Data Privacy Policy

Effective Date: 16 January 2025

Application Scope: This Data Privacy Policy applies to the use of our website joseki.problem-manager.eu and our mobile application Joseki-Master, available on the Apple App Store and Google Play Store) (collectively, "Services").

The aim of this Policy is to:

• Ensure that you understand what personal data we collect about you, the reasons why we collect and use it, and who we share it with;
• Explain the way we use the personal data that you share with us in order to give you a great experience when you are using our Services; and
• Explain your rights and choices in relation to the personal data we collect and process about you and how we will protect your privacy.

Acknowledgement

By using our Services, you acknowledge that you have read, understood, and agree to this Data Privacy Policy. If you do not agree, please do not use our Services.

1. Introduction

Lihos GmbH ("we," "us," or "our") is committed to protecting your privacy. We take pride in treating our users' privacy the way we would like to be treated ourselves. This Data Privacy Policy explains how we receive, collect, store, use, disclose, and protect your personal information when you use our Services, including the information we collect through our advertising practices. We make sure we comply with US Data Privacy Laws, the EU General Data Protection Regulation as well as other applicable laws and regulations.

2. Data Collected

2.1 Data that you voluntarily provide us with:

2.1.1 You may provide us with your personal data in a number of ways, including, without limitation, when you sign up for the Services; have previously provided us with personal information prior to this Privacy Policy or last updates coming into effect; purchase a subscription or make any payment for the Services; subscribe to any alerts, information releases, news, newsletters, updates and media releases; complete and submit any forms to us; post any content on or through the Services; contact us directly in person or via any medium including but not limited to by mail, telephone, social media and commercial electronic messages; communicate with us for any matters.

2.1.2 Personal data that may be provided by you includes, but is not limited to:

1. contact information such as your full name, current and valid email address;
2. account password;
3. physical address;
4. phone number;
5. billing information and purchase history;
6. more detailed contact preferences;
7. location data.

2.1.3 By giving us this data, you consent to this data being collected, used, disclosed, transferred to Europe, and stored by us, as described in this Privacy Policy.

2.2 Data that we collect automatically

2.2.1 We collect data from every visitor and customer of the Services, in particular we automatically collect data about your visit to the Services and your usage of the Services. This anonymized information may include IP address, browser type, browser language, cookies data, actions you have taken within the Services, performance of the service, specifications of the user's hardware and software, date and time of access to the Services and the URL of the page requested, other information about how you interacted with our Services. This type of data helps us to improve our Services for both you and for all of our users. Data may be transferred to the following third parties: Microsoft Azure Cloud in Europe Such data will only be kept for 90 days. Legal basis for processing: it is in our legitimate interest.

2.2.2 When any kind of technical issue arises, we may collect data related to the issue to help us understand and fix the problem. This anonymized information may include data like: Instance IDs, Crash traces, and dump data.
Data may be transferred to the following third parties: Microsoft Azure Cloud in Europe Such data will only be kept for 90 days. Legal basis for processing: it is in our legitimate interest.

2.4 Cookies and tracking

2.4.1 Cookies are small data files that are placed on your computer or mobile device when you visit a website. Website owners use cookies to make their websites operate, improve functionality and user experience, as well as to provide reporting information.

2.4.2 We may set our own cookies and use third parties cookies (e.g. for advertising, interactive content and analytics).

2.4.3 We use different types of cookies, including:

a) Essential website cookies: these are important cookies as they are necessary to provide you with services available through our App, such as access to secure areas.

b) Performance and functionality cookies: these cookies are necessary to enhance the performance and functionality of our App but are non-essential to their use. However, without these cookies, certain functionality may become unavailable.

c) Analytics and customization cookies: these cookies collect information that is used either in aggregate form to help us understand how our App is being used or how effective our marketing campaigns are, or to help us customize our App for you in order to enhance your experience.

d) Advertising cookies: these cookies are used to make advertising messages more relevant to you. They perform functions like preventing the same ad from continuously reappearing, ensuring that ads are properly displayed, and in some cases selecting advertisements that are based on your interests.

2.4.4 You may opt out from cookies at any time by customizing your cookie preferences. However, in some cases we will not be able to provide you with all services.

2.5 Web beacons and similar technologies

2.5.1 Apart from cookies, we use other similar technologies, like web beacons, to monitor traffic, deliver and communicate with cookies, improve site performance. Similar to cookies you may opt out from web beacons at any time. If you wish to opt out of this processing activity, please contact us via email with the subject named ÔÇ£Privacy Policy BeaconsÔÇØ.

2.6 NA

2.7 Opting-Out

2.7.1 You may decline to have your personal data collected via third party tracking technologies by navigating to the settings feature in your browser and declining all third party cookies or declining third party cookies from specific sites, or, for mobile, limiting ad tracking or resetting the advertising identifier via the privacy settings on your mobile device.

