Personal Data Processing Policy for Video Surveillance

1. General Provisions

1.1. This Personal Data Processing Policy for Video Surveillance (the "Policy") has been developed in accordance with the Law of the Republic of Belarus No. 99-Z dated 7 May 2021 "On Personal Data Protection" (the "Personal Data Protection Law") and establishes the procedure for processing images of individuals (personal data subjects) captured by the video surveillance system operated by Rozum Robotics LLC (the "Company").

1.2.Data Controller (Company):

Rozum Robotics Limited Liability Company

Office 151, 4/5 Biryuzova Street,

220073 Minsk,

Republic of Belarus

Business Registration Number (UNP): 192948908

1.3. The Company conducts video surveillance without obtaining the consent of personal data subjects pursuant to Paragraph 20 of Article 6 of the Law of the Republic of Belarus No. 99-Z dated 7 May 2021 "On Personal Data Protection", as the processing is necessary for the performance of obligations and powers established by the legislation of the Republic of Belarus.

Video surveillance is carried out solely for the following purposes:

1.4. This Policy is a public document and is available on the Company's official website: www.rozum.com.

2. Camera Locations, Purposes and Operation of Video Surveillance

2.1. The Company operates an open (non-covert) video surveillance system on a continuous 24/7 basis using eleven (11) cameras monitoring the following areas:

• Manufacturing premises (metalworking workshop), 4 Biryuzova Street, Minsk (3 cameras) — occupational safety, monitoring of labour discipline, and monitoring of equipment operation.
• Inventory storage area, entrance/exit area, and manufacturing premises (metalworking workshop), 4 Biryuzova Street, Minsk (1 camera) — protection of Company property (access control), occupational safety, labour discipline monitoring, and equipment operation monitoring.
• Entrance/exit area equipped with the Access Control System (ACS), and manufacturing premises (metalworking workshop), 4 Biryuzova Street, Minsk (1 camera) — property protection (access control), occupational safety, and labour discipline monitoring.
• Manufacturing premises (metalworking workshop), 4/10 Biryuzova Street, Minsk (2 cameras) — occupational safety and equipment operation monitoring.
• Entrance/exit area equipped with the Access Control System (ACS), 4/10 Biryuzova Street, Minsk (1 camera) — property protection and access control.
• Manufacturing premises (assembly workshop), Room 5007, 5th Floor, 4/5 Biryuzova Street, Minsk (1 camera) — occupational safety and labour discipline monitoring.
• Areas adjacent to the server room and Company corridor, 5th Floor, 4/5 Biryuzova Street, Minsk (2 cameras) — protection of Company property, restriction of access to critical premises containing server and communication equipment, and prevention of unauthorized access.

2.2. The Company's video surveillance system is not used for:

• recording employees' actual working hours (working time is recorded using the Access Control System (ACS));
• biometric identification or unique identification of individuals appearing in video recordings, except where required during incident investigations;
• audio recording.

2.3. Video surveillance cameras are not installed in areas intended for employees' private use, including changing rooms, restrooms, or similar facilities.

The Company operates the video surveillance system independently and does not engage third parties for this purpose.

3. Notification

3.1.Employees, contractors and visitors are informed about the operation of the video surveillance system through clearly visible warning signs displaying a camera symbol together with explanatory text before entering areas monitored by surveillance cameras.

4. Storage of and Access to Video Recordings

4.1. Access to archived video recordings is restricted to specifically authorized Company employees designated by an order of the Company's Director.

4.2. Video recordings may be disclosed to third parties solely upon lawful requests from law enforcement authorities or courts in cases provided for by the legislation of the Republic of Belarus.

4.3. Video recordings are retained for 14 calendar days, after which they are automatically deleted through cyclic overwriting.

4.4. The retention period for a specific recording may be extended by decision of the Company's Director for the duration of an internal review or investigation where:

• there are indications of a disciplinary offence, violation of occupational safety requirements, administrative offence or criminal offence; or
• a personal data subject has submitted a request requiring examination of the relevant recording.

5. Rights of Personal Data Subjects and Procedure for Exercising Them

5.1.Any individual whose image has been captured by the Company's video surveillance system has the right to obtain information regarding the processing of their personal data and to access such data by viewing the relevant recording in the presence of an authorized Company representative, provided that doing so does not infringe the rights and legitimate interests of third parties. Copies of video recordings are not provided unless otherwise required by law.

5.2. To exercise these rights, the data subject shall submit a written request by post or an electronic document signed using a qualified electronic digital signature (EDS).

5.3. The request shall include:

• the applicant's full name;
• residential address;
• description of the request;
• handwritten signature or qualified electronic digital signature;
• the date, location and approximate time (within a one-hour period) during which the individual's image may have been recorded.

5.4. As the processing of personal data is carried out on the basis of applicable legislation (Section 1.3 of this Policy), the right to withdraw consent does not apply to the processing of personal data through the Company's video surveillance system.

6. Final Provisions

6.1. The Company implements appropriate legal, organizational and technical measures to protect personal data against unauthorized access, alteration, disclosure, destruction or any other unlawful processing.

Any amendments to this Policy shall be approved by an order of the Company's Director.