With this Privacy Notice we, Circleg AG (hereinafter Circleg, we or us), describe how we collect and further process personal data. This Privacy Notice is not necessarily a comprehensive description of our data processing. It is possible that General Terms and Conditions, consent forms or similar documents are applicable to specific
circumstances.

The term "personal data" in this Privacy Notice shall mean any information that identifies or could reasonably be used to identify any natural person.

If you provide us with personal data of other persons (such as family members, work colleagues), please make sure the respective persons are aware of this Privacy Notice and only provide us with their data if you are allowed to do so and such personal data is correct.

This Privacy Notice is aligned with the Swiss Federal Act on Data Protection («FADP») and the EU General Data Protection Regulation («GDPR»). However, the application of these laws depends on each individual case.

1. Controller

The "controller" of data processing as described in this Privacy Notice (i.e. the responsible person) is:
Circleg AG
Rautistrasse 30
8047 Zürich
Switzerland
hello@circleg.world

Our representative in the EEA according to art. 27 GDPR is:
Heartful Operations d.o.o.
Motovunska 22
10000 Zagreb
Croatia
heartful.operations@google.com

2. Collection and Processing of Personal Data

We primarily process personal data that we obtain from our customers (or their employees) and other business partners as well as other individuals in the context of our business relationships with them, from our employees (including former, temporary and future, and also externals working on site), applicants and other interested parties or that we collect from users when operating our websites and applications/software.

Insofar as it is permitted to us, we obtain certain personal data from publicly accessible sources, from authorities or other third parties (such as e.g., credit rating agencies, list brokers). The categories of data we receive about you from third parties include, but are not limited to:

• data you provided to one of our partners in order to receive our products such as prosthetists, this includes general contact details (such as name, gender, language, address, phone number, e-mail address), financial data (such as income), anthropometric data (such as weight, height, foot size, age), health data (such as amputation side, amputation type, reason for amputation, personal story; related questionnaire concerning aspects of quality of life, health status, physical pain, medical treatment, happiness, view on life, energy levels, acceptance of bodily appearance, mobility, ability to get around and perform activities, capacity for work, satisfaction levels, feelings etc.);
• information from public registers (e.g., debt registers, land registries, commercial registers, press, internet);
• data received in connection with administrative or court proceedings;
• information in connection with your professional role and activities (e.g., in order to conclude and carry out contracts with your employer);
• information about you in correspondence and discussions with third parties;
• credit rating information (if we conduct business activities with you personally);
• information about you given to us by individuals associated with you (family, consultants, legal representatives, etc.) in order to conclude or process contracts with you or with your involvement (e.g. references, your delivery-address, powers of attorney);
• information regarding legal regulations such as anti-money laundering and export restrictions;
• bank details, information regarding insurances, our distributors and other business partners for the purpose of ordering or delivering services to you or by you (e.g., payments made, previous purchases);
• information about you found in the media or internet (insofar as indicated in the specific case, e.g. in connection with job applications, media reviews, marketing/sales, etc.);
• your address and any interests and other socio-demographic data (for marketing purposes);
• data in connection with your use of our websites (e.g., IP address, MAC address of your smartphone or computers, information regarding your device and settings, cookies, date and time of your visit, sites and content retrieved, applications used, referring website, localization data).

3. Purpose of Data Processing and Legal Grounds

We primarily use collected data in order to conclude and process contracts with our customers and business partners, in particular in connection with the development, production and distribution of medical and non-medical products as well as the procurement of products and services from our suppliers and subcontractors.

You may be affected by our data processing in your capacity as an employee of such a customer or business partner.

In addition, in line with applicable law and where appropriate, we may process your personal data and personal data of third parties in order to comply with our domestic and foreign legal obligations and for the following purposes, which are in our (or, as the case may be, any third parties') legitimate interest, such as:

