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PONIETECH INDUSTRIES, LLC

PonieTech Industries, LLC & Looking Glass Robotics, LLC

Privacy Policy

How We Collect, Use, and Protect Your Information

Effective Date: March 16, 2026

Version: 1.0

1.  Introduction and Scope

PonieTech Industries, LLC and its subsidiary Looking Glass Robotics, LLC (collectively, "PonieTech," "we," "us," or "our") are committed to protecting the privacy of individuals who visit our websites, interact with our products and services, or otherwise engage with us. This Privacy Policy explains how we collect, use, disclose, and protect personal information.

This Privacy Policy applies to: our websites located at www.ponietech.com and any subdomains thereof; our products and services, including any beta or pilot programs; our mobile applications, if any; communications we send to you by email, phone, or other means; and any other interaction you have with PonieTech or Looking Glass Robotics, LLC.

By using our websites or services, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with the terms of this Privacy Policy, please do not use our websites or services.

2.  Information We Collect

2.1  Information you provide directly

We collect information you provide to us when you:

•       Contact us through our website contact forms, email, or phone (name, email address, phone number, company name, message content);

•       Request information about our products or services, including investor inquiries, partnership inquiries, or press inquiries;

•       Sign up for newsletters, updates, or announcements;

•       Apply for employment or contractor positions;

•       Participate in surveys, research programs, or beta testing;

•       Execute agreements with us, including NDAs, partnership agreements, or service contracts.

2.2  Information collected automatically

When you visit our websites, we may automatically collect:

•       Log data: IP address, browser type and version, operating system, referring URLs, pages visited, time and date of visits, and time spent on pages;

•       Device information: device type, unique device identifiers, and mobile network information;

•       Cookies and similar tracking technologies: see Section 6 (Cookies) for more detail;

•       Usage data: how you interact with our websites and communications, including links clicked and features used.

2.3  Information from third parties

We may receive information about you from third parties, including:

•       Business partners and referral sources who refer you to our services;

•       Publicly available sources, such as company websites and professional networks, when we research potential business relationships;

•       Analytics providers and advertising partners who help us understand how our websites are used.

2.4  Sensitive information

Our websites and services are not designed to collect sensitive personal information such as health or medical information, financial account numbers, government identification numbers, or biometric data. Please do not submit such information through our general contact forms or website. If you are participating in a clinical research or pilot program that involves collection of biometric or health data, separate consent and data handling procedures will apply and will be communicated to you in writing before any data collection begins.

3.  How We Use Your Information

We use the information we collect for the following purposes:

3.1  Operating and improving our business

•       Responding to your inquiries and requests;

•       Communicating with you about our products, services, and company developments;

•       Processing partnership, investor, or employment inquiries;

•       Administering agreements and legal obligations;

•       Improving our websites, products, and services based on usage patterns and feedback.

3.2  Legal and compliance

•       Complying with applicable laws, regulations, and legal processes;

•       Enforcing our terms, agreements, and policies;

•       Protecting the rights, property, and safety of PonieTech, our users, and others;

•       Detecting and preventing fraud, security incidents, and other harmful activities.

3.3  Communications

•       Sending you newsletters, updates, and announcements about our company and products, where you have opted in or where we have a legitimate interest;

•       Sending administrative communications related to agreements, services, or legal obligations;

•       Responding to press and media inquiries.

3.4  Analytics and research

•       Analyzing how our websites and services are used to improve user experience;

•       Conducting internal research and development activities;

•       Generating anonymized and aggregated data and statistics.

4.  How We Share Your Information

We do not sell your personal information. We may share your information in the following limited circumstances:

4.1  Service providers

We may share information with third-party service providers who assist us in operating our business, such as website hosting providers, email service providers, analytics providers, legal counsel, and accounting firms. These providers are authorized to use your information only as necessary to provide services to us and are bound by confidentiality obligations.

4.2  Business transactions

If PonieTech or any of its subsidiaries is involved in a merger, acquisition, financing, reorganization, bankruptcy, or sale of assets, your information may be transferred as part of that transaction. We will notify you by email or prominent notice on our website of any change in ownership or use of your information.

