Privacy Policy

1. Data Controller

The entity responsible for the collection, use, and protection of your personal data is:

TB NETWORKS, S.A.P.I. de C.V.Bosques de Ciruelos 180 PP, Bosques de las Lomas, Miguel Hidalgo, 11700, Mexico City, MexicoEmail: daniel@trebu.io

2. What Personal Data We Collect

Non-Sensitive Personal Data

We may collect the following categories of information:

• Contact information: Full name, phone number, email address, physical address.
• Identification data: Name, date of birth, gender.
• Financial information: Payment details such as bank account numbers, credit or debit card information (collected at the time of payment for Services).
• Employment data: Job type, role, tenure.
• Asset data: Information related to personal or family assets, including real estate and personal property, where applicable.
• Third-party data: Information about third parties that you provide to us in connection with the Services.

Sensitive Personal Data

We may collect sensitive personal data where required to provide our Services or as permitted by applicable law. When we collect sensitive data, we do so in accordance with the consent mechanisms established by the Law.

Data Collected Automatically

When you use the Roxels platform, we may collect technical data automatically, including:

• IP address and device identifiers.
• Browser type and operating system.
• Session duration and interaction patterns.
• Screen-sharing session data (visual data observed during guided flows, used solely for the purpose of providing real-time assistance or task automation).

3. How We Use Your Data

We use the personal data we collect for the following purposes:

• Service delivery: To provide, operate, and improve the Roxels platform, including AI-powered screen observation, real-time user guidance, task automation, data extraction, and webhook delivery.
• Account management: To create and manage your account, verify your identity, and process payments.
• Communication: To contact you regarding your account, respond to inquiries, and provide support.
• Legal compliance: To fulfill contractual obligations and comply with applicable laws and regulations.
• Security: To detect, prevent, and address fraud, unauthorized access, and technical issues.
• Improvement: To analyze usage patterns and improve the functionality and user experience of the platform.

The specific purposes for data processing will be defined in accordance with the service agreement or contract established between you and TB Networks.

By providing your personal data and not expressly objecting after being presented with this Privacy Policy, you are deemed to have given tacit consent to the processing of your data for the purposes described above, as provided by Article 8 of the Law.

4. Screen-Sharing and AI Processing

Roxels' core functionality involves AI-powered observation of users' screens during guided sessions. During these sessions:

• The AI observes what is displayed on the user's screen in real time to provide contextual guidance or to complete tasks on the user's behalf.
• Screen data is processed in real time and is used solely for the purpose of delivering the Service during that session.
• We do not store screen recordings or screenshots beyond what is strictly necessary to deliver the Service, unless otherwise specified in your service agreement.
• Any data collected through screen-sharing sessions is treated with the same security and confidentiality standards as all other personal data.

5. Data Transfers

Within TB Networks

We may share your personal data with other departments or affiliated entities of TB Networks (including subsidiaries and parent companies), whether located in Mexico or abroad, to fulfill the purposes described in this Privacy Policy and to comply with our contractual obligations.

With Third Parties

We may share certain personal data with third-party service providers ("Third-Party Recipients") when necessary to deliver the Services or fulfill the purposes described herein. Such transfers do not require your additional express consent when they fall within the exceptions established by the Law.

We will never sell your personal data to third parties.

6. Third-Party Links

The Roxels platform may contain links to third-party websites or services. These third-party sites have their own privacy policies, and we accept no responsibility for their practices. We encourage you to review their privacy policies before submitting any personal information.

The presence of a link on our platform does not constitute an endorsement of the linked site or its content.

7. Cookies and Similar Technologies

We may use cookies, web beacons, and similar technologies to collect information about your browsing activity on our platform. These technologies allow us to remember your preferences, analyze usage patterns, and improve your experience.

Most web browsers accept cookies automatically. You can configure your browser to block cookies or notify you when a cookie is being set. Disabling cookies may affect the functionality of certain features on the platform.

For more information on managing cookies, visit allaboutcookies.org.

