Privacy Notice for AROS: Smart Robotic Solutions

1. Purpose of This Notice

This Privacy Notice explains how ASBISC ENTERPRISES PLC ("we", "our", "us") collects, uses, and protects personal data when you use the AROS: Smart Robotic Solutions mobile application ("App"). The App is designed exclusively for authorized service providers invited by ASBISC ENTERPRISES PLC to perform maintenance and support for kiosks. This Notice also describes your rights under applicable data protection laws, including the EU General Data Protection Regulation (GDPR).

We aim to provide full transparency regarding our data practices, including what data we collect, why we collect it, how we store and protect it, and your rights as a data subject.

2. Contact Details

Data Controller: ASBISC ENTERPRISES PLC

Address: 1 Iapetou Street, Agios Athanasios, 4101 Limassol, Cyprus

Email: dpo@asbis.com

Phone: 25 857 097/ 25 857 098

3. Scope

This Privacy Notice applies only to the App and its authorized users. The App is not intended for public use and is accessible only to invited service providers. It does not apply to any unrelated websites or services.

4. Definitions

Personal Data: Any information relating to an identified or identifiable natural person.

Processing: Any operation performed on personal data, such as collection, storage, use, disclosure, or deletion.

Controller: The entity that determines the purposes and means of processing personal data.

5. Data We Collect

We collect and process the following categories of personal data:

We do not collect special category data or social media data.

6. How We Collect Data

• Directly from you: When you log in or contact support
• Automatically: Through app usage (technical logs, device info)
• From your employer: When your account is created by your company administrator

7. Purposes and Legal Basis

We process your personal data for the following purposes:

8. Failure to Provide Data

If you fail to provide required data, we may not be able to grant access to the App or perform our contractual obligations.

9. Data Sharing

We may share your data with:

• Your employer (service provider company)
• Authorized third-party IT providers for hosting and maintenance under strict confidentiality agreements

We do not sell or share your data for advertising.

10. International Transfers

If data is transferred outside the EU/EEA, we ensure appropriate safeguards such as Standard Contractual Clauses, encryption during transfer, and strict access controls.

11. Data Retention

We retain your data only as long as necessary for providing services under the contract and compliance with legal obligations. Detailed retention timelines are provided in Section 5.

12. Your Rights

Under GDPR, you have the right to:

• Access your personal data
• Request correction or deletion
• Object to processing based on legitimate interests
• Request data portability
• Withdraw consent (where applicable)

To exercise your rights, contact us at feedback_roboshops@asbis.com. We will respond within 30 days.

You also have the right to lodge a complaint with a supervisory authority if you believe your rights have been violated.

13. Security Measures

We implement technical and organizational measures to protect your data, including:

• Encryption of data in transit and at rest
• Secure authentication and password policies
• Regular security audits and vulnerability assessments
• Access control based on least privilege principle

You are responsible for keeping your login credentials confidential.

14. Changes to This Notice

We may update this Notice from time to time. Significant changes will be communicated via the App or email.

15. Contact

For questions or to exercise your rights:

Email: dpo@asbis.com

Address: 1 Iapetou Street, Agios Athanasios, 4101 Limassol, Cyprus