Privacy Policy

Updated: October 2025

This Privacy Notice applies to the processing of personal information by Beamm Technologies Inc. d/b/a Simulon (“Simulon,” “we,” “us,” or “our”) including on our website available at https://simulon.com/, our mobile application, and our other online or offline offerings which link to, or are otherwise subject to, this Privacy Notice (collectively, the “Services”).

Contents

1.Updates To This Privacy Notice

2.Personal Information We Collect

3.How We Use Personal Information

4.How We Disclose Personal Information

5.Your Privacy Choices And Rights

6.International Transfers Of Personal Information

7.Retention Of Personal Information

8.Supplemental Notice For Eu/Uk GDRP

9.Children’s Personal Information

10.Third-Party Websites/Applications

11.Contact Us


  1. UPDATES TO THIS PRIVACY NOTICE

We may update this Privacy Notice from time to time in our sole discretion. If we do, we’ll let you know by posting
the updated Privacy Notice on our website, and/or we may also send other communications.


  1. PERSONAL INFORMATION WE COLLECT

We collect personal information that you provide to us, personal information we collect automatically when you use the Services, and personal information from third-party sources, as described below.

A. Personal Information You Provide to Us Directly

We may collect personal information that you provide to us, such as Account Information.
We may collect personal information in connection with the creation or administration of your account. This personal information may include, but is not limited to:

  • Contact Details and Other Information. We may collect personal information such as your name, email address, phone number, professional details, and other information you store with your account.


  • Content and Related Information. We may collect any content you provide, along with information about, or contained in, the content. This information may include, but is not limited to, thumbnails, titles, images, audio, transcripts, and videos. It may also include details, statistics, analytics, performance information, and other information about the content.


  • Purchases. We may collect personal information and details associated with your purchases, including payment information. Any payments made via our Services are processed by third-party payment processors. We do not directly collect or store any payment card information entered through our Services, but we may receive information associated with your payment card information (e.g., your billing details).


  • Your Communications with Us. We, and our service providers, may collect the information you communicate to us, such as through email or our web chat tool.


  • Surveys. We may contact you to participate in surveys. If you decide to participate, we may collect personal information from you in connection with the survey.


  • Interactive Features. We and others who use our Services may collect personal information that you submit or make available through our interactive features (e.g., messaging features, commenting functionalities, forums, blogs, and social media pages). Any information you provide using the public sharing features of the Services will be considered “public.”


  • Sweepstakes or Contests. We may collect personal information you provide for any sweepstakes or contests that we offer. In some jurisdictions, we are required to publicly share information of sweepstakes and contest winners.


  • Conferences, Trade Shows, and Other Events. We may collect personal information from individuals when we attend or host conferences, trade shows, and other events.


  • Business Development and Strategic Partnerships. We may collect personal information from individuals and third parties to assess and pursue potential business opportunities.


  • Job Applications. If you apply for a job with us, we will collect any personal information you provide in connection with your application, such as your contact information and CV.

B. Personal Information Collected Automatically

We may collect personal information automatically when you use the Services, such as:

Device Information. We may collect personal information about your device, such as your Internet protocol (IP) address, user settings, cookie identifiers, other unique identifiers, browser or device information, hardware model, operating system version, device sensor information (such as gyroscopes, compasses and microphones), network connection, Internet service provider, and location information (including, as applicable, approximate location derived from IP address and precise geo-location information).

Usage Information. We may collect personal information about your use of the Services, such as the pages that you visit, items that you search for, the types of content you interact with, information about the links you click, the frequency and duration of your activities, and other information about how you use the Services.

Cookie Notice (and Other Technologies). We, as well as third parties, may use cookies, pixel tags, and other technologies (“Technologies”) to automatically collect personal information through your use of the Services.

  • Cookies. Cookies are small text files stored in device browsers.

  • Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded. in the Services that collects personal information about use of or engagement with the Services. The use of a pixel tag allows us to record, for example, that a user has visited, a particular web page or clicked on a particular advertisement. We may also include web beacons in e-mails to understand whether messages have been opened, acted on, or forwarded. See “Your Privacy Choices and Rights” below to understand your choices regarding these Technologies.

