Privacy Policy

Last updated 14 November 2024

This Privacy Statement for DECODE GR PRIVATE CAPITAL COMPANY (hereinafter referred to as "DECODE GR" or the "Company") describes how and why we may access, collect, store, use and/or share ("process") the of your personal information when you use our services ("Services"), including when:

• Visit our website at https://www.dikaio.ai/, or any of our websites linked to this Privacy Statement
• Cooperate with us in other relevant ways, including any sales, marketing or events Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights and choices. We are responsible for making decisions about how we process your personal information. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at info@dikaio.ai.

SUMMARY OF KEY POINTS

This summary provides key points from our Privacy Notice, but you can find out more detail about any of these topics by clicking on the link following each key point or using the table of contents below to find the section you're looking for.

• What personal information do we process? When you visit, use or navigate our Services, we may process personal information depending on how you interact with us and the Services, the

choices you make and the products and features you use.

• Do we process sensitive personal information? Some of the information may be considered "special" or "sensitive" in some jurisdictions, for example your ethnic origin. We may process sensitive personal information when necessary with your consent or as otherwise permitted by applicable law.
• Do we collect information from third parties? We do not collect information from third parties.
• How do we process your information? We process your information to provide, improve and administer our Services, to contact you, for security and fraud prevention, and to comply with the law. We may also process your information for other purposes with your consent. We only process your information when we have a valid legal reason to do so.
• Under what circumstances and with what types of parties do we share personal information? We may share information in certain situations and with certain categories of third parties.
• How do we keep your information secure? We have adequate organizational and technical processes and procedures in place to protect your personal data. However, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals or other unauthorized third parties will not be able to destroy the our security and collect inappropriate access, steal or modify your information.
• What are your rights? Depending on where you are geographically, applicable privacy laws may mean that you have certain rights regarding your personal information.
• How do you exercise your rights? The easiest way to exercise your rights is to submit a request

access for the data subject or contact us. We will consider and act on any request in accordance with applicable data protection legislation.

• Want to know more about what we do with any information we collect?

TABLE OF CONTENTS

1. WHAT INFORMATION DO WE COLLECT?
2. HOW DO WE PROCESS YOUR INFORMATION?
3. WHAT LEGAL BASIS DO WE PROCESS YOUR PERSONAL INFORMATION?
4. WHEN AND WHO WE SHARE IT WITH YOUR PERSONAL INFORMATION?
5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
6. DO WE OFFER PRODUCTS BASED ON ARTIFICIAL INTELLIGENCE?
7. HOW DO WE MANAGE YOUR SOCIAL CONNECTIONS?
8. HOW LONG DO WE KEEP YOUR INFORMATION?
9. HOW DO WE KEEP YOUR INFORMATION SECURE?
10. DO WE COLLECT INFORMATION FROM MINORS?
11. WHAT ARE YOUR PRIVACY RIGHTS?
12. DATA CHECK FOR "Do not Track" FEATURES
13. DO WE MAKE UPDATES TO THIS STATEMENT?
14. HOW CAN YOU CONTACT US?
15. HOW CAN YOU REVIEW, UPDATE OR DELETE THE DATA WE COLLECT FROM YOU?

1. WHAT INFORMATION DO WE COLLECT FROM YOU

Personal information you provide to us Briefly: We collect personal information that you voluntarily provide to us when you register for the Services, express an interest in receiving information about us or our products and services, when you engage in activities on the Services, or otherwise when you contact us. Personal information provided by you. The personal information we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:

• name
• email addresses
• language preference
• profile photo Sensitive Information. When necessary, with your consent or as otherwise permitted by applicable law, we process the following categories of sensitive information:
• data of legal documents
• legal case data Payment data. We may collect data necessary to process your payment if you choose to make purchases, such as your payment instrument number and the security code associated with your payment instrument. All payment data is managed and stored by Stripe. You can find the privacy notice links here: https://stripe.com/en-gr/privacy. Social media login data. We may provide you with the option to register with us using your existing social media account information, such as your Facebook, X or other social media account. If you choose to register in this way, we will collect certain profile information about you from your social media provider, as described below under "HOW DO WE MANAGE YOUR SOCIAL CONNECTIONS?".

