Privacy Policy

1. Definitions

In this policy, the following words have the following meanings:

“Data Protection Laws” means any applicable laws relating to the processing, privacy, and use of Personal Data, including (a) in the United Kingdom, (i) the Data Protection Act 1998 and the Privacy and Electronic Communications (EC Directive) Regulations 2003, SI 2003/2426, together with any law or regulation implementing Directive 95/46/EC (Data Protection Directive) or Directive 2002/58/EC (ePrivacy Directive); and/or (ii) the General Data Protection Regulation (EU) 2016/679 (GDPR), and/or any corresponding or equivalent national law or regulation (Revised UK DP Law); (b) in EU member states, the Data Protection Directive or GDPR (as applicable), and the ePrivacy Directive, together with all related member state laws or regulations; and (c) any judicial or administrative interpretation of the foregoing, any guidance, practice guidelines, codes of practice, approved codes of conduct, or approved certification mechanisms issued by any competent Supervisory Authority.

“Personal Data” means any information relating to an identified or identifiable natural person (“Data Subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person, and when referred to in this policy includes special categories of Personal Data.

2. Information We Collect About You and How We Collect It

a. We collect several types of information from and about users of the Platform, including:

• i. Personal Data;
• ii. Information about you that does not individually identify you, such as information about previous visits in the form of notes or service and purchase history; and
• iii. Information about your Internet connection, the devices you use to access the Platform, and usage details.

b. We collect this information:

• i. Directly from you when you provide it to us.
• ii. Automatically as you navigate through the Platform. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.

Information You Provide to Us

c. The information we collect on or through the Platform may include:

• i. Information that you provide by filling in forms on the Platform. This includes information provided at the time of creating an account.
• ii. Records and copies of your correspondence (including email addresses), if you contact us by email or SMS.
• iii. Details of transactions you carry out through the Platform and the fulfillment of your orders. You may need to provide payment information before placing an order through the Platform.

Information We Collect Through Automatic Data Collection Technologies

d. As you navigate through and interact with the Platform, we may use automatic data collection technologies to collect certain information about your devices, browsing actions, and usage patterns, including:

• i. Details of your visits to the Platform, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Platform.
• ii. Information about your computer and Internet connection, including your IP address, operating system, and browser type.

e. We may also use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). The Platform does not respond to "Do Not Track" signals.

f. The information we collect automatically does not include Personal Data.

g. This information helps us to improve the Platform and to deliver a better, more personalized service, including by enabling us to:

• i. Estimate our audience size and usage patterns.
• ii. Store information about your preferences, allowing us to customize the Platform according to your individual interests.
• iii. Speed up your searches.
• iv. Recognize you when you return to the Platform.
• v. Deliver relevant online advertising and marketing messages to you.

h. The technologies we use for automatic data collection may include:

• i. Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of the Platform. Unless you have adjusted your browser setting to refuse cookies, our system will issue cookies when you direct your browser to the Platform.
• ii. Web Beacons. Pages of the Platform and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, single-pixel gifs) that permit the company to count users who have visited those pages or opened an email and for other related statistics (for example, recording the popularity of certain content and verifying system and server integrity).

3. Children Under 13

Our Platform is not intended for children under 13 years of age. No one under age 13 may provide any personal information on the Platform. We do not knowingly collect personal information from children under 13. If you are under 13, please do not use or provide any information on this Platform, do not register, do not make any purchases, do not use any of the interactive or public comment features, and do not provide any information about yourself to us (including your name, address, telephone number, email address, screen name, or user name). If we learn that we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we may have any information from or about a child under 13, please contact us immediately at support@dsgex.ai.

4. Use of Collected Information

a. We will only use your Personal Data to the extent that the law allows us to do so. Under the GDPR, we rely on the following legal bases to process your Personal Data:

• i. Where you have given consent;
• ii. Where processing is necessary for the performance of a contract we have entered or are about to enter into with you; and
• iii. Where processing is necessary for the purposes of the legitimate interests pursued by us (or by a third party) and your interests or fundamental rights and freedoms do not override those interests.

b. We use information about you in the following ways:

• i. Processing requests or inquiries received from you; and
• ii. Processing requests for additional information or feedback when you express interest in one or more of our products/services.

c. We will use the information you provide:

• i. To carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products, and services that you request;
• ii. To provide you with information about other goods and services we offer that are similar to those that you have already purchased or inquired about;
• iii. To provide you, or permit other DSGex companies to provide you, with information about goods or services related to your request;
• iv. To notify you about changes to the Services; and
• v. To ensure that content from the Platform is presented in the most effective manner for you and for your device.

d. We will use the information we collect about you:

• i. To administer the Platform and for internal operations, including troubleshooting, data analysis, testing, research, statistical, and survey purposes;
• ii. To improve the Platform to ensure that content is presented in the most effective manner for you and for your device; and
• iii. As part of our efforts to keep the Platform safe and secure.

e. We may combine information received from other sources with information you provide to us and information we collect about you. We will use this information and the combined information for the purposes set out above (depending on the types of information we receive).

