PRIVACY POLICY

[Last Updated: April 4th, 2026]

(1) Introduction and Scope of this Privacy Policy

This Privacy Policy ("Privacy Policy") describes how App Central Ltd ("Company", "we" or "our") collects, uses, and processes Personal Data (as defined below), including the required disclosures and information about the types of Personal Data collected, why we collect your Personal Data and the purposes for which we use it, how long we retain it, with whom we share it, what your applicable rights are regarding your Personal Data, and how you can exercise them.

This Privacy Policy applies to our data collection and privacy practices in connection with any individuals, including representatives of prospects and potential business partners, who access and use our website, available at: https://www.app-central.com/ (respectively, "website" and "user" or "you"), as well as in connection with communications with us and interactions with our digital campaigns promoting our website, services, and business operations.

Please note that this Privacy Policy applies only to your use of the website and related interactions with us and does not govern our data collection or privacy practices related to your use of our apps, products, and services - such use is governed by the applicable policies made available within our apps and services.

You acknowledge that you are not under any statutory obligation to provide us with Personal Data, and any Personal Data you provide is provided at your free will (and with your consent, where required under applicable data protection laws). However, if you do not provide us with certain Personal Data, we will not be able to fulfill certain purposes, for example, to communicate with you regarding any inquiries you submit - all as described under section 4 of this Privacy Policy, "the data sets collected, purposes of use and lawful basis", which details the purposes for which each Personal Data set is processed.

This Privacy Policy further includes or incorporates specific information required under applicable data protection laws for residents of certain jurisdictions, including but not limited to:

If you are located in the EEA or the UK, this Privacy Policy further details our lawful basis for processing Personal Data, information regarding cross-border data transfers, and your rights related to the Personal Data we process, as well as additional information we are required to disclose to you under the EU and UK General Data Protection Regulations (collectively, "GDPR").

If you are a California resident, please also review our CCPA Privacy Notice, available at: [LINK], which serves as a Notice at Collection as required under the California Consumer Privacy Act ("CCPA") and further details the categories of personal information collected and additional information regarding our privacy practices, including your rights under the CCPA and other California privacy laws.

(2) Privacy Policy Amendments

The Company reserves the right to amend this Privacy Policy from time to time, at the Company's sole discretion. The most recent version of this Privacy Policy will always be posted on our website, and the "Last Updated" heading reflects the date of the most recent amendments. We will provide notice to you if these changes are material and, where required by applicable law, we will obtain your consent. Any amendments to the Privacy Policy will become effective immediately unless we notify you otherwise. We recommend reviewing this Privacy Policy periodically.

(3) Data Controller, Contact Information and Data Protection Representative

App Central Ltd is the "data controller" of the Personal Data collected subject to this Privacy Policy (as such term is defined under applicable privacy and data protection legislation or equivalent term). This means that the Company is responsible for deciding how and for what purposes your Personal Data is processed, as well as enabling you to exercise your rights related to your Personal Data processed by the Company.

For any questions you may have related to our processing of your Personal Data and this Privacy Policy, please contact us at: dpo@app-central.com.

 

EU and UK Data Protection Representative

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We value your privacy and your rights as a data subject and have therefore, in accordance with the GDPR, appointed Prighter Group with its local partners as our data protection representative and EU or UK users' point of contact, as follows:

European Union – Prighter EU Rep GmbH, Schellinggasse 3/10, 1010 Vienna, Austria

United Kingdom – Prighter Ltd, 20 Mortlake High Street, London, SW14 8JN, United Kingdom

Prighter gives you an easy way to exercise your privacy-related rights (e.g. requests to access or erase personal data). If you want to contact us via our representative, Prighter, or make use of your data subject rights, please visit: https://app.prighter.com/portal/12771016667.

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(4) The Data Sets Collected, Purposes of Use and Lawful Basis

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Depending on your interaction with us and our website, we collect certain information that may be classified as Non-Personal Data or Personal Data, as follows:

"Non-Personal Data" means information that is non-identifiable and anonymous. We are not aware of the identity of the individual from whom such Non-Personal Data was collected, and we are not able to link this information to an individual using reasonable means. Non-Personal Data may include technical information such as the type of operating system and browser, type of device, and your actions on the website all when collected on an aggregate basis or otherwise not combined with any identifiers.

