2.1 “Personal Data” is information about an individual whose identity is apparent or can
reasonably be ascertained from that information and includes information about an
individual consumer collected online and maintained in an accessible form.

2.2 Nieo’s may collect Personal Data you provide while interacting with us through the supply
of our Services including through our website and app sign in and authentication
procedures.

2.3 We receive and store Personal Data you provide to us through our business activities,
through your use of our Website or Apps, when we answer your queries or when you
provide Personal Data to us as an employee or applicant for employment.

2.4 We or our service providers may collect, store and process Personal Data from you when
you use our Website, order and register products, subscribe to and register services, and
respond to marketing or support materials.

2.5 For any of our Services that require a password, it is your responsibility to keep your
password confidential and secure.

We ask you to provide Personal Data and obtain other information through the use of our
Website or Apps, such as the following categories of information:

– name, phone number, address, usernames, passwords, email addresses, photos,
subscriptions or registration details, forms submitted and user preferences.

– non-identifiable device information, IP addresses, location data, system logs, browser activity,
operating system, length of visit, number of visits and referral sources, user preference settings,
unique IDs generate for each Website sign in, product descriptions viewed

– Information from authorised third party sources may include name, addresses, email
addresses, phone number and demographic data

2.6 We may collect additional data from Customers at other times, including but not limited to,
when you provide feedback, respond to events,surveys and promotions, or communicate
with our customer support.

2.7 We also collect Personal Data to improve our Services through marketing communications
and data analytics.

2.8 We do not knowingly collect any Personal Data from you that is considered sensitive or a
“Special Category” under the GDPR such as Personal Data revealing physical or mental
health, racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade
union membership, and the processing of genetic data, biometric data for the purpose of
uniquely identifying a natural person, data concerning health or data concerning a natural
person’s sex life or sexual orientation.

2.9 We do not knowingly collect or process Personal Data of persons 13 years or younger. If
you are under the age of 16, we request that you obtain and provide verifiable parental
consent as required by any of the Privacy Laws.

3.1 We collect Personal Data from you in a variety of ways, including when you interact with us
electronically or in person, when you access our Website, App’s, or when we provide our
Services to you or for employment purposes.

3.2 Personal Data may be provided by you directly or may be sent to us automatically when
you use our Website.

3.3 We may also receive Personal Data from third parties in connection with the supply of our
Services. If we do, we will protect your Personal Data in accordance with this Privacy
Policy.

4.1 Nieo’s Grille uses your Personal Data and you consent to us using your Personal Data to:

(a) supply you with our Website and App’s in accordance with our Terms

(b) provide you with information and updates about our Website and our Services;

(c) communicate with you by a variety of measures including, but not limited to, by
telephone, email, SMS or mail;

(d) manage, research and develop our Website and our Services including through data
analytics;

(e) administer our business activities and internal record keeping;

(f) meet legal, regulatory and compliance obligations; and

(g) investigate any complaints.

4.2 If you choose to withhold your Personal Data, it may not be possible for us to provide you
with our Services or for you to access certain parts of our Website or App’s and for us to
respond to your query.

(a) supply you with our Website and App’s in accordance with our Terms

(b) provide you with information and updates about our Website and our Services;

(c) communicate with you by a variety of measures including, but not limited to, by
telephone, email, SMS or mail;

(d) manage, research and develop our Website and our Services including through data
analytics;

(e) administer our business activities and internal record keeping;

(f) meet legal, regulatory and compliance obligations; and

(g) investigate any complaints.

4.2 If you choose to withhold your Personal Data, it may not be possible for us to provide you
with our Services or for you to access certain parts of our Website or App’s and for us to
respond to your query.

5.1 “Personal Data” refers to any information relating to an identifiable natural person who can
be identified directly or indirectly (“Data Subject”).

5.2 The GDPR applies to the data processing activities of businesses with an establishment in
the EU or where the processing activities relate to offering goods or services to individuals
in the EU, or monitoring the behaviour of individuals in the EU.

5.3 If you are an individual residing in the EU, we may collect and process Personal Data
about you in accordance with the GDPR. A “Controller” says how and why personal data is
processed and a “Processor” acts on behalf of the Controller by processing the data.
Nieo’s Grille operates both as a Controller and a Processor when controlling or processing
the Personal Data of customers, employees and resellers.

5.4 When you use our Website, we process Personal Data on your behalf as a Data Processor
where you are the Data Controller and otherwise to the extent that we are a Data
Controller as defined in the GDPR.

5.5 The legal basis we rely on to collect and process your Personal Data is based on the
following:

(a) Contractual basis. This legal basis applies to the collection or processing of Personal
Data in order to fulfil or perform a contract with you, or to which you are a party.

(b) Consensual basis. This applies where you have provided your consent to the
collection or processing of Personal Data for a specific purpose (for example, to
provide you with marketing updates). You can withdraw your consent at any time by
updating your email preferences, opting-out, or by contacting us directly.

(c) Legitimate interests. This applies where we have a legitimate interest to collect or
process your Personal Data. For example, it may be to respond to an enquiry about
our Services.

(d) Legal obligations. This applies where it is necessary to disclose your Personal Data
to comply with a legal obligation.

5.6 When we use third-parties to process your Personal Data on our behalf, we ensure that
the processing of this Personal Data is confidential, pursuant to our documented
instructions and in accordance with the legal basis for the processing.

5.7 We only employ third-party data processors that are compliant with the GDPR
requirements and that have sufficient security measures in place to protect and safeguard
your data.

5.8 In the event of a Personal Data breach including any breach of security that leads to the
accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to
Personal Data transmitted, stored or process, we will report the breach to you (where we
are required to do so under the GDPR) without undue delay after becoming aware of the
breach, and not later than 72 hours after the breach giving you a description of the nature
of the breach.

6.1 You as a customer own all right, title and interest in the content and personal information
that you provide to us (“Subscriber Data”).

6.2 You are solely responsible for the accuracy, quality, integrity, legality, reliability, and
appropriateness of your Subscriber Data.

6.3 You grant to Nieo’s Grille, or to any third parties used by us to provide the Website or
Services and any associated software, a non-exclusive, worldwide and royalty free licence
to use, copy, display, perform, distribute, disseminate, transmit, translate, edit, cache and
create derivative works of Subscriber Data.

6.4 Nieo’s Grille or any related entities owns all right, title and interest in any data or
information that we create, generate, compile, derive or produce in connection with any
supply of our Website or Services, including data and information that is:

a) aggregate or raw or statistical relating to usage, analyses and results of the Website;

(b) for the purpose of optimising delivery, commercialisation and performance of our
Website; and

(c) samples and prototypes, conclusions, techniques, know how, methods, and
undocumented findings generated in the usual course of our business.

7.1 Under the Privacy Laws, you have certain rights as to how your Personal Data is being
controlled and used. We will provide you with reasonable access to your Personal Data in
accordance with the relevant Privacy Laws.

7.2 We comply with your rights under the Privacy Laws and the GDPR (subject to the grounds
set out in the GDPR) that permit you:

(a) to be informed as to how your Personal Data is being used;

(b) to access your Personal Data and to know specifically what information is held about
you and how it is processed, where and for what purpose (we will provide you with a
copy of your Personal Data in electronic format free of charge if requested);

(c) to rectify your Personal Data if it is inaccurate or incomplete;

(d) to erase your Personal Data (also known as ‘the right to be forgotten’) if you wish to
delete or remove your Personal Data;

(e) to restrict processing of your Personal Data;