• communication and processing of requests (e.g., employees, customers, interested parties, media inquiries, etc.; if you contact us via WhatsApp, communication with you will take place on this channel – please note that your phone number will be stored in our address book for recognition purposes and will be transmitted to WhatsApp, see WhatsApp's privacy policy);
• customer relationship management (e.g. communication with customers, customer contracts);
• finance and accounting, audit;
• an employee’s suitability for the job (recruiting, e.g. clarifications in connection with job applications, job interviews, contract negotiations);
• the performance of the employment contract (human resources administration, e.g. salary, bonus, vacations and expenses, insurance, taxes; IT administration, e.g. device management);
• providing and developing our products, services and websites, applications/software and other platforms, on which we are active;
• review and optimization of procedures regarding needs assessment for the purpose of direct customer approach as well as obtaining personal data from publicly accessible sources for customer acquisition;
• advertisement and marketing (including organizing events, newsletters), provided that you have not objected to the use of your data for this purpose (if you are part of our customer base and you receive our advertisement, you may object at any time);
• market and opinion research, media surveillance;
• asserting legal claims and defense in legal disputes and official proceedings;
• prevention and investigation of criminal offences and other misconduct (e.g. conducting internal investigations, data analysis to combat fraud);
• ensuring our operation and observation (application performance monitoring), including our IT, our websites, applications/software and other appliances;
• other measures to ensure the safety of our premises and facilities as well as protection of our employees and other individuals and assets owned by or entrusted to us (such as e.g. access controls, visitor logs, network and mail scanners);
• acquisition and sale of business divisions, companies or parts of companies and other corporate transactions and the transfer of personal data related thereto as well as measures for business management and compliance with legal and regulatory obligations as well as internal regulations of ours. If you have given us your consent to process your personal data for certain purposes (for example when registering to receive newsletters), we will process your personal data within the scope of and based on this consent, unless we have another legal basis, provided that we require one. Consent given can be withdrawn at any time, but this does not affect data processed prior to withdrawal.

4. Cookies / Tracking

When you visit our website, our servers may automatically log the standard data provided by your web browser. It may include your device’s Internet Protocol (IP) address, your browser type and version, the pages you visit, the time and date of your visit, the time spent on each page, and other details about your visit. Please be aware that while this information may not be personally identifying by itself, it may be possible to use it in the event of attacks on our IT infrastructure or other possibly unauthorized or abusive use of our website and applications/software for the purpose of clarification and defense and, if necessary, in the context of criminal proceedings for identification and for civil and criminal proceedings against the persons.

We typically use "cookies" on our websites and applications/software, which allow for an identification of your browser or device. A cookie is a small text file that is sent to your computer and automatically saved by the web browser on your computer or mobile device, when you visit our website or install our applications/software. If you revisit our website or use our applications/software, we may recognize you, even if we do not know your identity. Besides cookies that are only used during a session and deleted after your visit of the website ("session cookies"), we may use cookies in order to save user  configurations and other information for a certain time period (e.g., two years) ("permanent cookies").

Notwithstanding the foregoing, you may configure your browser settings in a way that it rejects cookies, only saves them for one session or deletes them prematurely. Most browsers are preset to accept cookies. We use permanent cookies for the purpose of saving user configuration (e.g., language, automated log in), in order to understand how you use our services and content. Certain cookies are sent to you from us, others from business partners with which we collaborate. If you block cookies, it is possible that certain functions (such as, e.g., language settings) are no longer available to you.

We currently use the following service providers and advertising partners:

• Nine.ch: Several functions on our website are provided by nine.ch who is hosting our website. This includes the consent management platform (CMP) and basket functions for which we place functional cookies. For the CMP, we use a comply_cookie to remember your interaction with the cookie banner. For retaining items in the basket, we use a PHPSESSID cookie which will be deleted when the browser is closed. We have concluded a data processing agreement with nine.ch (see https://docs.nine.ch/de/docs/legal-documents/data-processing-agreement);
• Google Analytics: We use Google Analytics from Google Ireland Limited which relies on Google LLC (located in the United States) as its sub-processor (both «Google»). Google collects information about the behavior of visitors to our website (duration, page views, geographic region of access, etc.) through performance cookies (see above) and on this basis creates reports for us about the use of our website. We have configured the service so that the IP addresses of visitors are truncated by Google in Europe before forwarding them to the United States and then cannot be traced back. We have turned off the «Data sharing» option and the «Signals option». Although we can assume that the information we share with Google is not personal data for Google, it may be possible that Google may be able to draw conclusions about the identity of visitors based on the data collected, create personal profiles and link this data with the Google accounts of these individuals for its own purposes. In any event, if you consent to the use of Google Analytics, you expressly consent to any such processing, including the transfer of your personal data (in particular website and app usage, device information and unique IDs) to the United States and other countries. Information about data protection with Google Analytics can be found here. If you have a Google account, you can find more details about Google's processing here.
• Google Tag Manager: We use Google Tag Manager from Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (“Google”) on our website. Google Tag Manager is a solution that allows marketers to manage website tags via an interface. If deactivation has been carried out at the domain or cookie level, it remains in effect for all tracking tags implemented with Google Tag Manager. You can prevent tags from being set at any time. For more information about how Google collects and uses your data through Google Tag Manager, please refer to their privacy policy.

