age and date of birth;

·  Your opinion on our products;

·  Products and services offered by your company (if you are a supplier);

·  Requirements of your business (if you are acustomer);

·  Prices and terms of payment;

·  History of the products which you have purchased from and sold to Posalux;

·  Any special request which you send to us;

·  Photos and videos of you that you wish to share.

We may also ask you to complete surveys which we will use for scientific and statistical purposes.

Do we collect your IP address and your cookies?

We may collect your IP address and your browser type for administrative and/or statistical purposes, without identifying any other personal information.

In somecases, we may also use cookies: these are small text files, containing lettersand numbers, which are downloaded onto your computer when you use our Media. We mainly use cookies to recognize you when you use our Media again in future and to display content which is relevant to your interests.

By default, web browsers are configured to accept cookies but you can easily change this by adjusting your browser settings. However, please note that if you choose to disable cookies, some parts of our Media may no longer be accessible.

Detailed information on our rules concerning cookies is available here: Cookies

How do we use your personal data?

We use your personal data primarily to manage our current and prospective customers and suppliers; in particular, your data is also used to respond to your requests and offers, or send you news and information about our products, our brands, our operations and/or our publications (e.g. newsletter); we also use your data to keep you informed of our requirements, which might be of interest to you, to enable you to make purchases or offers online or using other means of communication about products and services, including but not limited to accessories, spare parts and our after-sales service in particular.

We also use your data to enhance your digital experience of our Media: to understand your interest in our Media and their content, to confirm your participation in our operations, to process your payments, to ensure that our Media are presented in the way best tailored to you and your computer, and to protect you against any fraudulent activities.

How can you access your personal data?

You canal ways contact us by post, by email or by phone to check the personal data that we are holding on file concerning you.

If you notice an error in this data or if you think it is incomplete or ambiguous, you can also ask us to correct, complete or clarify it. You can also object to your data being used for marketing purposes or object to your data being shared with third parties for this purpose. Finally, you can ask us to erase all personal data which we hold on file about you. However, please note that we may keep are cord of your data for archieving purposes (especially where this is required by law or for insurance purposes).

Do we share your personal data?

Subject to what is stated in this policy on personal data protection or provided that you have given us your prior consent, we may share your personal data with employees in the Posalux Group or our service providers (e.g. the agencies which manage our mailing operations, or even service providers responsible for installing peripherals on our products) and/or commercial partners for theafore mentioned purposes, and only as necessary to complete the tasks entrusted to them. These people may need to get in touch with you directly using the contact information which you have given us.

Please note that our service providers are under strict instructions from us to only use your personal data to manage the services which we ask them to provide. We also require our service providers to ensure that they always comply with the applicable laws on personal data protection and to pay particular attention to guarantee that this data is kept confidential.

Where do we store your personal data?

Your personal data is stored in our databases and/or in the databases of our service providers.

In somecases, and mainly for technical reasons, these databases may be stored on servers located outside the country in which you originally provided the information (and may be stored in databases in countries outside the European Union).

Your rights concerning your personal data:

All rights according to GDPR legislation, namely the right to:

·  Access to your data;

·  Have your data corrected;

·  Have your data erased;

·  Restrict how your data is processed;

·  Object to its use;

·  Ensure the portability of your data;

·  Decide to withdraw your consent;

·  Appeal if Posalux fails to meet its obligations.

Do we send your personal data outside the European Economic Area (EEA)?

As the Posalux Group is an international group with Swiss roots, to optimize the quality of our service and to provide you with the information and updates described above, it may be necessary for us to send your personal data outside your country and/or to a country outside the EEA, where the personal data protection laws differ from those of the European Union.

In this case,we implement rigorous and appropriate policies to guarantee the security and confidentiality of personal data, namely physical, organizational, procedural, technical and staffing measures.

Length of personal data retention

Posalux will store your Personal Data in a secure environment for the length of timerequired to serve the purposes for which it was collected or for a minimum retention period set by the applicable civil and commercial legislation.

Is your personal data stored securely?

We always aim to store your personal data as safely and securely aspossible, and only for as long as required to serve the purpose for which it isbeing processed. With that in mind, we take the appropriate physical, technicaland organizational measures to minimize the risk of your data being modified,lost or accessed without authorization.

Please note that we reserve the right to make changes to this personal data protection policy. In this case, such changes will be published on this page.

Personal dataprotection officer for external persons (hereafter the Controller)

The "controller" of data processing as described in this data protection statement is René Ronchetti, CEO. You can notify us of any data protection related concerns, irrespective of the concerned affiliate company of Posalux Group using the following contact details: rh@posalux.com; Posalux SA, rue F Oppliger 18, CH-2504 Biel-Bienne.

Your personal data is collected by Posalux SA, rue F Oppliger 18, 2504 Biel Bienne, Switzerland.

Applicable legislation:

The protection of your personal data is governed by the applicable legislation inthe country where you work.

Posalux SA, rue F Oppliger 18, CH-2504 Biel-Bienne.+41 32 344 75 00

Biel Bienne July 31st2023