VENOTIS TM PRIVACY POLICY

Effective Date: September 2024

IdentiGEN Ltd. ( registered under company registration number 257418 , whose registered office is at Block 2 Blackrock Business Park, Carysfort Avenue, Blackrock, Dublin A94 H2x4, Ireland) (herein after the “ Company ”) is committed to protecting your privacy and your personally identifiable data and other personal information (“ Personal Data ”). The Company ha s created this privacy policy (the “ Privacy Policy ”) to let you know what information the Company collect s when you use the product offering (as defined in the Terms of Use (as defined below)) provided by the Company (the “ System ”), how the Company collects it and how it makes use of it. Please read this Privacy Policy carefully prior to using the System.

Categories of Personal Data Collected

The Company collects and stores the Personal Data when you visit or use the System and when you provide it to the Company , such as in your communications with the Company. Types of the Personal Data collected include, without limitation, your name, your farm or other physical address, contact details as well as administrative and traffic data, such as IP address and crash reports, to improve System performance and to ensure your use of the System complies with the terms and conditions and end user license agreement entered into between you and the Company ( the “ Terms of Use ”).

Use of Personal Data

The Company shall only use or disclose Personal Data for the purpose for which it was collected, a related secondary purpose (where reasonably expected), with your consent, or where otherwise permitted by law.

The Company uses the Personal Data they collect from or about you to:

• Establish and manage the contractual relationship with you, including providing you with our services and customer support.
• Collect and use necessary feedback on the System to test and improve their functionality.
• Evaluate, update and improve the System.
• Conduct statistical and monitoring analysis (including, inter alia, via standard third-party data analytics tools), data analytics, undertake necessary security and identify verification checks, allow software integration with other tools that you use, to track your use of the System and/or for other internal purposes, such as evaluating, providing, and improving the System.
• Where we have your consent for direct marketing, provide you with promotional offers and information regarding products and services from the Company or third parties where you have accepted or consented to receive such offers and information via the System or otherwise.
• Generate aggregated data through the anonymization of your Personal Data.
• Any other purpose for which the Company may notify you from time to time.

Where applicable privacy and data protection laws require a legal basis to process Personal Data, the Company relies on the following lawful bases:

• The performance of the contract entered into between you and the Company where provision of the Personal Data is essential for the formation and performance of the product and related services ;
• The legitimate interests of the Company during the performance of the contract entered between your employer or contractor, you and the Company , as the case may be;
• The legitimate interests of the Company when enhancing and improving the System;
• When this is necessary for the Company to comply with legal obligations (e.g., when the Company is requested to provide the Personal Data as part of a legal investigation); and
• Your consent, or at your direction.

Where the Company process es your Personal Data on the basis of your consent, you have certain rights with respect to your personal information, such as, a right of access, correction, restriction of use, and deletion. If you object to the Company processing your personal data, we will cease collecting and using your personal information; doing so will limit our ability to interact with you. The Company may still be required to process certain personal information about you in order to meet our legal or regulatory obligations or based on the legitimate interests of the Company . If you choose to exercise your data protection rights, please visit www.msdprivacy.com and select your country of residence to submit your request .

Sharing and Transfer of Your Personal Data

The Company will share or otherwise disclose your Personal Data to the following categories of recipients in the following circumstances:

• Our corporate affiliates : to fulfil the purposes specified above in accordance with this Privacy Policy.
• Third party vendors and service providers : to provide and improve the System as well as for specialized services such as customer service, networking, billing, marketing, hosting, data processing and other services related to the System.
• Law enforcement authorities, courts, and administrative or regulatory bodies : to comply with applicable legislation, a court order or legal process.
• Other third parties as necessary : for purposes such as to protect and defend the Company ’ (or its licensors’) rights or property, prevent fraud or violations of our Terms of Use, and ensure the personal safety of other users of the System or the public at large.
• Potential purchasers or investors : in the event that the Company sell s , assign s or transfer s some or all of its business or assets to a successor or acquirer, or if the Company is acquired by or merges with a third party, or if the Company file s for bankruptcy or becomes insolvent, the Company will disclose, sell, assign or transfer all of your Personal Data as part of the transaction.