Analytics. We may use Technologies and other third-party tools to process analytics information on our Services. Some of our analytics partners could include:

Google Analytics. We use analytics services provided by Google Inc. This allows us to process usage data to better understand how our website and web-related Services are used. This enables us to continually improve our website, making it relevant to your interests and needs. This may involve personal data, such as cookie and other device identifiers. The data collected by Google Analytics is usually transferred to a Google server in the USA and processed there. In addition, Google uses your data for its own purposes, e.g., for profiling or linking it to other data. For more information, please visit Google Analytics’ Privacy Policy. To learn more about how to opt-out of Google Analytics’ use of your information, please click here.

LinkedIn Analytics. For more information, please visit LinkedIn Analytics’ Privacy Policy. To learn more about how to opt-out of LinkedIn’s use of your information, please click here.

Mixpanel. For more information about Mixpanel, please visit Mixpanel’s Privacy Policy.

Facebook Connect. For more information, please visit Facebook’s Data Policy. You can object to the collection of your data by Facebook pixel, or to the use of your data for the purpose of displaying Facebook ads by contacting the following address while logged into your Facebook account: https://www.facebook.com/settings?tab=ads.

C. Personal Information Collected from Third Parties

We may collect personal information about you from third parties. For example, if you access the Services using a Third-Party Service (defined below), we may collect personal information about you from that Third-Party Service that you have made available via your privacy settings. In addition, users of the Services may upload or otherwise provide personal information about others.


  1. HOW WE USE PERSONAL INFORMATION

We use personal information for a variety of business purposes, including to provide the Services, for administrative purposes, and to provide you with marketing materials, as described below.

A. Provide the Services

We use personal information to fulfill our contract with you and provide the Services, such as:
  • Managing your information;

  • Providing access to certain areas, functionalities, and features of the Services;

  • Answering requests for support;

  • Communicating with you;

  • Sharing personal information with third parties as needed to provide the Services;

  • Processing your financial information and other payment methods for products and Services purchased;

  • Processing applications if you apply for a job we post on our Services; and

  • Allowing you to register for events.

B. Administrative Purposes

We use personal information for various administrative purposes, such as:

  • Pursuing our legitimate interests such as direct marketing, research and development (including marketing research), network and information security, and fraud prevention;

  • Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity;

  • Carrying out analytics;

  • Measuring interest and engagement in the Services;

  • Performing computations;

  • Developing and/or training models;

  • Improving, upgrading, or enhancing the Services;

  • Developing new products and services;

  • Creating de-identified and/or aggregated information.;

  • Ensuring internal quality control and safety;

  • Authenticating and verifying individual identities, including requests to exercise your rights under this Privacy Notice;

  • Debugging to identify and repair errors with the Services;

  • Auditing relating to interactions, transactions, and other compliance activities;

  • Enforcing our agreements and policies; and

  • Carrying out activities that are required to comply with our legal obligations.

C. Marketing

We may use personal information to tailor and provide you with marketing and other content. We may provide you
with these materials as permitted by applicable law. If you have any questions about our marketing practices, you may contact us below.

D. With Your Consent or Direction

We may use personal information for other purposes that are clearly disclosed to you at the time you provide
personal information, with your consent, or as otherwise directed by you.

E. Automated Decision Making

We may engage in automated decision making, including profiling.


  1. HOW WE DISCLOSE PERSONAL INFORMATION

We disclose personal information to third parties for a variety of business purposes, including to provide the
Services, to protect us or others, or in the event of a major business transaction such as a merger, sale, or asset transfer, as described below.

A. Disclosures to Provide the Services

We may disclose any of the personal information we collect to the categories of third parties described below.

Service Providers. We may disclose personal information to third-party service providers that assist us with the provision of the Services. This may include, but is not limited to, service providers that provide us with hosting, customer service, analytics, marketing services, IT support, and related services. In addition, personal information and chat communications may be disclosed to service providers that help provide our chat features.