8. Google User Data

If the Roxels platform accesses any Google user data, it will do so only with your explicit verification and consent. You will be notified before any access to your Google data and must authorize credentials before access is granted. Google user data accessed through Roxels will not be stored or shared by us beyond the scope of the authorized functionality.

9. Children's Privacy

The Roxels platform is not intended for use by individuals under 13 years of age. We do not knowingly collect personal information from children under 13. If we become aware that a minor has submitted personal data, we will delete that information promptly.

10. Your Rights (ARCO Rights)

Under Mexican law, you have the right to:

• Access your personal data in our possession and learn how it is being processed.
• Rectify your data if it is inaccurate or incomplete.
• Cancel your data when you believe it is no longer necessary for the purposes described in this Privacy Policy, when it is being used for purposes you did not consent to, or when the contractual relationship has ended.
• Object to the processing of your data for specific purposes.

How to Exercise Your Rights

To exercise any of these rights, please submit a written request via email to daniel@trebu.io with the following information:

1. Your full name.
2. Your address or email address where we can send our response.
3. A copy of an official identification document.
4. For legal entities: documents proving legal existence, powers of attorney, and the legal representative's identification.
5. A clear description of the personal data involved and the right you wish to exercise.
6. Any additional documents that may help us locate your data.

We will respond to your request within 20 business days from the date of receipt. This period may be extended once for an additional 20 business days if justified by the circumstances.

When We May Deny a Request

We may deny your request if:

• You are not the data holder or authorized representative.
• The data is not found in our records.
• Granting the request would infringe on a third party's rights.
• A legal or judicial order prevents compliance.
• The request has already been fulfilled.

11. Revocation of Consent

You may revoke your consent for the processing of your personal data at any time. To do so, send a request to daniel@trebu.io including:

1. Your full name.
2. Your address or email for response delivery.
3. Official identification (for individuals) or corporate documentation (for legal entities).
4. A clear statement that you wish to revoke consent, along with your reasons.

We will respond within 20 business days. Please note that TB Networks may retain the right to process certain data as permitted or required by law, even after consent is revoked.

12. Data Blocking and Deletion

Once the purposes for processing your data have been fulfilled and no legal, administrative, or regulatory obligation requires otherwise, your personal data will be blocked and subsequently deleted from our systems.

13. Security

We implement technical, administrative, and physical security measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction. However, no method of transmission over the Internet or electronic storage is 100% secure. While we strive to protect your information, we cannot guarantee absolute security.

14. Data Retention

We retain personal data for as long as necessary to provide the Services, fulfill our legitimate business purposes, and comply with legal obligations. Data is retained for the longer of: (a) the period required by applicable law, or (b) as long as there is a defined and time-limited business need.

15. Limiting Use and Disclosure

You may limit the use and disclosure of your personal data by:

• Registering with the Public Registry managed by the Federal Consumer Protection Agency (PROFECO) to prevent your data from being used for marketing purposes. Visit PROFECO's website for more information.
• Requesting to be added to our exclusion list so that your data is not used for marketing, advertising, or commercial prospecting purposes by TB Networks.

16. Changes to This Privacy Policy

TB Networks reserves the right to modify or update this Privacy Policy at any time to reflect changes in legislation, internal policies, or service requirements.

Your continued use of the Roxels platform after any modifications constitutes acceptance of the updated Privacy Policy.

17. Applicable Law

This Privacy Policy is governed by the laws of Mexico. TB Networks is located in Mexico, and your personal data may be transferred to, stored, and processed in Mexico. If you are located outside of Mexico, please be aware that Mexican data protection standards may differ from those in your jurisdiction.

Your information may also be subject to lawful access by Mexican government authorities.

18. Contact

For any questions or concerns regarding this Privacy Policy or the processing of your personal data, please contact:

TB NETWORKS, S.A.P.I. de C.V. — Data Protection DepartmentBosques de Ciruelos 180 PP, Bosques de las Lomas, Miguel Hidalgo, 11700, Mexico City, MexicoEmail: daniel@trebu.io

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