We may share your information among our corporate affiliates and will do so in accordance with our Global Privacy Statement, Global Cross Border Privacy Policy, our Binding Corporate Rules (which have been approved in the European Union) and/or the Standard Contractual Clauses (when applicable). Your personal information may also be shared with other organisations who work on our behalf but solely at the direction of the Company . Organisations that receive information from the Company will be contractually bound to only use this information in accordance with Company’s instructions and in a manner that is consistent with all relevant data protection laws. A copy of our Global Privacy Statement and Global Cross Border Privacy Policy can be found by visiting the following site: www.msdprivacy.com.

Security

The Company ha s implemented suitable security policies, rules and technical measures to protect and safeguard the Personal Data under its control from unauthorized access, improper use or disclosure, unauthorized modification, unlawful destruction or accidental loss. The Company may use third party vendors and hosting partners to provide the necessary hardware, software, networking, storage, and related technology required to provide the service. These may be located at destinations outside your jurisdiction. By submitting your Personal Data, you agree to this. All of the Company ' employees and data processors that have access to, and are associated with the processing of your Personal Data, are obliged to respect the confidentiality of your Personal Data.

Links to Other Sites

The System may contain links to other sites. Other sites may also reference or link to the System. The Company is not responsible for the privacy practices or the content of such other online sites, and any information collected by these third-party online sites is not governed by this Privacy Policy, and the Company assume s no responsibility or liability whatsoever for the policies (including privacy policies), practices, actions or omissions of such third parties.

Your Rights

You can opt-out of marketing emails by utilizing the “unsubscribe” link or other mechanism noted in marketing emails you receive from the Company .

In accordance with applicable law (including relevant exemptions, as applicable), you may have the right to object to or request restriction of processing of your Personal Data, the right to request access, rectification, erasure and portability of your Personal Data or the right to receive confirmation that the Company hold s your Personal Data. When requesting correction of your Personal Data, you may have the right under applicable law, to provide to us a statement of the correction sought ( the “ Correction Statement ” ) and request that, if we do not make the correction you have sought, the Correction Statement is attached to the relevant Personal Data. Where the Company is using your Personal Data on the basis of your consent, you have the right to withdraw this consent at any time without affecting the lawfulness of the processing based on the consent prior to its withdrawal. You also have the right to lodge a complaint in relation to a breach of privacy principles in accordance with the Company Privacy Statement (see below) or with your data protection authority. If you choose to exercise your data protection rights, please visit www.msdprivacy.com and select your country of residence to submit your request .

Retention and Deletion of Your Personal Data

The Company will retain your Personal Data for as long as needed to provide you with the services described in the Terms of Use. This often means that the Company will keep Personal Data for the duration of your account, which will be terminated in accordance with the Terms of Use. Please note, however, that where applicable legislation requires the Company to do so, it will be required to keep records of your Personal Data even after such termination during the term established by applicable law.

Contact Information

In the event that you wish to learn more about our data privacy practices or to make a complaint about how the Company processes your Personal Data, please contact the Company in the first instance at the contact details below:

IdentiGEN Ltd.

Contact details : Please visit www.msdprivacy.com and select your country of residence to obtain relevant contact details .

Company Privacy Statement: A copy of our Global Privacy Statement can be found by visiting the following site: www.msdprivacy.com. The Company will endeavour to deal with your request as soon as possible.

Where applicable, you have the right to lodge a complaint with a data protection authority.

Change to this Policy

The Company reserve s the right to make, from time to time, changes and updates to this Privacy Policy as shall be provided in the System. You are responsible for regularly familiarising yourself with our communication to obtain timely notice of such changes. If you do not agree to the altered Privacy Policy, you may stop using the System.