Other Users or Third Parties You Share or Interact With. The Services may allow Simulon users to share content (including personal information) or interact with other users or third parties (including the general public).

Third-Party Services You Share or Interact With. The Services may link to or allow you to interface, interact, share information with, direct us to share content/information with, access and/or use third-party websites, applications, services, products, and technology (each a “Third-Party Service”). Any personal information shared with a Third-Party Service will be subject to the Third- Party Service’s privacy policy. We are not responsible for the processing of personal information by Third-Party Services.

• Business Partners. We may share your personal information with business partners to provide you with a product or service you have requested. We may also share your personal information with business partners with whom we jointly offer products or services. Once your personal information is shared with our business partner, it will also be subject to our business partner’s privacy policy. We are not responsible for the processing of personal information by our business partners.

• Simulon Customers (Authorized Users Only). In cases where you use our Services as an employee, contractor, or other authorized user of a Simulon customer, that customer may access information associated with your use of the Services including usage data and the contents of the communications and files associated with your account. Your personal information may also be subject to the Simulon customer’s privacy policy. We are not responsible for the Simulon customer’s processing of your personal information.

• Affiliates. We may share your personal information with our corporate affiliates.

B. Disclosures to Protect Us or Others

We may access, preserve, and disclose any information we store associated with you to external parties if we, in
good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our, or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.

C. Disclosure in the Event of Merger, Sale, or Other Asset Transfers
If we are involved in a merger, acquisition, financing, reorganization, bankruptcy, receivership, purchase or sale of assets, transition of service to another provider, or other similar corporate transaction, your personal information may be disclosed, sold, or transferred as part of such a transaction.


  1. YOUR PRIVACY CHOICES AND RIGHTS

Your Privacy Choices. The privacy choices you may have about your personal information are described below.

Email Communications. If you receive an unwanted email from us, you can use the unsubscribe functionality found at the bottom of the email to opt out of receiving future emails. Note that you will continue to receive transaction-related emails. We may also send you certain non-promotional communications regarding us and the Services, and you will not be able to opt out of those communications (e.g., communications regarding the Services or updates to this Privacy Notice).

Mobile Devices. We may send you push notifications through our mobile application. You may opt out from receiving these push notifications by changing the settings on your mobile device. With your consent, we may also collect precise location-based information via our mobile application. You may opt out of this collection by changing the settings on your mobile device. To request deletion of your account, please use the standard deletion functionality available via the Services, or contact us using the information set forth in “Contact Us” below.

“Do Not Track.” Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.

• Cookies. You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. However, if you adjust your preferences, the Services may not work properly. Please note that cookie-based opt-outs are not effective on mobile applications. However, you may opt- out of certain tracking on some mobile applications by following the instructions for Android, iOS, and others. The online advertising industry also provides mechanisms that may allow you to opt out of receiving targeted ads from organizations that participate in self-regulatory programs. To learn more, visit the Network Advertising Initiative, the Digital Advertising Alliance, and the European Digital Advertising Alliance. Please note you must separately opt out in each browser and on each device.

Your Privacy Rights. In accordance with applicable law, you may have the right to:

  • Confirm Whether We Are Processing Your Personal Information;

  • Request Access to or Portability of Your Personal Information;

  • Request Correction of Your Personal Information;

  • Request Deletion of Your Personal Information;

  • Request Restriction of or Object to our Processing of Your Personal Information; and

  • Withdraw Your Consent to our Processing of Your Personal Information. Please note that your withdrawal will only take effect for future processing, and will not affect the lawfulness of processing before the withdrawal.

If you would like to exercise any of these rights, please contact us below. We will process such requests in accordance with applicable laws. If your personal information is subject to the applicable data protection laws of the European Economic Area or the United Kingdom, you have the right to lodge a complaint with the competent supervisory authority if you believe our processing of your personal information violates applicable law.

