DijiSense Privacy Policy

The Platform processes Personal Data only to the extent necessary for the performance of its contract with the customer, and only for the following specified purposes: **1. IoT Device Data Ingestion and Routing** Receiving, relaying, and processing data signals from customer-authorised IoT sensors, gateways, and devices to power real-time monitoring, alerting, and visualisation functionality. **2. Digital Twin Model Construction and Maintenance** Processing customer-provided facility information — including architectural models, device layout data, and historical sensor data — to build and maintain Digital Twin models for facility analysis and decision support. **3. Audit Ledger Archiving (Subscribed Users Only)** For customers who have subscribed to the "Mail Ledger Audit Archiving Service," providing a neutral, third-party archiving environment isolated from the customer's own systems, preserving sensor data and operational records for future audit and verification purposes. **4. Security Operations and Technical Support** Collecting necessary system access logs and operational audit records to maintain platform security, identify anomalous access behaviour, and provide technical support upon customer request.

The Platform collects the following categories of data as necessary to provide its services: **A. Customer Account Information** Business name, contact person name, email address, billing address, and payment information. Payment data is processed securely by third-party payment processors; the Platform does not retain full payment card numbers. **B. Facility and Device Information** Architectural floor plans, sensor point configurations, device model inventories, and API key configurations uploaded or authorised by the customer. **C. Sensor Operational Data** Real-time and historical numerical data generated by IoT sensors, including temperature, humidity, power consumption, air quality, and access control status. Such data generally does not constitute Personal Data; however, customers are solely responsible for determining whether the data they connect to the Platform includes any personally identifiable information. **D. User Activity Logs** Platform login timestamps, behavioural operation logs, Dashboard configuration change records, and API call records, used for security auditing and technical support. **E. Device and Connection Information** Browser type, IP address, operating system version, and session identifiers, used for authentication and connection security management.

The Platform strictly adheres to the principle of data minimisation in accordance with Article 5(1)(c) of the UK GDPR, reducing privacy risk to the greatest extent practicable. **Prohibition on Secondary Use** The Platform undertakes not to use customer data — including facility information, sensor data, device configurations, Digital Twin models, and operational records — for any purpose other than service delivery, technical support, and audit archiving. The Platform strictly prohibits data mining, advertising profiling, or the sale or transfer of any customer data to any third party. **Role as Data Processor** In connection with this service, the customer acts as the Data Controller and the Platform acts solely as the Data Processor within the meaning of the UK GDPR and the Data Protection Act 2018. The Platform will not disclose any customer data to external parties except as required by applicable law. Upon request, the Platform is prepared to enter into a Data Processing Agreement (DPA) compliant with Article 28 of the UK GDPR to support the customer's regulatory compliance. **SI White-Label Partner Data Processing** Customers holding an authorised SI Partner plan who provide Platform services to their own end customers under their own brand bear full and independent responsibility for the protection of their end customers' Personal Data. The Platform does not act as a Data Controller with respect to the end customers of any SI partner.

The Platform provides the following data protection mechanisms, tiered by security level: **1. Encryption at Rest** All historical sensor data, Digital Twin models, and audit ledger records stored in the Platform's cloud environment are encrypted using AES-256 symmetric encryption. **2. Encryption in Transit** All data transmissions — including MQTT, HTTP API, and WebSocket connections — are mandatorily protected using TLS 1.2 or higher, preventing interception or tampering in transit. **3. Key Management Principles** The Platform provides varying levels of encryption protection in accordance with the service plan selected by the customer. This may include platform-managed key custody, or the use of customer-provided keys (BYOK) or customer-held keys (HYOK). **4. Integrity Verification** Each batch of sensor data written to the audit ledger is assigned a SHA-256 digital fingerprint, ensuring data integrity from the moment of archiving and enabling verification that no tampering has occurred. **5. On-Premise Deployment** Customers who elect on-premise deployment retain all data within their own data centres; the Platform's cloud systems have no contact with that customer's data. Licence keys issued by the Platform are bound to the customer's designated server hardware. The Platform provides software licensing only and bears no responsibility for the customer's hardware, network infrastructure, or information security management.