All personal information you provide to us must be true, complete and accurate and you must notify us of any changes. Automatically Collected Information In Brief: Certain information -- such as your Internet Protocol (IP) address and/or your browser and device characteristics -- is automatically collected when you visit our Services. We automatically collect certain information when you visit, use or navigate the Services. This information does not reveal your specific identity (such as your name or contact information), but may include device and usage information such as your IP address, browser and device characteristics, operating system, preferences language, referral URLs, device name, country, location, information about how and when you use our Services and other technical information. This information is primarily necessary to maintain the security and operation of our Services, as well as for our internal analysis and reporting purposes. Like many businesses, we also collect information through cookies and similar technologies. The information we collect includes:

• Log and usage data. Log and usage data is service-related, diagnostic, usage and performance information that our servers automatically collect when you access or use our Services and that we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type and settings, and information about your activity on the Services (such as date/time stamps related to your usage, pages and files viewed, searches and other actions you take, such as which features you use), device event information (such as system activity, error reports (sometimes called "error logs") and settings hardware).

• Device data. We collect device data, such as information about the computer, phone, tablet or other device you use to access the Services. Depending on the device used, this device data may include information such as IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or carrier telephony, operating system and system configuration information.

• Location data. We collect location data, such as information about your device's location, which may be accurate or inaccurate. How much information we collect depends on the type and settings of the device you use to access the Services. For example, we may use GPS and other technologies to collect geolocation data that informs us of your current location (based on your IP address). You may opt out of allowing us to collect this information by either denying access to the information or turning off the Location setting on your device. However, if you choose to opt out, you may not be able to use certain aspects of the Services.

2. HOW DO WE PROCESS YOUR INFORMATION?

Briefly: We process your information to provide, improve, and administer our Services, to contact you, for security and fraud prevention, and to comply with the law. We may also process your information for other purposes with your consent. We process your personal information for a number of reasons, depending on how you interact with our Services, including:

• To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so that you can create and log in to your account and keep your account active.
• To provide and facilitate the delivery of the services to the user. We may process your information to provide you with the service you have requested.
• To ask for feedback. We may process your information when necessary to solicit feedback and contact you about your use of our Services.
• For marketing and product promotion purposes. We may process the personal information you send us for marketing purposes if this is in line with your preferences. You can opt out of the above notification at any time. For more information, see "WHAT ARE YOUR PRIVACY RIGHTS?" below.
• To deliver targeted advertising to you. We may process your information to develop and deliver personalized content and advertising tailored to your interests, location and more.
• To protect our Services. We may process your information as part of our efforts to

keep our Services secure, including fraud monitoring and prevention;

• To determine the manner of use. We may process information about how you use our Services to better understand how you use them so we can improve them.
• To determine the effectiveness of marketing and promotional campaigns. We may process your information to better understand how to provide marketing and promotional campaigns that are more relevant to you.
• To save or protect the vital interests of an individual. We may process your information when necessary to save or protect an individual's vital interests, such as to prevent harm.

3. ON WHAT LEGAL BASIS DO WE PROCESS YOUR INFORMATION?

Briefly: We process your personal information only when we believe it is necessary, having a legitimate reason (ie, a legal basis) to do so in accordance with applicable law, such as with your consent, to comply with laws, to provide you with services for to enter into or fulfill our contractual obligations, protect your rights or fulfill our legitimate business interests. The General Data Protection Regulation (GDPR) and the corresponding UK Data Protection Regulation (UK GDPR) impose an obligation for us to clarify the valid legal bases on which the processing of your personal data is based. Therefore, we may rely on the following legal bases to process your personal data:

• Consent. We may process your information if you have given us permission (ie consent) to use your personal information for a specific purpose. You can withdraw your consent at any time. Learn more about withdrawing your consent.