"Personal Data" means information that identifies an individual or may with reasonable effort identify an individual.

Below you will find details regarding the types of Personal Data we collect, how and for which purposes we use your Personal Data, and our lawful basis for processing Personal Data (subject to the GDPR, if applicable).

Please note that the actual processing operation for each purpose of use and lawful basis, as we detail below, may differ. Such processing operation usually includes a set of operations made by automated means, such as collection, storage, use, disclosure by transmission, erasure, or destruction, and is based on the same lawful basis as stipulated below. In addition, we may process certain Personal Data, based on our legitimate interests, to prevent potentially prohibited or illegal activities, fraud, misappropriation, infringements, identity thefts, and any other misuse of our website, to enforce our other policies, and to take precautions against legal liability.

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(I) Online Identifiers and Usage Data

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Types of Personal Data

When you access and otherwise interact with our website or digital campaigns, we collect online identifiers associated with your browser or device, such as Internet Protocol (IP) address, Cookie ID, user agent, and similar online identifiers (collectively "Online Identifiers").

Online Identifiers are further used to generate certain information, for example, IP address can be used to extract your approximate location (e.g., country).

Further, we collect information related to your actions or interactions with our website and digital campaigns, for example the time and date of the access or interaction, the duration, the URL of the website's page you have viewed, click stream, crash and error data, browser or settings of language preferences, and similar information. We may further use tools on our website which provide us with information and insights, such as the advertising campaign from which you have reached our website (collectively "Usage Data"). Where such Usage Data is associated with an Online Identifier it is processed by us as Personal Data.

Purposes of Processing

We collect and use Online Identifiers and Usage Data for the following purposes:

• To operate and enable the proper functionality of our website, including to secure our website and prevent fraud or other malicious conduct, to detect errors, for debugging and to resolve such technical issues.

• For internal analytic purposes and to enhance and improve our website and its content, as well as the way we offer it. For example, we use Online Identifiers and Usage Data to understand how users use our website or the most viewed content and pages.

• To advertise and promote our website, business operations and services. This includes to serve ads on third party's platforms across the web, as well as targeted ads (further depending on your browser and cookies setting and preferences) and to measure effectiveness of, and improve, our ads and marketing campaigns, for example, to track conversions (how many users reached our website or contacted us), build targeted audience and remarket our website and services.

Lawful Basis under the GDPR

Online Identifiers and Usage Data collected through cookies that are strictly necessary for the proper and basic operation of our website, including for strict security purposes, will be processed by us based on our legitimate interest.

Online Identifiers and Usage Data collected for analytics and marketing purposes through our use of third-party cookies, will be processed by us based on your consent which we will obtain through our cookies preference management tool available on our website.

You may withdraw consent at any time by using the cookies preference management tool, or by managing opt-out through your browser or device.

For additional information regarding our use of cookies and the choices you can make, please see Section 6 of this Privacy Policy "Our Use of Cookies and Tracking Technologies".

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(II) Contact Information and Contact Communications

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Types of Personal Data

If you contact us, either through online forms available on the website, chats (which might be operated by AI Agents) or through other means we make available through our website (such as sending us an email), or if you sign up to receive marketing communications from us, submit your apps or assets for our review to explore potential partnership, etc., you will be requested to provide us with your contact information, which, depending on your interaction with us, may include your name, telephone number, email address or business email address, your organization, profile or account on social media platforms, etc. In addition, we may use business intelligence tools and services to obtain potential business customers or partners representatives contact information as set forth above ("Contact Information").

We will further process and store the content of communications with you, and may also process data related to these communications, such as interactions with email correspondence (including access time and date), etc. (collectively "Contact Communications Data").

Please note that, if you communicate with us in connection with a job or a position we offer through the website, the Personal Data you will provide (including for example your resume/CV) will be processed in accordance with our candidates' privacy policy available at: [LINK] and governed by its terms.