  1. INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION

All personal information processed by us may be transferred, processed, and stored anywhere in the world,
including, but not limited to, the United States or other countries, which may have data protection laws that are different from the laws where you live. These countries may or may not have adequate data protection laws as defined by the data protection authority in your country. If we transfer personal information from the European Economic Area, Switzerland, and/or the United Kingdom to a country that does not provide an adequate level of protection under applicable data protection laws, one of the safeguards we may use to support such transfer is the EU Standard Contractual Clauses.

For more information about the safeguards we use for international transfers of your personal information, please contact us below.


  1. RETENTION OF PERSONAL INFORMATION

We store the personal information we collect as described in this Privacy Notice for as long as you use the Services, or as necessary to fulfill the purpose(s) for which it was collected, provide the Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws. To determine the appropriate retention period for personal information, we may consider applicable legal requirements, the amount, nature, and sensitivity of the personal information, certain risk factors, the purposes for which we process your personal information, and whether we can achieve those purposes through other means.


  1. SUPPLEMENTAL NOTICE FOR EU/UK GDPR

This Supplemental Notice for EU/UK GDPR only applies to our processing of personal information that is subject to the EU or UK General Data Protection Regulation. In some cases, providing personal information may be a requirement under applicable law, a contractual requirement, or a requirement necessary to enter into a contract. If you choose not to provide personal information in cases where it is required, we will inform you of the consequences at the time of your refusal to provide the personal information.
Simulon’s processing of your personal information may be supported by one or more of the following lawful bases:

Privacy Notice

Section

Lawful Basis:

Performance of a

Contract (i.e., to

provide the Services

to you)

Lawful Basis:

Legitimate Interest

Lawful Basis:

Consent

Lawful Basis: For

Compliance with

Legal Obligations

Section 3A: Provide

the Services

Section 3B:

Administrative

Purposes

Section 3C: Marketing



Section 3D: With Your

Consent or Direction


Section 3E:

Automated Decision

Making


If we process personal information that is considered a “special category of personal data”, then our processing of this personal information may be supported by one or more of the following conditions:

• Explicit Consent: You may have provided your explicit consent for our processing of your personal information.

• Publicly Available Personal Information: Our processing of your personal information may relate to personal information which has been manifestly made public by you.

• Necessary for the Establishment, Exercise or Defense of Legal Claims: Our processing of your personal information may be necessary for the establishment, exercise or defense of legal claims.


  1. CHILDREN’S PERSONAL INFORMATION

The Services are not directed to children under 13 (or other age as required by local law outside the United States), and we do not knowingly collect personal information from children. Please see THIS PAGE for more about our age rating suitability. you are a parent or guardian and believe your child has uploaded personal information to the Services in violation of applicable law, you may contact us below.


10. THIRD-PARTY WEBSITES/APPLICATIONS

The Services may contain links to other websites/applications and other websites/applications may reference or link to our Services. These third-party services are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen, or approve, and are not responsible for, the privacy practices or content of such other websites or applications. Providing personal information to third-party websites or applications is at your own risk.


11. CONTACT US

Simulon is the controller of the personal information we process under this Privacy Notice. If you have any questions about our privacy practices or this Privacy Notice, or to exercise your rights as detailed in this Privacy Notice, please contact us at privacy@simulon.com.

EU Representative:
Rickert Rechtsanwaltsgesellschaft mbH
Beamm Technologies Inc.
Colmantstraße 15, 53115 Bonn
Germany
art-27-rep-beamm@rickert.law

UK Representative:
Rickert Services Ltd UK
Beamm Technologies Inc.
PO Box 1487 Peterborough PE1 9XX
United Kingdom
art-27-rep-beamm@rickert-services.uk

Switzerland Representative:
HÄRTING Attorneys-at-Law Ltd.
Landis + Gyr-Strasse 1 6300 Zug
swissdatarep@haerting.ch

Turkey Representative:
Att. Didem Kalaycioglu Birol
Sultan Selim District Humeyra Street.
Nef 09 B Block No: 7 Inner Door No: 57
Kagithane/ Istanbul, Turkiye.
info@dkb-legal.com

Updated: October 2025

This Privacy Notice applies to the processing of personal information by Beamm Technologies Inc. d/b/a Simulon (“Simulon,” “we,” “us,” or “our”) including on our website available at https://simulon.com/, our mobile application, and our other online or offline offerings which link to, or are otherwise subject to, this Privacy Notice (collectively, the “Services”).