5. Disclosure of Your Information

a. You agree that we have the right to share your Personal Data with:

• i. Selected third parties including business partners, suppliers, and subcontractors for the performance of any contract we enter into with them or with you; and
• ii. Analytics and search engine providers that assist us in the improvement and optimization of the Platform.

b. We will not disclose your personal information to third parties unless:

• i. In the event that we sell or buy any business or assets, in which case we will disclose your Personal Data to the prospective buyer or seller;
• ii. If DSGex or substantially all of its assets are acquired by a third party, in which case Personal Data held by us about our customers will be one of the transferred assets;
• iii. If we are under a duty to disclose or share your Personal Data to comply with any legal obligation, or to enforce other agreements, or to protect the rights, property, or safety of DSGex, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction. In certain situations, we may be required to disclose Personal Data in response to lawful requests by public authorities, including national security or law enforcement requirements.

6. Where We Store Your Personal Data

a. We have put in place measures to protect your Personal Data from accidental loss and from unauthorized access, use, alteration, or disclosure. All information you provide to us is stored on our secure servers behind firewalls. Any payment transactions will be encrypted using Transport Layer Security (TLS).

b. The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of the Platform, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

c. Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your Personal Data, we cannot guarantee the security of your data transmitted to the Platform; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.

7. How Long We Store Personal Data

a. We will only retain your Personal Data for as long as necessary to fulfill the purposes we collected it for.

b. To determine the appropriate retention period for Personal Data, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure, the purposes for which we process the data and whether we can achieve those purposes through other means, as well as applicable legal requirements.

8. Your Rights Under GDPR

Under certain circumstances, you have the right to:

• a. Request access to your Personal Data (commonly known as a "subject access request"). This enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it.
• b. Request correction of the Personal Data that we hold about you.
• c. Request erasure of your Personal Data.
• d. Object to processing of your Personal Data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object.
• e. Request restriction of processing of your Personal Data.
• f. Request the transfer of your Personal Data to another party.

To exercise any of the above rights, please contact us using the information in the Contact section below. You also have the right to lodge a complaint under the GDPR with the competent Supervisory Authority. A list of Supervisory Authorities is available at: ec.europa.eu/justice/data-protection/bodies/authorities.

Our Platform may contain links to the websites of our partners, advertisers, and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies.

9. Your California Privacy Rights

California's “Shine the Light” law (Civil Code Section § 1798.83) permits California residents to request information regarding our disclosure of personal information to third parties for direct marketing purposes. To make such a request, please send an email to support@dsgex.ai.

10. Arbitration Agreement

In the event of a dispute between you and DSGex arising out of or relating to this Privacy Policy, either party may elect to resolve the dispute through binding arbitration rather than in court (the "Arbitration Agreement"). Under certain conditions, you may request binding arbitration when other dispute resolution procedures have been exhausted. Any claim (except claims challenging the validity or enforceability of this arbitration agreement, including the Class Action Waiver) may be resolved by binding arbitration if either party requests it.

THIS MEANS THAT IF EITHER YOU OR DSGEX ELECTS ARBITRATION, NEITHER PARTY SHALL HAVE THE RIGHT TO LITIGATE THAT CLAIM IN COURT OR TO HAVE A JURY TRIAL. DISCOVERY AND APPEAL RIGHTS ARE ALSO LIMITED IN ARBITRATION.

11. Class Action Waiver

ARBITRATION MUST BE ON AN INDIVIDUAL BASIS. THIS MEANS THAT NEITHER YOU NOR DSGEX MAY JOIN OR CONSOLIDATE CLAIMS IN ARBITRATION BY OR AGAINST OTHER PARTIES, OR LITIGATE IN COURT OR ARBITRATE ANY CLAIMS AS A REPRESENTATIVE OR MEMBER OF A CLASS OR IN A PRIVATE ATTORNEY GENERAL CAPACITY.

12. Governing Law and Arbitration Rules

The Arbitration Agreement is governed by the Federal Arbitration Act (FAA). Arbitration must be conducted only with the American Arbitration Association (AAA) or Judicial Arbitration and Mediation Services (JAMS). The arbitration rules will be the procedures of the selected arbitration organization. If the organization's procedures change after a claim is filed, the procedures in effect at the time the claim was filed will apply. Arbitration hearings shall take place in Minnesota. A single arbitrator will be appointed. The arbitrator must follow all applicable substantive law (unless it conflicts with the FAA), observe statutes of limitations, respect valid privileges, and issue a written decision with reasons.

The arbitrator's decision is final and binding unless the FAA allows for judicial review. However, if the amount in controversy genuinely exceeds $100,000, either you or DSGex may elect to appeal to a new panel of three arbitrators. The appellate panel has full discretion to accept or reject the original award in whole or in part. An appeal must be filed within 30 days after the original award is issued. The appealing party bears all costs of the appeal unless the appellate panel determines otherwise.

13. Contact

Questions, comments, and requests regarding this privacy policy are welcomed and should be addressed to us at:

GEIA LLC
E-mail: support@dsgex.ai

Dated: April 14, 2026