Privacy Policy

Date: 2025-04-25

Provider Information/Impressed

The NanoMatriX, the ComplyNexus, the TrackMatriX and HealthMatriX website is provided by NanoMatriX Technologies Limited, a company registered in Hong Kong S.A.R., under the business registration number 34684210.

Managing Director: Alfons Futterer

Address: Unit 6 & 7, 18/F, Workingfield Commercial Bldg., 408-412 Jaffe Road, Wanchai, Hong Kong SAR

Tel.: +852 2523 9959

Fax.: +852 2523 9759

Email: [email protected]

This policy sets out:

1. The information we collect about you when you visit our website, use our products or services, or otherwise interact with us, how we collect such information;

2. How we use, share, store, transfer, and secure the information; and

3. How you may access and control the information.

1. Who are we

We (“NanoMatriX ” or “we” refer to NanoMatriX Technologies Limited of 18/F, Unit 6 & 7, Working field Commercial Bldg., 408-412 Jaffe Road) are a provider of authentication and traceability products and services on our platform (“Platform” means our website at www.nanomatrixsecure.com, www.complynexus.com, and our software, namely TrackMatriX SaaS, ComplyNexus, ComplyNexus PQE, ComplySpark, and Privicore Nexus). This Privacy Policy applies to all products and services offered by NanoMatriX Technologies Limited, including but not limited to TrackMatriX SaaS platform, ComplyNexus, ComplyNexus PQE, ComplySpark, and Privicore Nexus, anti-counterfeiting and anti-fraud consulting services, cybersecurity workshops, vulnerability assessments, and any other services provided through our website or third-party platforms. Note: if you are using services that are integrated or built using our products and services, the privacy policy of those services will describe how they collect, use, store, and share your information. We are not responsible for the privacy policies or actions of our customers or business partners.

This Privacy Policy applies to our customers, prospective customers, our customers’ customers (both direct and indirect), vendors, resellers, job applicants, current and former employees, contractors, visitors to our company websites, and recipients of our e-mail communications. Current employees are also governed by internal Human Resources policies, which are available upon request.

2. What information we collect about you

2. 1. We collect the following types of information about you:

2. 1. • Account and profile information that you provide when you register for an account or sign up for our products or services, for example your name, username or similar personal identifier, other personal description, job title, date of birth and gender, physical address (billing or delivery or both), email address, telephone number(s) (collectively, “Account Data”).

2. 1. • Information you provide through support channels, for example when you report a problem to us or interact with our support team, including any contact information, documentation, or screenshots (collectively, “Support Data”).

2. 1. • Content you provide through use of our products or services, for example content displayed on landing pages (collectively, “User Content”).

2. 1. • Communication, marketing, and other preferences that you set when you set up your account or profile, or when you participate in a survey or a questionnaire that we send you (collectively, “Preference Data”).

2. 1. • Details of any transactions, purchases, or orders that you’ve made with us(collectively, “Transaction Data”).

2. 1. • Payment information, for example your payment card information or bank account details (collectively, “Financial Data”).

2. 1. • Information about your device or connection, for example your internet protocol (IP)address, log-in data, browser type and version, time-zone setting, browser plug-in types and versions, operating system and platform, and other technology on devices you use to access our products or services and information we collect through cookies and other data collection technologies (please read our Cookies Policy for details) (collectively, “Technical Data”); and Information about your use of or visit to our Platform, for example your click stream to, through, and from our Platform, products you viewed, used, or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), or methods to browse away from the page(collectively, “Usage Data”).

1. 2. We collect the above information when you provide it or when you use or visit our Platform. We may also receive information about you from other sources, including:

1. 1. • Our personnel, agents, advisors, consultants, and contractors based in Hong Kong, Thailand, India, Pakistan, and the Philippines in connection with our operations or services, for example, our staff engaged in fulfilling your order, processing your payment, and providing support services.

1. 1. • Our business partners and service providers are based in Hong Kong, the United States of America, and Singapore, and they provide technical, payment, delivery services, advertising networks, analytics, market research, and search information services.

1. 3. We do not collect sensitive data or special category data about you. This includes your racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, and data about your health, sex life, or sexual orientation.

1. 4. The information we collect includes “personal information,” which refers to any data, information, or combination of data and information that you provide to us or through your use of our products or services and that relates to an identifiable individual. It also includes non-personal information.

3. How we use the information we collect

3. 1. We only use your personal information where the law allows us to. We use your personal information only where:

1. 1. • We need to perform the contract we have entered into (or are about to enter into) with you, including to operate our products or services, to process transactions with you (such as billing), to authenticate you when you log into our platform, to provide customer support and personalized features, and to protect the safety and security of our Platform.

