ANDESPHERE PRIVACY POLICY

1. Introduction

This Privacy Policy (the "Policy") sets out the conditions under which Andesphere SpA and Andesphere Ltd. (collectively, the "Provider"), including their related companies, affiliates, subsidiaries and strategic partners, collect, process, use, store, transfer and protect data from users who access and use the service known as Andy Partner (the "Service").

Accessing, registering for, and using Andy Partner constitutes the user's free, conscious, express and irrevocable acceptance of this Policy, including broad authorization for their data to be used not only in Andy Partner but also across every current and future program, software, application and platform operated by Andesphere SpA and Andesphere Ltd.

The user understands that the consent granted also covers the possibility of sharing data with related companies, and that such sharing will be used solely to improve, develop, integrate and enhance the services offered.

2. Scope of the Policy

This Policy applies to all personal and usage data collected through:

• Andy Partner, in every modality and version.
• Any other current or future software, system, platform or application operated by Andesphere SpA and Andesphere Ltd.
• Related companies, affiliates, subsidiaries or strategic partners that receive or use data under authorization from the Provider in accordance with this Policy.

Consequently, the user acknowledges that their data may be processed beyond Andy Partner and across the entire Andesphere SpA and Andesphere Ltd. technology ecosystem and related companies.

3. Data Collected

The Provider may collect, directly or indirectly, the following categories of data:

• Identification data: name, last name, national ID, email, phone number, address and any other information provided during sign-up processes.
• Authentication data: credentials, encrypted passwords and security verifications.
• Interaction data: questions, instructions, commands, messages, files and any other content entered by the user in Andy Partner or other Andesphere programs.
• Technical data: IP address, approximate location, device type, operating system, browser, cookies and similar technologies.
• Usage-derived data: frequency, duration, history and usage patterns from Andy Partner and any current or future Provider software.

The user expressly authorizes all of this data to be used, shared and processed in Andy Partner, other Andesphere SpA and Andesphere Ltd. software and by their related companies.

4. Purposes of Processing

The collected data may be processed for the following purposes, broadly and redundantly:

• Service delivery: ensure Andy Partner operates correctly and securely.
• Continuous improvement: train, optimize and refine artificial intelligence models applied in Andy Partner and all current and future Provider software.
• New product development: use the data as input to design, test and deploy new digital solutions from Andesphere SpA and Andesphere Ltd.
• Related companies: share data with affiliated, subsidiary, related or strategic partner companies, provided it is used solely for technology projects, services or software connected to the Provider.
• Statistics and analytics: produce metrics, reports, usage trends and internal studies.
• Security and compliance: detect and prevent misuse, unauthorized access or fraud and comply with legal and regulatory requirements.
• Communication: contact the user regarding changes, updates, legal notices, news or legitimate promotions.

The user accepts and acknowledges that their data may be reused, combined and processed across different Andesphere SpA and Andesphere Ltd. products and related companies, always with the goal of improving and expanding the service ecosystem.

5. Confidentiality and Related Companies

• The Provider and its related companies commit to handling user data with strict confidentiality.
• Information will not be disclosed indiscriminately to unrelated third parties unless expressly authorized by the user or required by law.
• Information may be shared with related companies, affiliates, subsidiaries and strategic partners, ensuring it is used exclusively for technology initiatives linked to Andesphere SpA and Andesphere Ltd.

6. Transfers and Storage

• Data may be stored on servers located inside or outside Chile.
• International transfers will be carried out with appropriate security mechanisms and in accordance with applicable regulations.
• The user expressly agrees that shared data may circulate among Andesphere SpA, Andesphere Ltd. and their related companies, always within the terms of this Policy.

7. User Rights

The user may exercise the right to:

• Access: learn what data is being processed.
• Rectification: request correction of inaccurate data.
• Deletion: request deletion of data, except when retention is required for legal obligations.
• Objection: oppose certain processing activities.

These rights may be exercised regarding data processed in Andy Partner, in other Andesphere SpA and Andesphere Ltd. programs and their related companies.

8. Retention Period

Data will be retained for as long as necessary to fulfill the purposes described. After that period, data may be deleted or anonymized. Nevertheless, data may remain anonymized for statistical, research or software development purposes by Andesphere SpA, Andesphere Ltd. and related companies.

9. Information Security

The Provider will adopt technical, administrative and organizational measures to protect information against unauthorized access, loss or alteration.

The user acknowledges that no system is 100% secure and releases the Provider and its related companies from liability for incidents beyond reasonable control.

10. Policy Updates

The Provider may modify this Policy at any time. Changes come into effect upon publication on the Andy Partner platform or other official Andesphere SpA and Andesphere Ltd. channels.

Continued use of the Service after changes are published constitutes tacit acceptance of those modifications.

11. Governing Law and Jurisdiction

This Policy is governed by the laws of the Republic of Chile. Any dispute will be submitted to the Ordinary Courts of Justice of the city of Puerto Montt, and the user expressly waives any other venue.

12. Contact

Users may exercise their rights or ask questions via www.andesphere.com.

13. Final Clause

The user declares they have read, understood and fully accepted this Policy and grants express, broad and irrevocable consent for their data to be used in Andy Partner, in all current and future software operated by Andesphere SpA and Andesphere Ltd., and by their related companies, affiliates, subsidiaries and strategic partners.

The consent granted extends to any future technological development, even if not specifically identified at the time of acceptance.