The Platform delivers its services using globally distributed cloud infrastructure. **Cross-Border Transfer Compliance** For customer data subject to UK, EU, or other jurisdictional restrictions on international transfers, the Platform will ensure that such transfers comply with applicable legal requirements, including by implementing the International Data Transfer Agreement (IDTA), the UK Addendum to the EU Standard Contractual Clauses, or EU Standard Contractual Clauses (SCCs) as appropriate, or other transfer mechanisms recognised by the Information Commissioner's Office (ICO) or other competent supervisory authorities. **Substantive Equivalence** The Platform ensures a consistent and substantively equivalent standard of data security protection across all geographic service regions, without reducing protections based on a customer's location.

The Platform may engage the following categories of third-party service providers in connection with its operations: - **Cloud Infrastructure Providers:** Used for computing, storage, and networking services. All providers are bound by Data Processing Agreements (DPAs). - **Payment Processors** (e.g., Paddle, TapPay): Process subscription payments. The Platform does not retain full payment card data. - **Email Notification Services:** Used to deliver system alerts, billing notifications, and technical support communications. Only necessary information is transmitted. The Platform does not share customer data with advertisers, data brokers, or any third party not directly involved in service delivery.

**1. Exercise of Rights** The Platform respects the rights afforded to data subjects under the UK GDPR and the Data Protection Act 2018, including: - **Right of Access (Subject Access Request):** The right to obtain confirmation of whether Personal Data is being processed and to receive a copy of that data. - **Right to Rectification:** The right to have inaccurate Personal Data corrected without undue delay. - **Right to Erasure:** The right to request erasure of Personal Data where the grounds set out in Article 17 UK GDPR are met. - **Right to Restriction of Processing:** The right to restrict processing in the circumstances set out in Article 18 UK GDPR. - **Right to Data Portability:** The right to receive Personal Data in a structured, commonly used, and machine-readable format under Article 20 UK GDPR. - **Right to Lodge a Complaint:** Data subjects have the right to lodge a complaint with the Information Commissioner's Office (ICO) at www.ico.org.uk. To exercise any of the above rights, please contact: **security@dijisense.com** **2. Retention Periods** - **Account Data:** Retained for the duration of the active service term; permanently deleted within thirty (30) days of account termination. - **Historical Sensor Data:** Retained for the period corresponding to the customer's subscribed storage plan; securely destroyed using physical or irreversible digital destruction methods upon expiration. - **Audit Ledger Records:** Retained only for the duration of the customer's subscribed audit period. Upon service termination or a deletion request, the Platform will complete irreversible digital destruction within thirty (30) days. - **System Operational Logs:** Retained for a maximum of ninety (90) days for security audit purposes, then automatically purged. **3. On-Premise Deployment Customers** Customers who have elected on-premise deployment manage their own data. The Platform has no ability to execute deletion operations on their behalf. Customers may perform data purge procedures independently in accordance with the Platform's technical documentation.

The Platform's official website and management dashboard use strictly necessary cookies to maintain login sessions and user preferences, in accordance with the Privacy and Electronic Communications Regulations 2003 (PECR). The Platform does not use third-party advertising tracking cookies, engage in cross-site tracking, or deliver behavioural advertising.

The Platform's services are directed exclusively to businesses and professional organisations (B2B). The Platform does not provide services directly to children and does not knowingly collect Personal Data from any individual known to be under the age of eighteen (18).

This Policy will be updated from time to time in response to changes in applicable law or adjustments to the Platform's services. Customers will be notified of material changes by email or platform announcement at least thirty (30) days before the effective date of such changes. For any questions regarding this Policy or the Platform's data processing practices, please contact the Platform's Information Security and Compliance Team: **Contact:** security@dijisense.com **This Policy is governed by the laws of the Republic of China (Taiwan). Any disputes arising in connection with this Policy shall be subject to the exclusive jurisdiction of the Taiwan Taipei District Court as the court of first instance.**