1. 1. • We have a legitimate interest in doing so. “Legitimate Interests” is a legal ground upon which we may process personal information, where that processing is necessary to pursue interests of our business provided always that your fundamental rights or data protection interests are not overridden as a result, for example for research and development. For more information on your rights, please see “7. Your rights” below.

1. 1. • You’ve given us consent to do so for a specific purpose, for example we may send you direct marketing materials or publish your information as part of our testimonials or customer stories to promote our products or services with your permission; or

1. 1. • We need to comply with a legal or regulatory obligation.

1. 2. If you have given us consent to use your personal information for a specific purpose, you have the right to withdraw your consent any time by contacting us, but please note this will not affect any use of your information that has already taken place

1. 3. We do not share your personal information with any company outside our group for marketing purpose, unless with your express specific consent to do so.

1. 4. If you are a resident of the European Economic Area, we have set out our legal bases for processing your information in the Legal Bases Table at the end of this policy.

4. How we share the information we collect

1. 1. We reserve the right to collect, share, and otherwise disclose non-personal information for any purpose except where limited by applicable laws, and to create non-personal information from personal information to do so.
   2. We may share information with third parties for research, analysis, profiling, and similar purposes to help us improve our products and services. If personal information is included, it will be strictly in an aggregated or de-identified form that does not specifically identify you.
   3. If you use any third-party software in connection with our products or services, for example, any third-party software that our Platform integrates with, you might give the third-party software provider access to your account and information. We do not control policies and procedures of third-party software providers, and this policy does not cover how your information is collected or used by third-party software providers. We encourage you to review the privacy policies of third-party software providers before you use the third-party software.
   4. Our Platform may contain links to third-party websites over which we have no control. If you follow a link to any of these websites or submit information to them, your information will be governed by their policies. We encourage you to review the privacy policies of third-party websites before you submit information to them.
   5. We may share your information with government and law enforcement officials to comply with applicable laws or regulations, for example when we respond to claims, legal processes, law enforcement, or national security requests.
   6. If we are acquired by a third party as a result of a merger, acquisition, or business transfer, your personal information may be disclosed and/or transferred to a third party in connection with such transaction. We will notify you if such transaction takes place and inform you of any choices you may have regarding your information.

5. How we transfer information internationally

5. 1. We collect information globally and primarily store that information in Hong Kong, Singapore, India, or the United States of America,. For the purpose of providing our products and services to you, we may transfer, process, and store your information outside your country of residence where we or our service providers operate.

5. 2. We only transfer personal information internationally under appropriate contractual clauses,where appropriate legal safeguards are in place or where we have consent to do so.

6. How we store, secure, and retain the information we collect

5. 1. We use data hosting service providers based in Singapore, the United States of America, and India to host the information we collect.

5. 2. We have adopted the following technical and organizational measures to protect the security and integrity of your personal information:

1. 2. • Information is encrypted using TLS/SSL technology.
      • Your account is password-protected, with the requirement(s) that passwords must be at least 15 characters long, with a combination of letters, symbols, and numbers.
      • Access to your personal information is restricted to personnel or service providers on a strictly need-to-know basis, who will only process your information on our instructions and who are subject to a duty of confidentiality; and Our information collection, storage, and processing practices are reviewed regularly.

1.  

1. 1. We have implemented procedures to address any suspected privacy breach. We will notify you and any applicable regulator of a breach where we are legally required to do so.
   2. While we implement safeguards designed to protect your information, please note that no transmission of information on the Internet is entirely secure. We cannot guarantee that your information, during transmission through the Internet or while stored on our systems or processed by us, is safe and secure.
   3. We only retain personal information for so long as it is reasonably necessary to fulfil the purposes we collected it for, including satisfying any legal, accounting, or reporting requirements. After such time, we will delete or anonymize your information, or if this is not possible, we will securely store your information and isolate it from further use. We periodically review the basis and appropriateness of our data retention policy.

7. Your rights

1. You have the right to:

• Be informed of what we do with your personal information.

• Obtain confirmation on whether the person’s information is being processed by us. You also have the right to request a copy of personal information we hold about you.