• Contract Performance. We may process your personal information when we believe it is necessary to fulfill our contractual obligations to you, including the provision of our Services, or at your request prior to any transaction with you.

• Legitimate interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and your fundamental rights and freedoms. For example, we may process your personal information for some of the purposes described in order to:

• We send users information about special offers and discounts on our products and services.

• We develop and display personalized and relevant advertising content for our users.

• Analyze how our Services are used so we can improve them for our users.

• Support marketing activities.

• Diagnose problems and/or prevent fraudulent activities.

• Understand how our users use our products and services so that we can improve our users' experience.

• Legal Obligations. We may process your information where we believe it is necessary to comply with our legal obligations, such as cooperating with a law enforcement or regulatory authority, exercising or defending legal rights us or the disclosure of your information as evidence in a legal dispute in which the Company is involved.

• Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of third parties, such as situations involving potential threats to the safety of any person.

4. WHEN AND WHO DO WE SHARE YOUR PERSONAL INFORMATION?

Briefly: We may share information in certain circumstances described in this section and/or with the following categories of third parties.

Vendors, Consultants and Other Third Party Service Providers. We may share your data with third parties - including but not limited to suppliers, service providers, contractors or others ("third parties") who perform services for us or on our behalf and require access to this information to provide their services to the Company. We have entered into contracts with third parties, which aim to ensure the protection of your personal data. These agreements provide that third parties are not allowed to process your personal information without specific instructions from us. In addition, they undertake not to transmit your personal data to other entities other than the Company. Finally, they are required to ensure the integrity and security of the data they hold on our behalf and to keep it only for the period of time we specify. The categories of third parties with whom we may share personal information are as follows:

• AI platforms

• Ad networks

• Data analysis services

• Cloud Computing Services

• Data storage service providers

• Payment processors

• Performance monitoring tools

• Product Engineering & Design Tools

• Web hosting service providers

• Affiliate marketing programs We may also need to share your personal information in the following cases: Business transfers. We may share or transfer your information in connection with or during negotiations for any merger, sale of corporate assets, financing or acquisition of all or part of the Company to another company.

5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

Briefly: We may use cookies and other tracking technologies to collect and store your information. We may use cookies and similar tracking technologies (such as web beacons and pixels) to collect information when you interact with our Services. Certain online tracking technologies help us maintain the security of our Services and your account, prevent errors, fix errors, save your preferences, and assist with basic website functionality.

We also allow third parties and service providers to use online tracking technologies on our Services for analytics and advertising, including managing and serving ads, tailoring ads to your interests, or sending abandoned shopping cart reminders (depending on your communication preferences). Third parties and service providers use their technology to provide advertisements about products and services tailored to your interests, which may appear either on our Services or on other websites. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Statement.

6. WE OFFER PRODUCTS BASED ON ARTIFICIAL INTELLIGENCE

Briefly: We offer products, features or tools powered by artificial intelligence, machine learning or similar technologies. As part of our Services, we offer products, features or tools powered by artificial intelligence, machine learning or similar technologies (collectively, "AI Products"). These tools are designed to improve your experience and provide you with innovative solutions. The terms of this Privacy Notice govern the use of AI Products within our Services.

Use of AI technologies

We provide the AI Products through third party service providers ("AI Service Providers"), including Anthropic, OpenAI. As described in this Privacy Statement, your input, output and personal information will be shared with and processed by these artificial intelligence service providers to enable your use of our artificial intelligence products for purposes described in "TOU WHAT LEGAL BASIS ARE WE BASED ON FOR PROCESSING YOUR PERSONAL INFORMATION". You must not use the AI Products with

in any way that violates the terms or policies of any AI service provider; All the artificial intelligence models we use do not perform a training process with user data, thus ensuring the privacy and security of your information. In addition, the models we use are located within the European Union and fully comply with the General Data Protection Regulation (GDPR).

