TOPSALE PRIVACY POLICY Effective Date: April 24, 2026 Version: 1.0 ================================================================================ 1. INTRODUCTION TOPSALE ("we", "us", or "our") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, store, and share information when you access or use our websites, applications, and services (collectively, the "Services"). By using our Services, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with our practices, please do not use the Services. ================================================================================ 2. INFORMATION WE COLLECT We collect only the minimum information necessary to provide and improve our Services. We do not collect any personally identifiable information such as names, email addresses, or company names. All identifiers used in our system are anonymous and cannot be traced back to any specific individual. 2.1 Anonymous Identifiers When you register for or use our Services, we assign you a randomly generated anonymous ID. This identifier has no connection to your real identity and cannot be used to identify you as an individual. 2.2 Usage and Behavioral Data We collect information about how you interact with our Services, linked only to your anonymous ID, including: - Pages visited and features used - Time spent on specific pages - Clickstream data and navigation paths - Actions taken within the application 2.3 Device and Technical Data When you access our Services, we automatically collect certain technical information, including: - IP address (anonymised or truncated where possible) - Operating system (e.g., Windows, macOS, iOS, Android) - Browser type and version - Device type (e.g., desktop, mobile, tablet) - Language preferences and time zone - Screen resolution 2.4 Cookies and Tracking Technologies We use analytical cookies only. These cookies help us understand usage patterns and improve our Services. We do not use advertising or targeting cookies. The analytical cookies we use include: - Session cookies: temporary cookies that expire when you close your browser - Persistent analytics cookies: used to recognise returning visitors anonymously and understand usage trends You can control cookies through your browser settings. Disabling analytical cookies may affect your experience of our Services. 2.5 Information from Third Parties We may receive anonymised usage data from third-party analytics providers that assist us in operating our Services. These providers are contractually required to handle data in accordance with this policy. ================================================================================ 3. HOW WE USE YOUR INFORMATION We use the information we collect for the following purposes: - To provide, maintain, and improve our Services - To personalise your experience and deliver relevant content - To analyse usage trends and optimise product performance - To detect, prevent, and address technical issues and security threats - To communicate with you about updates and support - To comply with legal obligations and enforce our terms We do not use any automated decision-making or profiling that produces legal or similarly significant effects on users. ================================================================================ 4. THIRD-PARTY SERVICES AND ANALYTICS We use Amplitude, a third-party product analytics service, to help us understand how users engage with our Services. Amplitude collects anonymised behavioural data through our Services. Amplitude may use cookies and similar technologies to collect information about your interactions. We do not control the data practices of Amplitude. We encourage you to review Amplitude's Privacy Policy at https://amplitude.com/privacy for more information on how they handle data. We do not use Google Analytics or any Google tracking services in our platform. ================================================================================ 5. HOW WE SHARE YOUR INFORMATION We do not sell your personal information. We may share information in the following circumstances: - With service providers who perform functions on our behalf (e.g., hosting, analytics, customer support) - To comply with applicable laws, regulations, or legal processes - To protect the rights, property, or safety of TOPSALE, our users, or the public - In connection with a merger, acquisition, or sale of assets, subject to confidentiality obligations ================================================================================ 6. DATA RETENTION We retain your data for the duration of your active account registration with us. All data associated with your anonymous ID is retained while your account remains active. Upon account termination or deregistration, your data will be deleted or anonymised within a reasonable period, unless we are required by law to retain it for longer. ================================================================================ 7. DATA SECURITY We implement reasonable administrative, technical, and physical safeguards to protect the information we collect. However, no method of transmission over the Internet or electronic storage is completely secure, and we cannot guarantee absolute security. ================================================================================ 8. YOUR RIGHTS AND CHOICES Depending on your location, you may have certain rights regarding your information. As we do not collect personally identifiable information, many of these rights are fulfilled by design. However, you may still contact us to exercise the following rights: - The right to access information held about you - The right to request correction or deletion of your data - The right to object to or restrict certain processing activities - The right to withdraw consent where processing is based on consent - The right to lodge a complaint with a supervisory authority ================================================================================ 9. EUROPEAN USERS - GDPR If you are located in the European Economic Area (EEA), the United Kingdom, or Switzerland, the following additional terms apply under the General Data Protection Regulation (GDPR) or equivalent legislation. 9.1 Legal Basis for Processing We process your information on the following legal bases: - Legitimate interests: to operate, maintain, and improve our Services - Legal obligation: to comply with applicable laws and regulations - Consent: where you have provided explicit consent (e.g., for analytical cookies) 9.2 Data Subject Rights Under GDPR, you have the right to: access your data (Article 15), rectify inaccurate data (Article 16), erasure of your data (Article 17), restriction of processing (Article 18), data portability (Article 20), and to object to processing (Article 21). 9.3 International Transfers Your data may be transferred to and processed in countries outside the EEA, including New Zealand and the United States. We ensure appropriate safeguards are in place, such as Standard Contractual Clauses, to protect your data in accordance with GDPR requirements. 9.4 Data Protection Officer For GDPR-related enquiries, please contact us at the details provided in Section 14. ================================================================================ 10. CALIFORNIA USERS - CCPA If you are a California resident, the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA) provide you with specific rights regarding your personal information. 10.1 Your California Rights - Right to Know: You may request disclosure of the categories and specific pieces of personal information we have collected about you. - Right to Delete: You may request deletion of personal information we have collected, subject to certain exceptions. - Right to Correct: You may request correction of inaccurate personal information. - Right to Opt-Out: We do not sell or share personal information for cross-context behavioural advertising. - Right to Non-Discrimination: We will not discriminate against you for exercising your CCPA rights. 10.2 Submitting a CCPA Request To submit a verifiable consumer request, please contact us using the details in Section 14. We will respond within 45 days as required by law. ================================================================================ 11. NEW ZEALAND USERS - PRIVACY ACT 2020 We comply with the New Zealand Privacy Act 2020 and the Information Privacy Principles (IPPs) contained therein. 11.1 Collection of Information We collect only the information necessary for the purposes described in this policy. We do not collect information by unlawful means or in ways that are unfair or unreasonably intrusive. 11.2 Your Rights Under the Privacy Act 2020 - You have the right to request access to personal information we hold about you (Information Privacy Principle 6). - You have the right to request correction of your personal information if it is inaccurate (Information Privacy Principle 7). - You have the right to complain to the Office of the Privacy Commissioner if you believe we have breached the Privacy Act 2020. 11.3 Privacy Commissioner If you have concerns about how we handle your information, you may contact the Office of the Privacy Commissioner at www.privacy.org.nz or call 0800 803 909. ================================================================================ 12. INTERNATIONAL DATA TRANSFERS Your information may be transferred to and processed in countries other than the one in which you reside, including but not limited to New Zealand and the United States. We take appropriate measures to ensure that your information receives an adequate level of protection in the jurisdictions in which we process it. ================================================================================ 13. CHANGES TO THIS PRIVACY POLICY We may update this Privacy Policy from time to time. When we make material changes, we will update the version number and effective date at the top of this document. Your continued use of the Services after the changes take effect constitutes your acceptance of the revised policy. ================================================================================ 14. CONTACT US If you have any questions, concerns, or requests regarding this Privacy Policy, please contact us at: Email: enquiry@appzgate.co.nz Company: Appzgate Solutions Limited