Contents

1.Updates To This Privacy Notice

2.Personal Information We Collect

3.How We Use Personal Information

4.How We Disclose Personal Information

5.Your Privacy Choices And Rights

6.International Transfers Of Personal Information

7.Retention Of Personal Information

8.Supplemental Notice For Eu/Uk GDRP

9.Children’s Personal Information

10.Third-Party Websites/Applications

11.Contact Us


  1. UPDATES TO THIS PRIVACY NOTICE

We may update this Privacy Notice from time to time in our sole discretion. If we do, we’ll let you know by posting
the updated Privacy Notice on our website, and/or we may also send other communications.


  1. PERSONAL INFORMATION WE COLLECT

We collect personal information that you provide to us, personal information we collect automatically when you use the Services, and personal information from third-party sources, as described below.

A. Personal Information You Provide to Us Directly

We may collect personal information that you provide to us, such as Account Information.
We may collect personal information in connection with the creation or administration of your account. This personal information may include, but is not limited to:

  • Contact Details and Other Information. We may collect personal information such as your name, email address, phone number, professional details, and other information you store with your account.


  • Content and Related Information. We may collect any content you provide, along with information about, or contained in, the content. This information may include, but is not limited to, thumbnails, titles, images, audio, transcripts, and videos. It may also include details, statistics, analytics, performance information, and other information about the content.


  • Purchases. We may collect personal information and details associated with your purchases, including payment information. Any payments made via our Services are processed by third-party payment processors. We do not directly collect or store any payment card information entered through our Services, but we may receive information associated with your payment card information (e.g., your billing details).


  • Your Communications with Us. We, and our service providers, may collect the information you communicate to us, such as through email or our web chat tool.


  • Surveys. We may contact you to participate in surveys. If you decide to participate, we may collect personal information from you in connection with the survey.


  • Interactive Features. We and others who use our Services may collect personal information that you submit or make available through our interactive features (e.g., messaging features, commenting functionalities, forums, blogs, and social media pages). Any information you provide using the public sharing features of the Services will be considered “public.”


  • Sweepstakes or Contests. We may collect personal information you provide for any sweepstakes or contests that we offer. In some jurisdictions, we are required to publicly share information of sweepstakes and contest winners.


  • Conferences, Trade Shows, and Other Events. We may collect personal information from individuals when we attend or host conferences, trade shows, and other events.


  • Business Development and Strategic Partnerships. We may collect personal information from individuals and third parties to assess and pursue potential business opportunities.


  • Job Applications. If you apply for a job with us, we will collect any personal information you provide in connection with your application, such as your contact information and CV.

B. Personal Information Collected Automatically

We may collect personal information automatically when you use the Services, such as:

Device Information. We may collect personal information about your device, such as your Internet protocol (IP) address, user settings, cookie identifiers, other unique identifiers, browser or device information, hardware model, operating system version, device sensor information (such as gyroscopes, compasses and microphones), network connection, Internet service provider, and location information (including, as applicable, approximate location derived from IP address and precise geo-location information).

Usage Information. We may collect personal information about your use of the Services, such as the pages that you visit, items that you search for, the types of content you interact with, information about the links you click, the frequency and duration of your activities, and other information about how you use the Services.

Cookie Notice (and Other Technologies). We, as well as third parties, may use cookies, pixel tags, and other technologies (“Technologies”) to automatically collect personal information through your use of the Services.

  • Cookies. Cookies are small text files stored in device browsers.

  • Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded. in the Services that collects personal information about use of or engagement with the Services. The use of a pixel tag allows us to record, for example, that a user has visited, a particular web page or clicked on a particular advertisement. We may also include web beacons in e-mails to understand whether messages have been opened, acted on, or forwarded. See “Your Privacy Choices and Rights” below to understand your choices regarding these Technologies.