Purposes of Processing

We collect and use Contact Information and Contact Communications Data for the following purposes:

• To respond to your inquiry or request, for example, send you the information you have requested, etc.

• For business prospects or partners, we may use your Contact Information for direct marketing purposes, meaning to send you marketing materials related to our business operation and services in which you have shown interest, such as new products, special opportunities etc., or otherwise, subject to applicable laws, to contact you and explore potential business opportunities and offer you information regarding our services that we think will be of interest to you or your organization.

• To enhance and improve our marketing efforts.

• To keep internal records of our communications where we believe it is required, for example, to comply with our obligations under applicable laws, to have internal records demonstrating our compliance, to provide you with any further assistance, to record and comply with a request to unsubscribe from marketing communications, or in the event of any potential, threatened, or actual claim or dispute.

Lawful Basis under the GDPR

Contact Information and Contact Communications Data processed by us to respond to your inquiry or requests, as well as, where processed to send you information and materials you have voluntarily signed up to receive, are processed based on your consent.

Contact Information and Contact Communications Data processed by us for direct marketing purposes are processed based on our legitimate interests.

Contact Information and Contact Communications Data processed by us to improve our marketing efforts and for internal records keeping are processed based on our legitimate interests.

You have the right to withdraw your consent at any time. You may further opt-out from our marketing communications by using the "unsubscribe" within the body of the message or other option we may make available.

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(5) How We Collect Personal Data

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Depending on the nature of your interaction with the website and with us, we collect Personal Data as follows:

• By using automated means – we may use cookies or similar technologies to gather some information automatically when you interact with our website or digital campaigns. For additional information regarding our use of cookies and the choices you can make, please see Section 6 of this Privacy Policy, "Our Use of Cookies and Tracking Technologies".

• When you voluntarily choose to provide us with information – such as when you contact us, as detailed in this Privacy Policy.

• Provided by third party service providers we engage with – such as business intelligence services and tools.

(6) Our Use of Cookies and Tracking Technologies

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We use "cookies" (or similar tracking technologies such as tags and pixels) on our website. The use of cookies is standard industry-wide practice. Cookies and similar technologies are small pieces of information, text, or code that a website assigns and stores on your browser while you access a website. Cookies can be used for various purposes, including for operation and security, to improve website functionality and remember preferences, for statistical purposes, as well as for advertising purposes.

The information generally collected and stored by cookies includes Online Identifiers and Usage Data (as defined in Section 4 of this Privacy Policy, "The Data Sets Collected, Purposes of Use and Lawful Basis").

The cookies and tracking technologies can be either placed by us (known as "first party cookies") or by third parties whose services we use, such as our marketing partners, social media, analytic providers, etc. (known as "third party cookies"). The duration of cookies and tracking technologies – meaning the period until such are deleted – can be either when you close your browser (known as "session cookies") or for longer periods according to their purpose and settings (known as "persistent cookies").

Third-party advertising providers whose cookies we may use, may independently collect additional data sets, including to combine Online Identifiers and Usage Data with other information they have independently collected relating to your online interactions across their network of websites, for the purpose of enhanced targeting campaigns and personalized ads, as well as providing aggregated analytics related to the performance of advertising campaigns you interacted with. These third parties collect and use this information under their own privacy policies and are responsible for their practices.

The cookies preference management tool available on our website lists and details the cookies we use on our website. You may change your cookies preference at any time, including, as applicable, withdraw consent or opt-out from the processing of Personal Data through cookies for certain purposes, by using the cookies preference management tool. Note that certain cookies used for strict operation and security purposes are considered "strictly necessary" and cannot be disabled.

In addition, most browsers will allow you to block the acceptance of cookies or erase cookies by adjusting the privacy and security settings of your web browser. Please refer to the support page of your browser to learn more.

Please note that once you choose to opt out or disable cookies, some features of our website may not operate properly.