• Require us to correct any inaccuracy or error in any personal information we hold about you;

• Request erasure of your personal information if (i) it is no longer necessary for the purposes for which it was collected; (ii) you have withdrawn your consent and no other legal ground for the processing exists; (iii) you objected and no overriding legitimate grounds for the processing exist; (iv) the processing is unlawful or erasure is required to comply with a legal obligation (note, however, that we may not always be able to comply with your request of erasure for record keeping purposes, to complete transactions, or to comply with our legal obligations);

• Restrict the processing by us of your personal information (while we verify or investigate your concerns with this information, for example);

• Object to any of our processing where we do so based on our legitimate interests (including for marketing purposes);

• Request to receive some of your personal information in a structured, commonly used, and machine-readable format, and request that we transfer such information to another party;

• Refuse to give consent or withdraw your consent at any time where we are relying on consent to process your personal information (although this will not affect the lawfulness of any processing carried out before you withdraw your consent); and

• To complain with the data protection supervisory authority in the country where you live or work or where you feel your rights have been infringed

2. You may opt out of receiving marketing materials from us by using the unsubscribe link in our communications, by updating your preferences within your account on our Platform, or by contacting us. Please note, however, that even if you opt out from receiving marketing materials from us, you will continue to receive notifications or information from us that are necessary to use our products or services.

3. As a security measure, we may need specific information from you to help us confirm your identity when processing your privacy requests or when you exercise your rights.

4. Any request under paragraph 7.1 will typically be addressed free of charge. However, we may charge a reasonable administration fee if your request is unfounded, repetitive, or excessive.

5. We will respond to all legitimate requests within one (1) month. Occasionally, it may take us longer than a month if your request is particularly complex or if you have made many requests.

8. Changes to this policy

8. 1. We may amend this policy from time to time by posting the updated policy on our Platform. By continuing to use our Platform after the changes come into effect, you agree to be bound by the revised policy.

9. Policy towards children

8. 1. Our products and services are not directed to individuals under 18. We do not knowingly collect personal information from individuals under 18. If we become aware that an individual under 18 has provided us with personal information, we will take steps to delete such information. Contact us if you believe that we have mistakenly or unintentionally collected information from an individual under 18.

10. Contact us

8. 1. please get in touch with our Data Protection Officer [*] at [email protected] or submit any written request: NanoMatriX Technologies Limited 18/F, Unit 6 & 7, Working field Commercial Bldg., 408-412 Jaffe Road Attn: Alfons Futterer

8. 2. Please contact us in the first instance if you have any questions or concerns or you would like to exercise any of your rights set out in this Privacy Policy. If you have unresolved concerns, you have the right to file a complaint with Privacy Commissioner for Personal Data, Hong Kong in related to Hong Kong data protection laws (https://www.pcpd.org.hk), or the data protection supervisory authority in the country where you live or work or where you feel your rights have been infringed.

COOKIES POLICY

Cookies are small text files that are placed on your device by a web server when you access our Platform. We use cookies to identify your access and monitor usage and web traffic on our Platform to customize and improve our products and services.

We use both persistent cookies and session cookies. A persistent cookie stays in your browser and will be read by us when you return to our Site or a partner site that uses our services. Session cookies only last for as long as the session lasts (usually the current visit to a website or a browser session).

We use the following types of cookies:

1. Strictly necessary cookies – these are cookies that are required for the operation of our site. They include, for example, cookies that enable you to log into secure areas of our website.
2. Analytical/performance cookies allow us to recognize and count the number of visitors and to see how visitors move around our Site when they are using it. This helps us to improve the way our site works, for example, by ensuring that users can easily find what they are looking for.00000000
3. Functionality cookies – these are used to recognize you when you return to our site.
4. Targeting cookies – these cookies record your visit to our site, the pages you have visited, and the links you have followed.

You can block cookies by activating the settings on your browser that allow you to refuse the use of all or some cookies. However, if you do so, you may be unable to access all or parts of our site.

LEGAL BASES TABLE

Processing purpose	Type of data processed	Legal basis
To register you as a user on out Platform	Account Data	To perform our contract with you
To enable you to use our products and services	Account Data, Transaction Data, Support Data, Technical Data and User Content	To perform our contract with you
To process your payments	Account Data, Transaction Data, Financial Data	To perform our contract with you
To collect overdue amounts	Account Data, Transaction Data, Financial Data	Legitimate interest to recover debts due to us
To notify you about changes to our products, services or terms	Account Data, Transaction Data, Financial Data	To perform our contract with you
To administer and maintain safety and security of our Platform	Technical Data, Usage Data	To perform our contract with you
To study usage of our products or services	Transaction Data, Support Data, Technical Data, Usage Data	Legitimate interest to improve our Platform, products and services
To gather feedback on our products, services or features	Account Data	Legitimate interest to improve our Platform, products and services
To provide information on products or services that maybe of interest to you	Account Data, Preference Data	Consent, which you may withdraw any Time