1. Privacy Policy

Sonim Online Privacy and Security Policy

1) Introduction. 

We value your privacy and are committed to protecting your personal
information. This Privacy Policy explains how we collect, use, disclose, and safeguard your
information.


2) Enterprise Customers. 

NEXA primarily provides products and services to business and
enterprise customers. In many cases, NEXA processes personal information on behalf of its
customers in accordance with contractual agreements and applicable law. Where NEXA
acts as a service provider or processor on behalf of a customer, individuals seeking to
exercise privacy rights may need to direct their request to the organization that controls the
personal information.


3) Information We Collect. 

We may collect personal information that you provide directly to
us, as well as information collected automatically through your use of our website and
services. This may include:

  1. Identifiers (such as name, email address, or account information)
  2. Usage data (such as interactions with our website or services)
  3. Device and technical information
  4. Other information you choose to provide


4) How We Use Information. 

We may use personal information for purposes including to:

  1. Provide and maintain our services
  2. Improve functionality and user experience
  3. Communicate with users
  4. Personalize content and offerings
  5. Ensure security and prevent fraud
  6. Comply with legal obligations


5) Sharing of Information. 

  1. We may disclose personal information to:
  2. Service providers and vendors that support our operations
  3. Business partners in connection with our services
  4. Legal or regulatory authorities, where required
  5. Other parties in connection with a business transaction


6) Legal Bases for Processing. 

Where applicable under data protection laws, we process
personal information based on one or more of the following legal bases:

  1. Performance of a contract;
  2. Compliance with legal obligations;
  3. Legitimate business interests, including providing, securing, maintaining, and improving
    our services;
  4. Consent, where required by applicable law;
  5. Protection of vital interests or other lawful bases permitted under applicable law.



7) Cookies and Tracking Technologies. 

We use cookies and similar technologies as
described in our Cookie & Tracking Technologies Policy.


8) Sensitive Personal Information

  1. We may collect certain categories of personal information that are considered “sensitive”
    under applicable law. This may include, where permitted:
    1. Precise geolocation information
    2. Biometric identifiers or information (such as facial recognition data or fingerprints)
    3. Health-related information
    4. Financial account information

    5. Government-issued identification numbers

       

  2. How We Use Sensitive Personal Information. We may use sensitive personal
    information for purposes such as:
    1. Providing and improving our services
    2. Personalizing user experiences
    3. Ensuring security and preventing fraud

    4. Complying with legal obligations

       

  3. Disclosure to Third Parties. 

    We may disclose sensitive personal information to service
    providers or other third parties as necessary to support our business operations, subject
    to applicable legal requirements.

     

  4. Your Rights and Choices. 

    Depending on your location, you may have the right to limit
    the use and disclosure of your sensitive personal information. You may exercise these
    rights through available privacy settings, consent tools, or by contacting us as described
    in our Privacy Policy.

     

  5. Changes to Our Practices. 

    Our collection and use of sensitive personal information
    may change over time as we develop new features or services or as legal requirements
    evolve. If you have questions about our handling of sensitive personal information,
    please contact us at: legal@nexamobilty.com

     

9) International Data Transfers. 

Personal information may be transferred to and processed
in countries other than the country in which it was collected. Where required by applicable
law, we implement appropriate safeguards designed to protect personal information during
international transfers.


10) Your Rights and Choices. 

Depending on your location, you may have rights
regarding your personal information, including the right to access, delete, or correct your
data, and to opt out of certain uses. You may exercise these rights as described in this
policy or by contacting us. Depending on your location and applicable law, you may have
rights regarding your personal information, including rights to access, correct, delete,
restrict, object to certain processing activities, receive a copy of your data in a portable
format, and withdraw consent where processing is based on consent.


11) California Privacy Rights. 

If you are a California resident, you may have the following
rights under applicable California privacy laws:

  1. Right to Know. 

    You may request information regarding the categories of personal
    information we collect, the sources from which we collect it, the purposes for which it is
    used, and the categories of third parties with whom it is disclosed.

     

  2. Right to Access. 

    You may request access to specific pieces of personal information
    that we maintain about you, subject to applicable legal exceptions.

     

  3. Right to Delete. 

    You may request deletion of personal information we have
    collected from you, subject to applicable legal exceptions.

     

  4. Right to Correct. 

    You may request correction of inaccurate personal information
    maintained about you.

     

  5. Right to Opt Out of Sale or Sharing. 

    Where applicable, you may have the right to
    opt out of the sale or sharing of your personal information. Requests may be submitted
    through our "Do Not Sell or Share My Personal Information" mechanism where required.

     

  6. Right to Limit the Use and Disclosure of Sensitive Personal Information. 

    Where applicable, you may have the right to limit certain uses and disclosures of sensitive
    personal information.

     

  7. Right to Non-Discrimination. 

    We will not discriminate against you for exercising any
    privacy rights available under applicable law.
     

To exercise these rights, please contact us at legal@nexamobility.com or through any
privacy rights request mechanism we make available.


12) Data Retention. 

Retention periods may vary depending on the nature of the information,
legal requirements, contractual obligations, and legitimate business needs.


13) Security. 

We implement reasonable administrative, technical, and organizational measures
to protect personal information.

 

14) Changes to This Privacy Policy. 

We may update this Privacy Policy from time to time. Changes will be effective when posted.


15) Contact. 

If you have questions about this Privacy Policy or our data practices, please
contact us at: legal@nexamobility.com. Individuals located in the European Economic Area
may have the right to lodge a complaint with a supervisory authority if they believe their
personal information has been processed in violation of applicable law.