In accordance with applicable law, we may include visible and invisible image files in our newsletters and other marketing e-mails. If such image files are retrieved from our servers, we can determine whether and when you have opened the e-mail, so that we can measure and better understand how you use our offers and customize them. You may disable this in your e-mail program, which will usually be a default setting.

5. Social Networks

We may operate pages and other online presences («fan pages», «channels», «profiles», etc.) on social networks and other platforms operated by third parties and collect the data about you. We receive this data from you and from the platforms when you interact with us through our online presence (for example when you communicate with us, comment on our content or visit our online presence). At the same time, the platforms analyze your use of our online presences and combine this data with other data they have about you (for example about your behavior and preferences). They also process this data for their own purposes, in particular for marketing and market research purposes (for example to personalize advertising) and to manage their platforms (for example what content they show you) and, to that end, they act as separate controllers.

We process this data for the purposes set out in Section 3, in particular for communication, for marketing purposes (including advertising on these platforms) and for market research. We may disseminate content published by you (for example comments on an announcement), for example as part of our advertising on the platform or elsewhere. We or the operators of the platforms may also delete or restrict content from or about you in accordance with their terms of use (for example inappropriate comments).

For further information on the processing of the platform operators, please refer to the privacy information of the relevant platforms. There you can also find out about the countries where they process your data, your rights of access and erasure of data and other data subjects rights and how you can exercise them or obtain further information. We currently use the following platforms:

• We have a profile on LinkedIn. The provider is LinkedIn Ireland Unlimited Company, Dublin, Ireland. You can find more information on the data protection in their data protection declaration. Some of your data may be transferred to the US. The processing of LinkedIn can be objected to here. Further settings can be made via the objection form. In connection with the operation of our LinkedIn profile, we use LinkedIn Page Analytics. We thus receive information about the use of our content. It helps us understand how our page is used and how to improve it. We have agreed our data protection responsibilities according to the joint controller addendum.
• We operate the page on Facebook. The controller for the operation of the platform for users from Europe is Meta Platforms Ireland Ltd., Dublin, Ireland. Their privacy policy is available here. Some of your data may be transferred to the US. Objection to advertising is possible here. We are jointly responsible with Meta Platforms Ireland Ltd., Dublin, Ireland, for the data collected and processed when you visit our site for the creation of “Page Insights”. We have organized our responsibilities with regard to data protection as described in the page controller addendum. Page Insights is used to compile statistics about what visitors do on our site (comment on posts, share content, etc.) as described here. It helps us understand how our site is used and how we can improve it. We only receive anonymous, aggregated data.
• We have two profiles on Instagram: circleg.world and circleg.latam. The provider is Instagram Inc., Menlo Park, USA, which belongs to the Meta group (Facebook). Their privacy policy is available here. Some of your data may be transferred to the US. Objection to advertising is possible here. In connection with the operation of our Instagram profile, we use the Instagram Insights function to obtain statistical evaluations of the users of our posts. Information on Instagram Insights can be found in the privacy policy as well as here.
• We use YouTube to post our own videos and make them publicly accessible on our channel. The provider is Google LLC, USA. The privacy policy is available here. Some of your data may be transferred to the US. Objection to advertising is possible here. Further information about how to adjust your privacy settings can be found here. We use the YouTube analytics functions in connection with operating our YouTube account. The analytics functionality allows us to analyze use and create a statistical evaluation. Further information can be found here.
• We operate a profile on TikTok. The provider is TikTok Technology Limited, Dublin, Ireland. You can find their privacy policy here. Some of your data may be transferred to the US, Singapore, China or other third countries. You can object to the processing of personal data here. In connection with operating our TikTok profile, we use TikTok Analytics. This provides us with aggregated information about the use of our content (e.g. views, likes, shared content, comments). It helps us understand how our channel is used and how to improve it. We are jointly responsible with TikTok for the data processed in connection with TikTok Analytics. We have organized our data protection responsibilities as described in the joint controller addendum. Further information on TikTok Analytics is available here.