Analytics. We may use Technologies and other third-party tools to process analytics information on our Services. Some of our analytics partners could include:

Google Analytics. We use analytics services provided by Google Inc. This allows us to process usage data to better understand how our website and web-related Services are used. This enables us to continually improve our website, making it relevant to your interests and needs. This may involve personal data, such as cookie and other device identifiers. The data collected by Google Analytics is usually transferred to a Google server in the USA and processed there. In addition, Google uses your data for its own purposes, e.g., for profiling or linking it to other data. For more information, please visit Google Analytics’ Privacy Policy. To learn more about how to opt-out of Google Analytics’ use of your information, please click here.

LinkedIn Analytics. For more information, please visit LinkedIn Analytics’ Privacy Policy. To learn more about how to opt-out of LinkedIn’s use of your information, please click here.

Mixpanel. For more information about Mixpanel, please visit Mixpanel’s Privacy Policy.

Facebook Connect. For more information, please visit Facebook’s Data Policy. You can object to the collection of your data by Facebook pixel, or to the use of your data for the purpose of displaying Facebook ads by contacting the following address while logged into your Facebook account: https://www.facebook.com/settings?tab=ads.

C. Personal Information Collected from Third Parties

We may collect personal information about you from third parties. For example, if you access the Services using a Third-Party Service (defined below), we may collect personal information about you from that Third-Party Service that you have made available via your privacy settings. In addition, users of the Services may upload or otherwise provide personal information about others.


  1. HOW WE USE PERSONAL INFORMATION

We use personal information for a variety of business purposes, including to provide the Services, for administrative purposes, and to provide you with marketing materials, as described below.

A. Provide the Services

We use personal information to fulfill our contract with you and provide the Services, such as:
  • Managing your information;

  • Providing access to certain areas, functionalities, and features of the Services;

  • Answering requests for support;

  • Communicating with you;

  • Sharing personal information with third parties as needed to provide the Services;

  • Processing your financial information and other payment methods for products and Services purchased;

  • Processing applications if you apply for a job we post on our Services; and

  • Allowing you to register for events.

B. Administrative Purposes

We use personal information for various administrative purposes, such as:

  • Pursuing our legitimate interests such as direct marketing, research and development (including marketing research), network and information security, and fraud prevention;

  • Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity;

  • Carrying out analytics;

  • Measuring interest and engagement in the Services;

  • Performing computations;

  • Developing and/or training models;

  • Improving, upgrading, or enhancing the Services;

  • Developing new products and services;

  • Creating de-identified and/or aggregated information.;

  • Ensuring internal quality control and safety;

  • Authenticating and verifying individual identities, including requests to exercise your rights under this Privacy Notice;

  • Debugging to identify and repair errors with the Services;

  • Auditing relating to interactions, transactions, and other compliance activities;

  • Enforcing our agreements and policies; and

  • Carrying out activities that are required to comply with our legal obligations.

C. Marketing

We may use personal information to tailor and provide you with marketing and other content. We may provide you
with these materials as permitted by applicable law. If you have any questions about our marketing practices, you may contact us below.

D. With Your Consent or Direction

We may use personal information for other purposes that are clearly disclosed to you at the time you provide
personal information, with your consent, or as otherwise directed by you.

E. Automated Decision Making

We may engage in automated decision making, including profiling.


  1. HOW WE DISCLOSE PERSONAL INFORMATION

We disclose personal information to third parties for a variety of business purposes, including to provide the
Services, to protect us or others, or in the event of a major business transaction such as a merger, sale, or asset transfer, as described below.

A. Disclosures to Provide the Services

We may disclose any of the personal information we collect to the categories of third parties described below.

Service Providers. We may disclose personal information to third-party service providers that assist us with the provision of the Services. This may include, but is not limited to, service providers that provide us with hosting, customer service, analytics, marketing services, IT support, and related services. In addition, personal information and chat communications may be disclosed to service providers that help provide our chat features.