Our AI products

Our AI products are designed for the following functions:

• AI bots
• Create AI documents
• Image analysis
• Natural language processing

How we process your data using AI

All personal information processed with the AI Products is treated in accordance with our Privacy Statement and our agreement with third parties. This ensures a high level of security and protection of your personal data throughout the processing, giving you the assurance of the integrity and security of your information.

How to Opt Out

To opt out, you can contact us using the contact details provided.

7. HOW DO YOU MANAGE YOUR SOCIAL CONNECTIONS?

In Brief: If you choose to register or log in to our Services using a social media account, we may have access to certain information about you. Our Services offer you the ability to register and log in using your account information on third-party social media (such as your Google, Microsoft or LinkedIn login information). Where you choose to do this, we will receive certain profile information about you from your social media provider. The profile information we receive may vary depending on the social media provider concerned, but often includes your name, email address and profile picture, as well as other information you choose to make public on such social media platform. We will use the information we receive only for the purposes described in this Privacy Statement or otherwise made clear to you in the relevant Services. Please note that we do not control and are not responsible for other uses of your personal information by the third party social media provider. We encourage you to read their privacy notice to understand how they collect, use and share your personal information and how you can set your privacy preferences on their websites and apps.

8. HOW LONG DO WE KEEP YOUR INFORMATION?

Briefly: We retain your information for as long as necessary to fulfill the purposes described in this Privacy Statement, unless otherwise required by law. We will only retain your personal information for as long as is necessary for the purposes set out in this Privacy Statement, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). None of the purposes of this notice imposes an obligation to retain your personal data beyond the period of time during which you maintain an account with the company.

When there is no longer a legitimate business need to process your personal data, we will either delete or anonymize it. If this is not possible (e.g. due to storing your data in backup files), then your data will be stored securely and isolated from any further processing until it can be permanently deleted.

9. HOW DO WE KEEP YOUR INFORMATION SECURE?

Briefly: Our aim is to protect your personal information through a system of organizational and technical security measures. We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. Despite our reasonable safeguards and efforts to protect your data, no electronic transmission over the Internet or information storage technology can guarantee absolute security. Therefore, we cannot promise or guarantee that hackers, cybercriminals or other unauthorized third parties will not be able to compromise our security and collect inappropriate access to, steal or modify your data. Although we make every effort to protect your personal data, the transmission of your personal data to and from our Services is at your own risk. It is recommended that the Services be accessed only in a secure environment. All the services we use to maintain the data are fully harmonized with the applicable legislation of the European Union and have the certifications

• SOC 2 Type II Certifed (Assessment of data security, availability, and privacy by an independent organization)
• HIPAA Compliant (Compliance with health data security standards to protect sensitive information)
• GDPR Compliant (Compliance with the regulations of the European Union for the protection of personal data)
• ISO 27001 Certifed (Certification for the implementation and management of Information Security Systems)
• PCI DSS Certifed (Compliance with security standards for the protection of credit card data)
• Data Encryption at Rest and In Transit
• Role-Based Access Control

10. DO WE COLLECT INFORMATION FROM MINORS?

In Brief: We do not knowingly collect, solicit data from, direct our services to, or knowingly sell our services to minors under the age of 18. By using our Services, you represent that you are at least 18 years old or that you are the parent or legal guardian of a minor and consent to their use of the Services. In the event that we determine that they have collected personal data from persons under the age of 18, we will deactivate the relevant account and take reasonable steps to immediately delete such information from our records. If you find that we may have collected data from minors under the age of 18, please contact us at info@dikaio.ai.