4.3  Legal requirements

We may disclose your information if required to do so by law, regulation, court order, or governmental authority, or if we believe in good faith that such disclosure is necessary to comply with applicable law, protect the rights or property of PonieTech, prevent fraud or illegal activity, or protect the safety of individuals.

4.4  With your consent

We may share your information in other circumstances with your explicit prior consent.

5.  Data Retention

We retain personal information for as long as necessary to fulfill the purposes for which it was collected, comply with legal obligations, resolve disputes, and enforce agreements. When information is no longer needed, we will delete or anonymize it in accordance with our data retention policies.

Specifically: contact and inquiry information is retained for up to three (3) years from last contact; website analytics data is retained for up to two (2) years; agreement-related information is retained for the duration of the agreement plus seven (7) years; employment application data is retained for one (1) year if no offer is made.

6.  Cookies and Tracking Technologies

Our websites may use cookies, web beacons, pixels, and similar tracking technologies to enhance your experience and gather information about how our websites are used. Cookies are small text files stored on your device when you visit a website.

Types of cookies we use

•       Essential cookies: Required for the website to function properly. These cannot be disabled.

•       Analytics cookies: Help us understand how visitors interact with our website, including which pages are most popular and how users navigate the site. We use this information to improve our website.

•       Preference cookies: Remember your settings and preferences to enhance your experience on future visits.

You can control cookies through your browser settings. Disabling cookies may affect the functionality of our websites. We will request your consent for non-essential cookies where required by applicable law.

7.  Your Rights and Choices

Depending on your location, you may have certain rights regarding your personal information:

•       Access: Request a copy of the personal information we hold about you;

•       Correction: Request correction of inaccurate or incomplete information;

•       Deletion: Request deletion of your personal information, subject to legal obligations;

•       Portability: Request a copy of your information in a portable format;

•       Opt-out of marketing: Unsubscribe from marketing communications at any time by clicking the unsubscribe link in any email or contacting us directly;

•       Object to processing: Object to our processing of your information where we rely on legitimate interests.

To exercise any of these rights, please contact us at privacy@ponietech.com. We will respond to your request within thirty (30) days. We may need to verify your identity before processing your request.

8.  Data Security

We implement reasonable administrative, technical, and physical safeguards to protect your personal information against unauthorized access, loss, misuse, and alteration. These measures include: access controls limiting access to personal information to authorized personnel; encryption of data in transit using industry-standard protocols; regular security assessments; and contractual security obligations imposed on service providers who handle personal data on our behalf.

No method of transmission over the internet or electronic storage is completely secure. While we strive to protect your information, we cannot guarantee absolute security. In the event of a data breach that is likely to result in a risk to your rights and freedoms, we will notify you as required by applicable law.

9.  International Data Transfers

PonieTech is based in the United States. If you are located outside the United States, please be aware that your information may be transferred to, stored, and processed in the United States, where data protection laws may differ from those in your country. By using our websites or services, you consent to such transfer. Where required by law, we will implement appropriate safeguards for international transfers of personal data.

10.  Children's Privacy

Our websites and services are not directed to children under the age of 13 (or 16 in certain jurisdictions). We do not knowingly collect personal information from children. If we become aware that we have collected personal information from a child without parental consent, we will take steps to delete that information promptly. If you believe we have inadvertently collected information from a child, please contact us immediately at privacy@ponietech.com.

11.  California Privacy Rights

If you are a California resident, you may have additional rights under the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA), including the right to know what personal information we collect, use, and share; the right to delete your personal information; the right to opt out of the sale or sharing of your personal information (we do not sell personal information); and the right to non-discrimination for exercising your privacy rights. To exercise these rights, contact us at privacy@ponietech.com.

12.  Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. We will post the updated Privacy Policy on our website with a new effective date. If we make material changes, we will provide notice by email (if we have your email address) or by prominent notice on our website at least thirty (30) days before the changes take effect. Your continued use of our websites or services after the effective date constitutes acceptance of the updated Privacy Policy.

13.  Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact us:

Company

PonieTech Industries, LLC

Email

privacy@ponietech.com

Website

www.ponietech.com/privacy