Other Users or Third Parties You Share or Interact With. The Services may allow Simulon users to share content (including personal information) or interact with other users or third parties (including the general public).

Third-Party Services You Share or Interact With. The Services may link to or allow you to interface, interact, share information with, direct us to share content/information with, access and/or use third-party websites, applications, services, products, and technology (each a “Third-Party Service”). Any personal information shared with a Third-Party Service will be subject to the Third- Party Service’s privacy policy. We are not responsible for the processing of personal information by Third-Party Services.

• Business Partners. We may share your personal information with business partners to provide you with a product or service you have requested. We may also share your personal information with business partners with whom we jointly offer products or services. Once your personal information is shared with our business partner, it will also be subject to our business partner’s privacy policy. We are not responsible for the processing of personal information by our business partners.

• Simulon Customers (Authorized Users Only). In cases where you use our Services as an employee, contractor, or other authorized user of a Simulon customer, that customer may access information associated with your use of the Services including usage data and the contents of the communications and files associated with your account. Your personal information may also be subject to the Simulon customer’s privacy policy. We are not responsible for the Simulon customer’s processing of your personal information.

• Affiliates. We may share your personal information with our corporate affiliates.

B. Disclosures to Protect Us or Others

We may access, preserve, and disclose any information we store associated with you to external parties if we, in
good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our, or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.

C. Disclosure in the Event of Merger, Sale, or Other Asset Transfers
If we are involved in a merger, acquisition, financing, reorganization, bankruptcy, receivership, purchase or sale of assets, transition of service to another provider, or other similar corporate transaction, your personal information may be disclosed, sold, or transferred as part of such a transaction.


  1. YOUR PRIVACY CHOICES AND RIGHTS

Your Privacy Choices. The privacy choices you may have about your personal information are described below.

Email Communications. If you receive an unwanted email from us, you can use the unsubscribe functionality found at the bottom of the email to opt out of receiving future emails. Note that you will continue to receive transaction-related emails. We may also send you certain non-promotional communications regarding us and the Services, and you will not be able to opt out of those communications (e.g., communications regarding the Services or updates to this Privacy Notice).

Mobile Devices. We may send you push notifications through our mobile application. You may opt out from receiving these push notifications by changing the settings on your mobile device. With your consent, we may also collect precise location-based information via our mobile application. You may opt out of this collection by changing the settings on your mobile device. To request deletion of your account, please use the standard deletion functionality available via the Services, or contact us using the information set forth in “Contact Us” below.

“Do Not Track.” Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.

• Cookies. You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. However, if you adjust your preferences, the Services may not work properly. Please note that cookie-based opt-outs are not effective on mobile applications. However, you may opt- out of certain tracking on some mobile applications by following the instructions for Android, iOS, and others. The online advertising industry also provides mechanisms that may allow you to opt out of receiving targeted ads from organizations that participate in self-regulatory programs. To learn more, visit the Network Advertising Initiative, the Digital Advertising Alliance, and the European Digital Advertising Alliance. Please note you must separately opt out in each browser and on each device.

Your Privacy Rights. In accordance with applicable law, you may have the right to:

  • Confirm Whether We Are Processing Your Personal Information;

  • Request Access to or Portability of Your Personal Information;

  • Request Correction of Your Personal Information;

  • Request Deletion of Your Personal Information;

  • Request Restriction of or Object to our Processing of Your Personal Information; and

  • Withdraw Your Consent to our Processing of Your Personal Information. Please note that your withdrawal will only take effect for future processing, and will not affect the lawfulness of processing before the withdrawal.

If you would like to exercise any of these rights, please contact us below. We will process such requests in accordance with applicable laws. If your personal information is subject to the applicable data protection laws of the European Economic Area or the United Kingdom, you have the right to lodge a complaint with the competent supervisory authority if you believe our processing of your personal information violates applicable law.

