PRIVACY POLICY

The purpose of this policy is to inform you about how we process your personal data in connection with the use of the website www.assetwins.com (the “Website”), the platform Asset Wins (the “Platform”) and/or the application Asset Wins (the “Application”) in compliance with Regulation (EU) 2016/679 of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (hereinafter the "GDPR") and French Data Protection Law n° 78-17 of 6 January 1978 (together the "Applicable Regulations").

This Privacy Policy does not describe the methods of collecting and processing your data via cookies and other tracers (“Cookies”) on the Website, Platform or Application. For more information, please consult our Cookies Policy.

1. Who is the data controller?

The data controller is Asset Wins Pte. Ltd. (UEN: 202617976H), a company incorporated in Singapore, with its registered office at 1 Marina Boulevard, #28-00, One Marina Boulevard, Singapore 018989.”Us” or “We”) when browsing on our Website or https://app.assetwins.com using our Platform as our client.

However, when we provide our services to our clients, we process personal data on their behalf and for their own purposes. Our clients act therefore as data controllers in accordance with Article 4 of GDPR while we act as data processor.

2. What personal data we collect?

Personal data is a data that identifies an individual directly or indirectly, in particular by reference to an identifier such as a name.

We may collect the following personal data:

• Identification data (e.g., full name, email address, country);

• Data relating to your professional life (e.g., company name, CV, position/function, LinkedIn URL);

• Login data (e.g., logs, IP address);

• Data related to recordings from telephone calls with our customer care service (e.g., content of the calls, dates of the calls);

• Browsing data (IP address, pages viewed, date and time of connection, browser used, operating system, user ID, MAID, user behavior (mouse tracking));

• If you choose to sign in using a third-party authentication service (e.g., Google, or Microsoft), certain data such as your name and email may be collected from that service. By choosing this method, you agree that the service may share this information with us. We do not collect your third-party account password;

• Economic and financial data (e.g., bank details);

• Any information you wish to send us as part of your contact or demonstration request.

Mandatory data are indicated when you provide us with your data. They are indicated by any means.

3. How do we collect your personal data?

We may collect your personal data in two ways:

• directly, when you provide it to us (for example, by filling in a contact request form on our Website or by creating an account on our Platform);
• indirectly, via commercial partners, service providers or database enhancement tools.

4. Details of the processing of your personal data

Objectives	Legal basis	Data retention periods
To provide you with our services available on our Platform through your account	Execution of the contract to which you are party, or our legitimate interest in monitoring the performance of a contract to which your company is party (i.e., our terms and conditions)	When you have created your account: personal data are retained for the duration of your account. Your connection logs are retained for 6 months. In addition, personal data may be archived for probationary purposes for a period of 5 years.
To perform operations related to contracts, orders, invoices, loyalty programs and customer relationship management	Execution of the contract to which you are party, or our legitimate interest in monitoring the performance of a contract to which your company is party (i.e., our terms and conditions)	Personal data are retained for the duration of our business relationship. In addition, the data relating to your transactions (with the exception of your banking data) are archived for probationary purposes for a period of 5 years.
To analyze your use of the services, understand your expectations and improve the functionalities offered (in particular by analyzing exchanges or by compiling statistics on browsing and the audience for the Website, Platform and Application).	Our legitimate interest in improving our services	Recordings of telephone calls are retained for 6 months from the time they are collected. Documents analyzing the content of telephone calls are retained for 1week from the time of recording. If this does not concern telephone recordings (via cookies to improve the user experience): Personal data is stored for 25 months Once your data has been anonymized, it is no longer considered personal data, as it cannot be re-identified. They are retained for as long as necessary.
To manage your opinions on our products, services or content	Our legitimate interest in collecting your opinions on our products, services	2 years from the publication of the opinion
To create a database of customers and prospects	Our legitimate interest in developing and promoting our business	For our prospects: personal data is retained for 3 years from the date of your last contact. If you become a client: personal data is retained for the duration of the contract. In addition, the data relating to your transactions is archived for probationary purposes for a period of 5 years.
To send newsletters, requests and direct marketing mailings	For our customers and professional prospects: our legitimate interest in winning customer loyalty and informing our customers and prospects of our latest news. For our non-professional prospects: your consent.	Personal data is retained for a period of 3 years starting from the last contact with us (e.g., communication, action) or until you withdraw your consent when applicable.
Telephone prospecting	Our legitimate interest in developing and promoting our business	Personal data is retained for 3 years from the date of your last contact. We undertake to check beforehand that your number is not on a BLOCTEL-type opposition list.
To answer to your information request and other inquiries	Taking steps at your request prior to entering a contract	If you become a client: personal data is retained for the duration of the contract. If you do not become a client: personal data is retained for 3 years from the date of your last contact.
To comply with our legal and regulatory obligations	To comply with our legal and regulatory obligations	Invoices are archived for a period of 10 years. For our professional clients: the data relating to your contract and the elements relating to the signature of the contract are stored for 5 years from the conclusion of the contract. For our non-professional clients: the data relating to your contract and the elements relating to the signature of the contract are stored for 10 years from the conclusion of the contract.
To process your applications and to manage interview (pre-selection of candidates, contact to evaluate the candidate's ability to fill the position, finalization of the recruitment process)	Execution of precontractual measures	Personal data is retained in an active database for the duration of the recruitment process until the hiring decision is made. If your application is rejected, personal data may be retained for 3 months after the end of the recruitment process, in order to be able to provide you with explanations on the reasons that led to the rejection of your application. Personal data may be retained in an intermediate archive for evidential purposes for 5 years from the date of the hiring decision.
To create a CV database	Your consent	Personal data is retained for two years from the last contact with the data subject.
To process data subjects’ requests to exercise their rights	To comply with our legal and regulatory obligations	If we ask you a proof of identity: we only retain it for the necessary time to verify your identity. Once the verification has been carried out, the proof is deleted. If you exercise your right to object to direct marketing: we retain this information for 3 years. The information allowing the management of your requests to exercise your rights under the GDPR will be retained for 3 years from the date of the request.

