Introduction

Sustainable Office Solutions Ltd. and Sustainable Office Solutions Pte Ltd. (“Company”, “we” or “us”), respects your privacy and we are committed to protecting it through our compliance with this policy.

This policy describes the types of information we may collect from you or that you may provide when you visit www.sos-action.com (our “Website”) and our practices for collecting, using, maintaining, protecting and disclosing that information.

This policy applies solely to information we collect on this Website and in e-mail, text and other electronic messages between you and this Website. It does not apply to information collected by us offline or through any other means, including on any other website operated by us or any third party (including our affiliates) that may link to or be accessible from or on this Website.

Please read this policy carefully to understand our current policies and practices regarding your information and how we will treat it. BY SUBMITTING PERSONAL INFORMATION TO US OR BY ACCESSING OR USING THIS WEBSITE, YOU GIVE YOUR CONSENT THAT ALL PERSONAL INFORMATION THAT YOU SUBMIT MAY BE PROCESSED BY US IN THE MANNER AND FOR THE PURPOSE DESCRIBED IN THIS PRIVACY POLICY, AND YOU AFFIRM THAT YOU ARE EITHER MORE THAN 18 YEARS OF AGE, OR POSSESS LEGAL PARENTAL OR GUARDIAN CONSENT, AND THAT YOU ARE FULLY COMPETENT TO CONSENT TO THIS POLICY.

This policy may change from time to time as set out below under Changes to our Privacy Policy. Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check the policy frequently for updates.

Children’s Privacy

Our Website does not knowingly intend to collect personal information from children under 13 years of age. If you are under 13, do not use or provide any information on this Website or on or through any of its features. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information.

Information We Collect About You and How We Collect It

We may collect several types of information from and about users of our Website, including information: (a) by which you may be personally identified and that you will provide on a voluntary basis, such as name, postal address, e-mail address, telephone number or any other information that can be used to identify, describe, locate or contact you online or offline should you wish so (“personal information”) to provide you information on our products and services; (b) that is about you but individually does not identify you, such as the contents of your comments and postings on the Website; and/or (c) about your internet connection, the equipment you use to access our Website and usage details to improve your access and visit of our Website.

We collect this information depending on the context of your interactions with the Website, the features you use, and the choices you make. As further explained below, these can include: (a) directly from you when you provide it to us; and/or (b) automatically as you navigate through the site, including usage details, IP addresses and information collected through common information-gathering technologies. We rely on a variety of legal reasons and permissions (each a “legal basis”) to collect and process personal information about you, including with your consent, a balancing of legitimate interests, necessity to enter into and perform contracts with you, and compliance with legal obligations.

Information You Provide to Us

The information you provide directly to us on or through our Website may include: (a) information provided at the time of registering to use our Website or when requesting further services; (b) records and copies of your correspondence (including e-mail addresses), if you contact us; (c) your responses to surveys that we might ask you to complete for research purposes; (d) your search queries on the Website; and/or (e) details of transactions you carry out through our Website and their fulfillment.

Information We Collect Through Automatic Data Collection Technologies

As you navigate through and interact with our Website, we may use automatic data collection technologies to collect information about your equipment, browsing actions and patterns, including: (a) details of your visits to our Website and other communication data and the resources that you access and use on the Website; and (b) information about your computer and internet connection, including your IP address, operating system and browser type.

The information we collect automatically is often statistical data and does not include direct personal information, but we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to store information about your preferences, allowing us to customize our Website according to your individual interests and recognize you when you return to our Website.

Cookies on the Website. We use and engage certain other third-party advertising partners and analytics providers to use cookies, web beacons, and similar tracking technologies (collectively, “cookies”) on the Website. Cookies are small text files that are stored on your browser, device, or the page you are viewing. Some cookies are deleted once you close your browser, while other cookies are retained even after you close your browser so that you can be recognized on each subsequent visit. Cookies on our Website are generally classified into the following categories:

• Required/Operational Cookies: These are required for the operation of our Website and cannot be switched off in our systems. They are usually set in response to your actions and include, for example, cookies that enable you to log into secure areas, setting your own preferences, or filling in forms. These are session cookies that are erased when you close your browser and do not store any personal information.

• Performance/Analytical Cookies: These allow us to recognize and count the number of users of our Website and understand how users navigate through the Website. They tell us, for example, which pages are the most and least popular, which helps to improve how our Website works by ensuring that users can find what they are looking for easily. All information these cookies collect is aggregated and therefore anonymous. We use Google Analytics. For more information about this third-party analytics tool (and opting out of it), see Choices about How We Use and Disclose Your Information set out later in this policy.

• Advertising Cookies: These may be set through our Website by our authorized and trusted third-party advertising partners, which allows them to serve you targeted advertising (also referred to as “online behavioral advertising” or “interest-based advertising”) on our behalf across the Internet as you visit other websites that recognize the cookie. Advertising cookies rely on identifying details from your device and Internet browser. If you refuse or disable these cookies you will not enjoy targeted advertising from us or our advertising networks who provide us with the advertising services we request.