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(7) Disclosure of Personal Data

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We may disclose your Personal Data to third parties, including our affiliated companies, partners or service providers that help us manage our website, business operations and marketing campaigns. The categories of such third-party recipients or otherwise events in which we may share Personal Data are as follows:

• Our service providers – we share Personal Data with our service providers to perform the requested functions and services on our behalf, for example, cloud providers, analytic tools, security tools, communication management, chats AI agents and similar tools' providers, professional advisors, etc. These providers are prohibited from using the Personal Data we share with them for any purpose other than providing us with the requested services and we only share with them the types of Personal Data that are needed for the provision of the applicable services they provide us with.

• Marketing partners – we may share Personal Data with marketing partners we engage with or use their tools and services to market and promote our website and business operation, including for targeted advertising campaigns, for example, social media operators. The Personal Data shared may include Online Identifiers and Usage Data (as defined in Section 4 of this Privacy Policy "The Data Sets Collected, Purposes of Use and Lawful Basis"). These marketing partners may combine your Personal Data with other data they collect independently from your visits and interactions on other websites where their tools are used or that they otherwise operate.

• Our affiliated companies and sharing in the event of corporate transactions – we may share Personal Data, internally within our company group to fulfil certain purposes for which Personal Data is collected and retained, and may further share Personal Data in the event of a corporate transaction (for example, sale of our assets or substantial part of our business, merger, consolidation, etc.). The types of Personal Data that will be shared can be any data processed by us, as needed. Our affiliated companies or acquiring company will assume the rights and obligations as described herein.

• Sharing with law enforcement or governmental authorities & to enforce our rights or for security and fraud prevention – we may disclose certain Personal Data to law enforcement, governmental agencies, or authorized third parties, to comply with applicable laws or in response to a verified request or order. We may further share Personal Data to defend our rights, enforce our agreements or policies, to investigate or prevent potential violations thereof or any alleged illegal activity or any other activity that may expose us, you, or other users to legal liability, however Personal Data will be shared solely to the extent required.

For the avoidance of doubt, we may transfer, disclose, or otherwise use Non-Personal Data, including information linked to anonymous random identifiers or aggregated in a non-identifiable way, at our sole discretion.

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(8) Your Rights Related to Your Personal Data

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Depending on your relationship with us, your jurisdiction and the data protection laws that apply to you, you have the right to control and request certain limitations or rights to be executed.

The principal rights that may apply to your Personal Data (subject to your jurisdiction and additional conditions) may include:

• Right to be informed – you have the right to be provided with information regarding our privacy practices, including the Personal Data we collect and how we use it – as we detailed under this Privacy Policy. If you have any additional questions, you can contact us as set forth under this Privacy Policy.

• Right to access/inspect your Personal Data – you have the right to ask us to confirm whether we collect and use your Personal Data and which Personal Data we specifically hold about you, and to ask for a copy of your Personal Data or otherwise access it.

• Right to correction/rectification – you have the right to ask us to correct inaccuracies or update your Personal Data we hold or request deletion for inaccurate Personal Data, considering and subject to the nature and purposes of the processing.

• Right to deletion/"to be forgotten" – you have the right to request the deletion of certain Personal Data we process, if specific conditions are satisfied, for example, if you think we no longer need it for the purpose we collected it; where we have used it unlawfully; where the collection was based on your consent; or where we are subject to a legal obligation to delete it. Deletion request will be subject to our rights and obligations under applicable law.

• Right to withdraw consent – when we collect and process your Personal Data based on your consent, you have the right to withdraw such consent at any time.

• Right to opt-out of "sale" – you have the right to opt-out from receiving our marketing communications, if applicable, by unsubscribing through the message received. You further have the right to opt out of the "sale" of Personal Data (i.e., to opt out of targeted advertising by us) as further explained under Section 9 of this Privacy Policy ""Sale" of Personal Data". We do not profile you in a manner that has a significant effect on you or other individuals, therefore we do not provide an opt-out option from such use of Personal Data.

• Right to object – you have the right to object to any use of your Personal Data which is based on our legitimate interest if you believe your fundamental rights and freedoms to data protection outweigh our legitimate interest.

• Right to restrict processing – you have the right to ask us to restrict or limit the purpose for which we process your Personal Data, where certain conditions are satisfied.

• Data portability right – you have the right to request to be provided with a copy of your Personal Data in a portable format and, to the extent technically feasible, readily usable format that allows you to transmit the Personal Data.