5. Who are the recipients of your personal data?

The following categories of recipients will have access to your personal data:

1. The staff of our company;
2. Our processors: hosting provider, mailing provider, audience measurement tool, billing tool, cookie management tool, AI tool;
3. Our partners acting as independent data processors. We accept no responsibility for the processing of personal data by our partners, and invite you to consult their general terms of use and privacy policy;
4. to any authority legally empowered to deal with it, in particular the judicial, police or administrative authorities, if they so request.

6. Are your personal data likely to be transferred outside the European Union?

Your personal data is hosted for the duration of the processing on the servers of the company Microsoft (Azure), located in France.

As part of the tools, we use (see article on the recipients of your personal data, especially our processors), your personal data may be transferred outside the European Union. The transfer of your personal data in this context is secured with the use of following safeguards:

• Either personal data are transferred to a country that has been recognized as ensuring an adequate level of protection by a decision of the European Commission, in accordance with article 45 of the GDPR: in this case, this country ensures a level of protection deemed sufficient and adequate to the provisions of the GDPR; or

• The personal data are transferred to a country whose level of data protection has not been recognized as adequate to the GDPR: in this case these transfers are based on appropriate safeguards indicated in article 46 of the GDPR, adapted to each provider, including but not limited the execution of Standard Contractual Clauses approved by the European Commission, the application of Binding Corporate Rules or an approved certification mechanism; or

• The personal data are transferred under any appropriate safeguards described in Chapter V of the GDPR.

7. What rights can you exercise on your personal data?

You have the following rights regarding your personal data:

• Right to be informed: this is precisely why we have drafted this privacy policy as defined by articles 13 and 14 of the GDPR.

• Right of access: you have the right to access all your personal data at any time as defined by article 15 of the GDPR.

• Right to rectification: you have the right to rectify your inaccurate, incomplete or obsolete personal data at any time as defined by article 16 of the GDPR.

• Right to restriction of processing: you have the right to restrict the processing of your personal data in certain cases defined in article 18 of the GDPR.

• Right to erasure (“right to be forgotten”): you have the right to request that your personal data be deleted and to prohibit any future collection as defined by article 17 of the GDPR.

• Right to file a complaint to a competent supervisory authority (in France, the CNIL), under article 77 of the GDPR, if you consider that the processing of your personal data constitutes a breach of applicable regulations.

• Right to define instructions related to the retention, deletion and communication of your personal data after your death.

• Right to withdraw your consent at any time: for purposes based on consent, Article 7 of the GDPR provides that you may withdraw your consent at any time. Such withdrawal will not affect the lawfulness of the processing carried out before the withdrawal.

• Right to data portability: under specific conditions defined in article 20 of the GDPR, you have the right to receive the personal data you have provided us in a standard machine-readable format and to require their transfer to the recipient of your choice.

• Right to object: You have the right to object to the processing of your personal data as defined by article 21 of the GDPR. Please note that we may continue to process your personal data despite this opposition for legitimate reasons or for the defense of legal claims.

You can exercise these rights by writing to us at the following address: dpo@assetwins.com.

We may ask you to provide us with additional information if there is reasonable doubt, or any document likely to prove your identity if the doubt persists.

For any unsuccessful questions or requests, you are entitled to lodge a complaint with the competent supervisory authority in France, the Commission Nationale de l'Informatique et des Libertés (“CNIL”), located at 3 Place de Fontenoy - TSA 80715 - 75334 PARIS CEDEX 07.

8. Modifications

We may modify this privacy policy at any time, in particular to comply with any regulatory, jurisprudential, editorial or technical change. These modifications will apply on the date of entry into force of the modified version. Please regularly consult the latest version of this privacy policy. You will be kept posted of any significant change of the privacy policy.

Entry into force: 25 May 2026