11. WHAT ARE YOUR PRIVACY RIGHTS?

Briefly: In some regions, such as the European Economic Area (EEA), the United Kingdom (UK) and Switzerland, you have rights that allow you greater access and control over your personal information. You can review, change, or terminate your account at any time, depending on your country, province, or state of residence. In some regions (such as the EEA, UK and Switzerland), you have certain rights under applicable data protection laws. These may include the right to (i) request access to and obtain a copy of your personal information, (ii) request correction or deletion; (iii) restrict the processing of your personal information; (iv) if applicable, to data portability; and (v) not be subject to automated decision making. In some cases, you may also have the right to object to the processing of your personal information. You may make such a request by contacting us using the contact information provided in the HOW TO CONTACT US section below. We will consider and act on any request in accordance with applicable data protection legislation. If you are located in the EEA or the UK and you believe that we are processing your personal information unlawfully, you also have the right to lodge a complaint with your Member State's data protection authority or the UK's data protection authority. If you are located in Switzerland, you can contact the Federal Commissioner for Data and Information Protection. Withdrawal of your consent: If we have obtained your consent to process your personal information, you have the right to withdraw your consent at any time. by contacting us using the contact details that

are provided in the HOW TO CONTACT US section below However, please note that this will not affect the " or by updating your preferences. lawfulness of processing prior to its withdrawal nor will it affect processing of your personal information carried out on legitimate grounds for processing other than consent . Opting Out of Marketing and Promotional Communications: You may unsubscribe from marketing and promotional communications at any time by clicking “STOP” or by contacting us using the details provided in the “HOW TO CONTACT US” section below. After the process is complete, you will be removed from our marketing lists. However, we may still contact you for service-related purposes, such as sending you updates necessary to manage and use your account, respond to service requests, or for other non-marketing purposes. Account information If at any time you would like to review or change the information in your account or terminate your account, you may:

• Login to your account settings and update your account.
• Contact us using the contact details provided. Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain certain information in our records to prevent fraud, troubleshoot problems, assist in any investigations, enforce our legal terms and/or comply with applicable legal requirements. Cookies and similar technologies: Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and reject cookies. If you choose to remove cookies or reject cookies, this could affect some of our features or services. If you have questions or comments about your privacy rights, you can email us at [info@dikaio.ai] (mailto: info@dikaio.ai).

12. CONTROLS FOR "Do not Track" FEATURES

Most web browsers and some mobile operating systems and mobile apps include

a Do-Not-Track ("DNT") feature or setting that you can enable to indicate your “Do not Track” privacy preference regarding your web browsing activities. At this stage, no single technology standard for DNT signal recognition and implementation has been finalized. Therefore, we currently do not respond to browser DNT signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard is adopted for online tracking that we must follow in the future, we will notify you of that practice in a revised version of this Privacy Statement.

13. DO WE MAKE UPDATES TO THIS STATEMENT?

Briefly: Yes, we will update this Statement as necessary to remain compliant with applicable law. The revised version will be identified by the updated "Revision" date that will appear at the top of this Privacy Statement. In the event of material changes to this Privacy Statement, we may notify you either through a prominently posted notice of such changes or by contacting you directly. It is recommended that you regularly refer to this Privacy Statement so that you are aware of our data protection practices.

14. HOW CAN YOU CONTACT US?

If you have any questions about this Privacy Statement, our practices, or your relationship with us, please contact us:

• Via email: info@dikaio.ai DECODE GR PRIVATE COMPANY

Dimitris Gounaris 96, Maroussi 15124 Athens, Attica Greece

15. HOW CAN YOU REVIEW, UPDATE OR DELETE THE DATA WE COLLECT FROM YOU?

Under the applicable laws of your country, you may have the right to request access to the personal data we collect from you, to obtain details about how it is processed, to correct any inaccuracies, or to request the deletion of your personal data. You may also have the right to withdraw your consent to the processing of your personal data. These rights may be subject to restrictions in accordance with applicable law. To request access, correction or deletion of your personal data, please complete and submit an access request to the data subject.