2.7.2 If your browser does not permit you to block any cookies and similar technologies, you can use the following third party tools to decline the collection and use of information for the purpose of serving your interest based advertising:

a) The NAI's opt-out platform: http://www.networkadvertising.org/choices/

b) The EDAA's opt-out platform http://www.youronlinechoices.com/

c) The DAA's opt-out platform: http://optout.aboutads.info/?c=2&lang=EN

3. Use of Personal Information

We do not sell, trade, or rent your personal identification information to others. We only use your personal data for the following purposes:

• To Provide and Improve Our Services:
  • Operate, maintain, and enhance the quality of our Services.
  • Personalize your experience.
  • Bill and collect money for Services ordered.
  • Provide customer support in response to their inquiries;
• For Advertising and Marketing Purposes:
  • Display targeted and non-targeted advertisements within our Services.
  • Send newsletters and promotional emails (with your consent).
• For Legal and Safety Reasons:
  • Comply with laws and regulations.
  • Protect our rights, property, and safety, and that of our users and the public.
  • Respond to lawful requests by public authorities, including to meet national security or law enforcement requirements.
  • Transfer your information in the case of a sale, merger, consolidation, liquidation, reorganization, or acquisition.

4. Disclosure of Data

4.1 We do not share personal information you have provided to us without your consent, unless:

4.1.1 Doing so is appropriate to carry out your own request; 4.1.2 We believe it is needed to enforce our Terms, or if it is legally required; 4.1.3 We believe it is needed to detect, prevent or address fraud, security or technical issues; 4.1.4 Otherwise protect our property, legal rights, or that of others. 4.2 We don't share your personal information with third parties, except for people and other entities that perform certain tasks on our behalf and who are under our control (our ÔÇ£Service ProvidersÔÇØ). We may need to share personal information with our Service Providers in order to provide products or services to you. Unless we tell you differently, our Service Providers do not have any right to use Personal Information or other information we share with them beyond what is necessary to assist us. You hereby consent to our sharing of Personal Information with our Service Providers. Our Service Providers are:

5. Your Rights and Choices

• Right to Access and Rectification: Request access to your personal information and have it corrected if it's inaccurate.
• Right to Erasure: Request the deletion of your personal information.
• Right to Restrict Processing: Limit how we use your personal information.
• Right to Data Portability: Receive your personal information in a structured format.
• Right to Object (including to Marketing): Object to our processing of your personal information for direct marketing or other purposes.
• Right to Complain: You have the right to lodge a complaint with a supervisory authority: http://www.datenschutz.hessen.de.
• Cookie Management: Manage your cookie preferences through your browser settings.
• Advertising Preferences:
  • Mobile Devices: Use device settings to limit ad tracking.
  • Web: Utilize browser settings or tools like the Network Advertising Initiative (NAI) or Digital Advertising Alliance (DAA) to manage targeted advertising.

6. Security Measures

6.1 The protection of your personal data is vital to us. We implement appropriate technical and organizational measures to protect your personal information against unauthorized access, disclosure, alteration, and destruction. While we strive to use commercially acceptable means to protect your personal data, no method of transmission over the Internet, or method of electronic storage, is completely secure, and we cannot guarantee the absolute security of any data.

6.2 You agree to protect the security of your login information and password and not to transfer such information to any third party. We will not be liable to you for the use of your account by any third party.

6.3 If you become aware of any unauthorized use of your account, you shall immediately notify us in writing.

7. International Transfers

For users outside the country where our servers are located (Europen Union), please note that we transfer your personal information to our servers. We ensure that these transfers are made with appropriate safeguards in place, such as the EU Standard Contractual Clauses, or the recipient's participation in the EU-US Privacy Shield Framework (where applicable).

8. Children's Privacy

Minors and children under the age of 16 (or other legal age of your country of residence) should not use our Services. If you are minor or a child, you need to obtain a written parental or guardian consent. We do not knowingly provide any Services to minors. If you access our Services, you represent that you have the legal capacity to enter into a binding agreement.

**9. Data Retention

9.1 We retain your personal data primarily within the USA and Europe. We retain your personal data for as long as we need it to fulfil the purposes for which we originally collected it or as needed to provide with the Services, except if required otherwise by law. In some cases we may determine the period of data retention based on the period we need to access the data for the provision of services, receiving payment, or for any other auditing or legal purposes.

9.2 Countries where we process information may have laws that are different, and potentially not as protective, as the laws of your own country, though we will always comply with the applicable laws when we process any information.

9.3 Data which is not needed anymore and not required to be retained by any laws or regulation is normally deleted latest 90 day thereafter.

**10. Merge of Company

10.1 If we merge with, or are acquired by, another company or organization, or sells all or a portion of its assets, your personal data may be disclosed to our advisers and any prospective purchaser or any prospective purchaser's adviser and may be among the assets transferred. However, personal data will always remain subject to this Privacy Policy.

11. Legal basis for processing

We collect and process personal data only where we have your consent, or where it is in our legitimate interest.

12. Changes to This Policy

We may update this Data Privacy Policy from time to time. Use of information we collect now is subject to the Privacy Policy in effect at the time such information is used. We will notify you of material changes through a notice on our Website or App or via email.

13. Contact Us

For any questions, concerns, or to exercise your rights, please contact our Data Protection Officer at:

• Email: joseki AT lihos.com
• Address: Lihos GmbH; Data Protection Officer; Talblick 7; 65760 Eschborn; Germany

Acknowledgement

By using our Services, you acknowledge that you have read, understood, and agree to this Data Privacy Policy. If you do not agree, please do not use our Services.

Version: 1.1

Last Updated: 16 January 2025