  1. INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION

All personal information processed by us may be transferred, processed, and stored anywhere in the world,
including, but not limited to, the United States or other countries, which may have data protection laws that are different from the laws where you live. These countries may or may not have adequate data protection laws as defined by the data protection authority in your country. If we transfer personal information from the European Economic Area, Switzerland, and/or the United Kingdom to a country that does not provide an adequate level of protection under applicable data protection laws, one of the safeguards we may use to support such transfer is the EU Standard Contractual Clauses.

For more information about the safeguards we use for international transfers of your personal information, please contact us below.


  1. RETENTION OF PERSONAL INFORMATION

We store the personal information we collect as described in this Privacy Notice for as long as you use the Services, or as necessary to fulfill the purpose(s) for which it was collected, provide the Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws. To determine the appropriate retention period for personal information, we may consider applicable legal requirements, the amount, nature, and sensitivity of the personal information, certain risk factors, the purposes for which we process your personal information, and whether we can achieve those purposes through other means.


  1. SUPPLEMENTAL NOTICE FOR EU/UK GDPR

This Supplemental Notice for EU/UK GDPR only applies to our processing of personal information that is subject to the EU or UK General Data Protection Regulation. In some cases, providing personal information may be a requirement under applicable law, a contractual requirement, or a requirement necessary to enter into a contract. If you choose not to provide personal information in cases where it is required, we will inform you of the consequences at the time of your refusal to provide the personal information.
Simulon’s processing of your personal information may be supported by one or more of the following lawful bases:

Privacy Notice

Section

Lawful Basis:

Performance of a

Contract (i.e., to

provide the Services

to you)

Lawful Basis:

Legitimate Interest

Lawful Basis:

Consent

Lawful Basis: For

Compliance with

Legal Obligations

Section 3A: Provide

the Services

Section 3B:

Administrative

Purposes

Section 3C: Marketing



Section 3D: With Your

Consent or Direction


Section 3E:

Automated Decision

Making


If we process personal information that is considered a “special category of personal data”, then our processing of this personal information may be supported by one or more of the following conditions:

• Explicit Consent: You may have provided your explicit consent for our processing of your personal information.

• Publicly Available Personal Information: Our processing of your personal information may relate to personal information which has been manifestly made public by you.

• Necessary for the Establishment, Exercise or Defense of Legal Claims: Our processing of your personal information may be necessary for the establishment, exercise or defense of legal claims.


  1. CHILDREN’S PERSONAL INFORMATION

The Services are not directed to children under 13 (or other age as required by local law outside the United States), and we do not knowingly collect personal information from children. Please see THIS PAGE for more about our age rating suitability. you are a parent or guardian and believe your child has uploaded personal information to the Services in violation of applicable law, you may contact us below.


10. THIRD-PARTY WEBSITES/APPLICATIONS

The Services may contain links to other websites/applications and other websites/applications may reference or link to our Services. These third-party services are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen, or approve, and are not responsible for, the privacy practices or content of such other websites or applications. Providing personal information to third-party websites or applications is at your own risk.


11. CONTACT US

Simulon is the controller of the personal information we process under this Privacy Notice. If you have any questions about our privacy practices or this Privacy Notice, or to exercise your rights as detailed in this Privacy Notice, please contact us at privacy@simulon.com.

EU Representative:
Rickert Rechtsanwaltsgesellschaft mbH
Beamm Technologies Inc.
Colmantstraße 15, 53115 Bonn
Germany
art-27-rep-beamm@rickert.law

UK Representative:
Rickert Services Ltd UK
Beamm Technologies Inc.
PO Box 1487 Peterborough PE1 9XX
United Kingdom
art-27-rep-beamm@rickert-services.uk

Switzerland Representative:
HÄRTING Attorneys-at-Law Ltd.
Landis + Gyr-Strasse 1 6300 Zug
swissdatarep@haerting.ch

Turkey Representative:
Att. Didem Kalaycioglu Birol
Sultan Selim District Humeyra Street.
Nef 09 B Block No: 7 Inner Door No: 57
Kagithane/ Istanbul, Turkiye.
info@dkb-legal.com