6. Data Transfers

In the context of our business activities and in line with the purposes of the data processing set out in Section 3, we may transfer data to third parties, insofar as such a transfer is permitted and we deem it appropriate, in order for them to process data for us or, as the case may be, their own purposes. In particular, the following categories of recipients may be concerned:

• our service providers (externally, such as e.g. banks, insurances, fiduciaries), including processors (such as e.g. IT providers, cloud storage service providers, newsletter providers, CRM software);
• dealers, distributors, suppliers, subcontractors and other business partners;
• customers;
• domestic and foreign authorities or courts;
• the media;
• the public, including users of our websites and social media;
• competitors, industry organizations, associations, organizations and other bodies;
• acquirers or parties interested in the acquisition of business divisions, companies;
• other parties in possible or pending legal proceedings;
• affiliates of the Circleg group.

together Recipients.

7. Transfer of Data Abroad

Certain Recipients may be within Switzerland but they may be located in any country worldwide, including Kenya where our affiliate is located or Brazil, Argentina, Chile, Sri Lanka and Bulgaria where some of our distributors or customers are based. Moreover, you must anticipate your data to be transmitted to other countries in Europe, the European Economic Area (EEA) and the USA where some our service providers are located. Some of our service providers use sub-processors that can be located in any country worldwide.

If a recipient is located in a country without adequate statutory data protection, we require the recipient to undertake to comply with data protection (for this purpose, we use the revised European Commission’s standard contractual clauses, which can be accessed here), unless the recipient is subject to a legally accepted set of rules to ensure data protection and unless we cannot rely on an exception. An exception may apply for example in case of legal proceedings abroad, but also in cases of overriding public interest or if the performance of a contract requires disclosure, if you have consented or if data has been made available generally by you and you have not objected against the processing.

8. Retention Periods for your Personal Data

We process and retain your personal data as long as required for the performance of our contractual obligation and compliance with legal obligations or other purposes pursued with the processing, i.e. for the duration of the entire business relationship (from the initiation, during the performance of the contract until it is terminated) as well as beyond this duration in accordance with legal retention and documentation obligations. Personal data may be retained for the period during which claims can be asserted against our company or insofar as we are otherwise legally obliged to do so or if legitimate business interests require further retention (e.g., for evidence and documentation purposes). As soon as your personal data are no longer required for the above-mentioned purposes, they will be deleted or anonymized, to the extent possible.

9. Data Security

We take appropriate security measures in order to maintain the required security of your personal data and ensure its confidentiality, integrity and availability, and to protect it against unauthorized or unlawful processing, and to mitigate the risk of loss, accidental alteration, unauthorized disclosure or access.

10. Obligation to Provide Personal Data to Us

In the context of our business relationship you must provide us with any persona data that is necessary for the conclusion and performance of a business relationship and the performance of our contractual obligations (as a rule, there is no statutory requirement to provide us with data). Without this information, we will usually not be able to enter into or carry out a contract with you (or the entity or person you represent). In addition, the website cannot be used unless certain information is
disclosed to enable data traffic (e.g. IP address).

11. Profiling and Automated Individual Decision-Making

We may partially process your personal data automatically with the aim of evaluating certain personal aspects (profiling). In particular, profiling allows us to inform and advise you about products possibly relevant for you more accurately. For this purpose, we may use evaluation tools that enable us to communicate with you and advertise you as required, including market and opinion research. In establishing and carrying out a business relationship, we generally do not use any fully automated individual decision-making. Should we use such procedures in certain cases, we will inform you separately on this and advise you of your relevant rights if required by law.

12. Your Rights

In accordance with and as far as provided by applicable law, you have the right to

• access;
• rectification;
• erasure of your personal data;
• restriction of processing;
• object to our data processing;
• withdraw consent;
• receive certain personal data for transfer to another controller (data portability).

Please note, however, that we reserve the right to enforce statutory restrictions on our part, for example if we are obliged to retain or process certain data, have an overriding interest (insofar as we may invoke such interests) or need the data for asserting claims. If exercising certain rights will incur costs on you, we will notify you thereof in advance. Please further note that the exercise of these rights may be in conflict with your contractual obligations and this may result in consequences such as premature contract termination or involve costs. If this is the case, we will inform you in advance unless it has already been contractually agreed upon. In general, exercising these rights requires that you are able to prove your identity (e.g., by a copy of identification documents where your identity is not evident otherwise or can be verified in another way). In order to assert these rights, please contact us at the addresses provided in Section 1 above.

In addition, every data subject has the right to enforce his/her rights in court or to lodge a complaint with the competent data protection authority. The competent data protection authority of Switzerland is the Federal Data Protection and Information Commissioner. You can find a list of authorities in the EEA here.

13. Amendments of this Privacy Notice

We may amend this Privacy Notice at any time without prior notice. The current version published on our website shall apply.

Version effective as of June 2025