• Right to appeal or lodge a complaint – If we decline to take action on your request to exercise your rights, we will inform you within the timeframe set out under applicable law, and we will explain the justification for declining your request as well as how you may appeal, if applicable. Where applicable, we will inform you of action taken or not taken in response to your appeal, including the reasons for the decision. If the appeal is denied, you may submit a complaint to the applicable authority or Attorney General of your state.

Where the GDPR applies, you have the right to lodge a complaint with the applicable Data Protection Authority in the EU or the Information Commissioner in the UK.

You may submit a request to exercise most of your privacy rights under applicable privacy laws by contacting us at dpo@app-central.com, or, where applicable to you, through our EU or UK data protection representative as set forth under Section 3 of this Privacy Policy "Data Controller, Contact Information and Data Protection Representative".

We will respond and fulfill your request within the timeframe required under applicable laws.

When you submit a request, we will take steps to verify your identity and your request by matching the information provided by you with the information we have in our records. In some cases, we may request additional information to verify your identity, or where necessary to process your request. If we are unable to verify your identity after a good faith attempt, we may deny the request and, if so, will explain the basis for denial and how to remedy any deficiencies, where applicable.

Certain rights can be easily executed independently by you without the need to contact us, and for example, you can use the cookies preference management tool on our website to change your preferences and opt-out of cookies including opt-out of "sale" of Personal Data and you can opt-out from receiving our marketing messages by clicking "unsubscribe" link or follow other opt-out instructions.

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(9) "Sale" of Personal Data

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Under US privacy laws, the term "sale" refers to disclosing or making available Personal Data to a third party in exchange for monetary or other valuable consideration, including for targeted advertising purposes. We do not "sell" Personal Data as most people would commonly understand that term, i.e., we do not disclose your Personal Data in direct exchange for money or some other form of payment. However, subject to the definition of the term "sale" under such US privacy laws, our practice of sharing the categories of Personal Data detailed above, when we use cookies or other third-party advertising services, is considered as "selling" Personal Data. The categories of Personal Data shared for this purpose include: Online Identifiers such as IP and Cookie ID; Internet and electronic network activity information (Usage Data); Geolocation data (such as country level extracted from IP) (all terms as defined under Section 4 of this Privacy Policy "The Data Sets Collected, Purposes of Use and Lawful Basis"). You have the right to opt out of such "sale" at any time by changing your preference using the cookies preferences management tool available on our website.

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(10) Retention of Personal Data

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We retain the Personal Data for as long as it is needed for the purposes for which it was collected, in accordance with applicable laws, or, where applicable, until we receive an expressed preference to opt-out or delete Personal Data by an individual. There are other circumstances in which we will retain your Personal Data for longer periods, as follows: we are required to retain the Personal Data in accordance with legal, regulatory, tax, or accounting requirements; where we determine we need to retain records of your dealings with us in the event of any complaints or in the event we reasonably believe there is a prospect of litigation relating to your Personal Data.

Without derogating from the above, except where we are required to retain Personal Data under applicable law, we may at our sole discretion, delete or amend any data, without notice, once we deem it is no longer needed.

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(11) Data Security

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We have implemented physical, technical, and organizational security measures that comply with applicable laws and industry standards intended to protect Personal Data from unauthorized access, alteration, disclosure or destruction.

Note, however, that security incidents cannot always be prevented, and we will not be held responsible for unauthorized or unintended access beyond our control. We make no warranty, express, implied, or otherwise, that we will always be able to prevent such unauthorized access or use.

Please contact us at dpo@app-central.com if you become aware of any attempt to gain unauthorized access to your Personal Data.

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(12) Cross-Border Data Transfer

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We may transfer, store or process your Personal Data in countries outside the country from which you accessed our website or interacted with us. We will take appropriate measures in accordance with applicable laws to ensure that your Personal Data receives an adequate level of data protection upon its transfer.

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(13) Children

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Our website and services are not intended for use by children, and we do not knowingly collect or maintain information about children. Please contact us at dpo@app-central.com, if you have reason to believe that a child has shared any information with us.