How to Manage Your Cookie Preferences

To comply with applicable law, we need to ask for your consent to set the cookies described above. When you arrive on our Website a pop-up message will appear asking for your consent to place cookies on your device. Once your consent has been provided, we use a cookie to ensure this message will not appear again when you revisit. For information about how to control the use of cookies on your device or your cookie settings and preferences for our Website, see Choices about How We Use and Disclose Your Information set out later in this policy.

How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal information for the following purposes: (a) to present our Website and its contents to you; (b) to provide you with information, products or services that you request from us; (c) to analyze and improve our products and services; and (d) to market our products and services.

Our Retention of Your Information

We retain personal information only as permitted under applicable laws, including only for as long as necessary to provide the products or services and fulfill the transactions you have requested, or for other essential purposes such as complying with our legal obligations, resolving disputes, and enforcing our agreements.

Disclosure of Your Information

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction under the conditions set forth in this section.

We may disclose for the purposes described above, personal information that we collect or you provide as set out in this privacy policy: (a) to our subsidiaries and affiliates; (b) to contractors, service providers and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them; and (c) to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of the Company’s assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by the Company about our Website users is among the assets transferred.

We may also disclose your personal information: (a) to comply with any court order, law or legal process, including to respond to any government or regulatory request; and (b) to enforce or apply our Terms of Use and other agreements;

Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

• Cookies and Ad Tracking Technologies. To change your cookie settings and preferences for our Website, click the Cookie Preferences link here or in the footer of the page. You can also control the use of cookies on your device, by setting your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies on your device, please note that some parts of the Website may then be inaccessible or not function properly, and you may be required to re-enter your log-in details when you visit.

• Google Analytics & Salesforce. We use a third-party web analytics tool to collect statistical data about our users’ browsing actions and patterns to help us improve the Website. Google Analytics & Salesforce collect only the IP address assigned to you on the date you visit this Website and no other identifying information. Although Google Analytics places a permanent cookie on your web browser to identify you as a unique user the next time you visit the Website, the cookie cannot be used by anyone but Google. Google’s ability to use and share information collected by Google Analytics about your visits to this Website is restricted by the Google Analytics Terms of Use and the Google Privacy Policy. You can prevent Google Analytics from recognizing you on return visits to this Website by disabling cookies on your browser, or to opt-out go to Google Analytics Opt-out Tool .

• Marketing from the Company. If you do not wish to have your contact information used by the Company to promote our products or services, you can opt-out by sending us an e-mail stating your request using the “Contact Us” form. If we have sent you a promotional e-mail, you may click on the opt-out option included in the email and thus send us a return e-mail asking to be omitted from future e-mail distributions. This opt-out does not apply to information provided to the Company as a result of a product purchase, warranty registration, product service experience or other transactions.

Accessing and Correcting Your Information

You can review and change your personal information by logging into the Website and visiting your account profile page. You may also contact us using the “Contact Us” form or email info@sos-action.com to request access to, correct or delete any personal information that you have provided to us. We cannot delete your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

Where We Store and Process Your Information

Given the global nature of our business and the centralization of certain business activities within the Sustainable Office Solutions Ltd. and Sustainable Office Solutions Pte Ltd. affiliates, personal information may be stored and processed internally for the lawful purposes described in this policy at different group levels (e.g., global, regional, and local) where Company or its affiliates, subsidiaries or service providers maintain operations, and where necessary to provide services or to manage our business. We recognize that the EU/EEA countries have certain data protection laws, including the EU General Data Protection Regulation (GDPR) and the corresponding implementing national laws (collectively, the “EU Data Protection Laws”) that generally restrict the transfer of personal information about individuals in the EU to the United States and certain other countries, unless there is “adequate protection” for such information when it is received. To address this restriction and equal restrictions in other countries or regions, we apply a consistent set of rules to all transfers of personal information amongst Sustainable Office Solutions Ltd. and Sustainable Office Solutions Pte Ltd. affiliates regardless of their location whether within or outside of the EU/EEA countries. To provide adequate protection for transfers of personal information, Company along with its affiliates, subsidiaries or service providers enter into the Standard Contractual Clauses for the Transfer of Personal Data to Third Countries (“Model Contract”) pursuant to European Commission Decision 2004/915/EC of 27 December 2004.

Data Security

In accordance with applicable law, we maintain appropriate technical and organizational security measures designed to protect your personal information from accidental loss or destruction and from unauthorized access, misuse, alteration and disclosure, wherever it is stored or processed, including when personal information is transmitted over a private network or stored in cloud environments.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.

Changes to Our Privacy Policy

It is our policy to post any changes we make to our privacy policy on this page. If we make material changes to how we treat our users’ personal information, we will notify you by e-mail to the e-mail address specified in your account, and/or through a notice on the Website home page. The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable e-mail address for you, and for periodically visiting our Website and this privacy policy to check for any changes.

Contact Information

To ask questions about this privacy policy or raise concerns about our privacy practices, please contact us by using our “Contact Us” form, or email info@sos-action.com. We will respond to questions or concerns within 30 days.