Jurídico Elo

Data Privacy Framework Program (DPF) Privacy Policy

Elo Touch Solutions, Inc. (“Elo”) complies with the EU-US Data Privacy Framework (“EU-US DPF”), the UK Extension to the EU-US DPF, and the Swiss-US Data Privacy Framework (“Swiss-US DPF”) as set forth by the US Department of Commerce (collectively, the “Data Privacy Framework”). Elo has self-certified to the US Department of Commerce that it adheres to the EU-US Data Privacy Framework Principles (“EU-US DPF Principles”) with regard to the processing of personal data received from the European Economic Area (“EEA”) in reliance on the EU-US DPF and from the United Kingdom in reliance on the UK Extension to the EU-US DPF. Elo has certified to the US Department of Commerce that it adheres to the Swiss-US Data Privacy Framework Principles (“Swiss-US DPF Principles”) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-US DPF. If there is any conflict between the terms in this privacy policy and the EU-US DPF Principles and/or the Swiss-US DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program and to view our certification, please visit https://www.dataprivacyframework.gov/.

This DPF Privacy Policy ("Policy") describes how Elo ("Company," "we," or "us") collects, uses, and discloses certain personally identifiable information that we receive in the United States (“US”) from the EEA, and the United Kingdom ("UK"), and Switzerland ("Personal Data"). This Policy supplements our Website Privacy Policy located at https://www.elotouch.com/privacy-policy, and unless specifically defined in this Policy, the terms in this Policy have the same meaning as the Website Privacy Policy.

Elo recognizes that the EEA, and the UK, and Switzerland have established strict protections regarding the handling of Personal Data, including requirements to provide adequate protection for Personal Data transferred outside of the EEA, the UK, and Switzerland. To provide adequate protection for certain Personal Data about consumers, corporate customers, clients, suppliers, business partners, job applicants, and employees received in the US from the EEA, and the UK, and Switzerland, Elo has elected to self-certify to the EU-US DPF, and UK Extension to the EU-US Data Privacy Framework, and Swiss-US Data Privacy Framework Swiss-US DPF administered by the US Department of Commerce ("DPF Program"). Elo adheres to the DPF Program Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement, and Liability and the Supplementary Principles.

For purposes of enforcing compliance with the DPF Program, Elo is subject to the investigatory and enforcement authority of the US Federal Trade Commission, or any other statutory body empowered to enforce compliance with the Data Privacy Framework. For more information about the DPF Program, see the US Department of Commerce's DPF website: https://www.dataprivacyframework.gov/. To review Elo's representation on the DPF list, see the DPF self-certification list, which is located at: https://www.dataprivacyframework.gov/list.

Your Rights

Under the DPF, you have rights in relation to your Personal Data. These include:

• Information on the types of Personal Data collected.
• Information on the purposes of collection and use.
• Information on the type or identity of third parties to which your personal data is disclosed.
• Choices for limiting use and disclosure of your Personal Data.
• Access to your personal data.
• Notification of the organization's liability if it transfers your Personal Data.
• Notification of the requirement to disclose your Personal Data in response to lawful requests by public authorities.
• Reasonable and appropriate security for your Personal Data.
• A response to your complaint within 45 days.
• Cost-free independent dispute resolution to address your data protection concerns.
• The ability to invoke binding arbitration to address any complaint that the organization has violated its obligations under the DPF Principles to you and that has not been resolved by other means.

You can also verify our self-certification to the DPF and check the information we have provided by viewing our details on the DPF list.

Personal Data Collection and Use

Our Website Privacy Policy located at https://www.elotouch.com/privacy-policy describes the categories of Personal Data that we may receive in the US as well as the purposes for which we use that Personal Data. Elo will only process Personal Data in ways that are compatible with the purpose that Elo collected it for, or for purposes the individual later authorizes. Before we use your Personal Data for a purpose that is materially different than the purpose we collected it for or that you later authorized, we will provide you with the opportunity to opt out. Elo maintains reasonable procedures to help ensure that Personal Data is reliable for its intended use, accurate, complete, and current.

Data Transfers to Third Parties

Third-Party Agents or Service Providers. We may transfer Personal Data to our third-party agents or service providers who perform functions on our behalf as described in our Website Privacy Policy. Where required by the DPF, we enter into written agreements with those third-party agents and service providers requiring them to provide the same level of protection the DPF requires and limiting their use of the data to the specified services provided on our behalf. We take reasonable and appropriate steps to ensure that third-party agents and service providers process Personal Data in accordance with our DPF obligations and to stop and remediate any unauthorized processing. Under certain circumstances, we may remain liable for the acts of our third-party agents or service providers who perform services on our behalf for their handling of Personal Data that we transfer to them.

Third-Party Data Controllers. In some cases, we may transfer Personal Data to unaffiliated third-party data controllers. These third parties do not act as agents or service providers and are not performing functions on our behalf. We may transfer your Personal Data to third-party data controllers for the purposes described in our Website Privacy Policy. We will only provide your Personal Data to third-party data controllers where you have not opted-out of such disclosures, or in the case of sensitive Personal Data, where you have opted-in if the DPF requires consent. We enter into written contracts with any unaffiliated third-party data controllers requiring them to provide the same level of protection for Personal Data the DPF requires. We also limit their use of your Personal Data so that it is consistent with any consent you have provided and with the notices you have received. If we transfer your Personal Data to one of our affiliated entities within our corporate group, we will take steps to ensure that your Personal Data is protected with the same level of protection the DPF requires.

Disclosures for National Security or Law Enforcement. Under certain circumstances, we may be required to disclose your Personal Data in response to valid requests by public authorities, including to meet national security or law enforcement requirements. We will only do so in accordance with the DPF Principles.

Security

Elo maintains reasonable and appropriate security measures to protect Personal Data from loss, misuse, unauthorized access, disclosure, alteration, or destruction in accordance with the DPF.

Access Rights

You may have the right to access the Personal Data that we hold about you and to request that we correct, amend, or delete it if it is inaccurate or processed in violation of the DPF. These access rights may not apply in some cases, including where providing access is unreasonably burdensome or expensive under the circumstances or where it would violate the rights of someone other than the individual requesting access. If you would like to request access to, correction, amendment, or deletion of your Personal Data, you can submit a written request to the contact information provided below. We may request specific information from you to confirm your identity. In some circumstances, we may charge a reasonable fee for access to your information.

Questions or Complaints

In compliance with the EU-US DPF, and the UK Extension to the EU-US DPF, and the Swiss-US DPF, Elo commits to resolve DPF Principles-related complaints about our collection and use of your personal information. EEA, and UK, and Swiss individuals with inquiries or complaints regarding our handling of personal data received in reliance on the EU-US DPF, and the UK Extension to the EU-US DPF, and the Swiss-US DPF should first contact Elo at: EloDPO@elotouch.com

In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, Elo commits to refer unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF to JAMS, an alternative dispute resolution provider based in the United States. If you do not receive timely acknowledgment of your DPF Principles-related complaint from us, or if we have not addressed your DPF Principles-related complaint to your satisfaction, please visit https://www.jamsadr.com/DPF-Dispute-Resolution for more information or to file a complaint. The services of JAMS are provided at no cost to you.

If you have any questions about this Policy or would like to request access to your Personal Data, please contact us as follows: EloDPO@elotouch.com.

Changes to This Policy

We reserve the right to amend this Policy from time to time consistent with the DPF's requirements.

Effective Date: September 04, 2025