PRIVACY POLICY

SCALES AND EMBER (PTY) LTD (the “Company”), governed by the laws of South Africa, requires the highest standards of professional and ethical conduct from its employees, officers, and directors. The Company’s commitment to honesty and integrity is fundamental to its business success and reputation.

This Code of Business Conduct and Ethics (this “Code”) outlines the principles and policies that all employees, officers, and directors of SCALES AND EMBER (PTY) LTD are expected to adhere to. It reflects the Company’s dedication to fostering a culture of honesty, integrity, and accountability in all aspects of its operations.

In addition to complying with this Code, employees, officers, and directors are encouraged to seek guidance whenever there is uncertainty about complying with the Company’s policies and applicable laws. While this Code provides general principles, specific policies and procedures are detailed in the Employee Handbooks of SCALES AND EMBER (PTY) LTD and its subsidiaries, the Code of Conduct applicable to vendors and licensees, and other policy statements such as the Securities Trading Policy, Related Person Transactions Policy, Whistleblower Policy, and Anti-Bribery Policy.

Your cooperation is essential to uphold SCALES AND EMBER (PTY) LTD’s commitment to ethical business practices and to maintain its reputation as a responsible corporate citizen.

 

SCALES AND EMBER (PTY) LTD Introduction SCALES AND EMBER (PTY) LTD (the “Company”), governed by the laws of South Africa, requires the highest standards of professional and ethical conduct from its employees, officers, and directors. The Company’s commitment to honesty and integrity is fundamental to its business success and reputation. This Code of Business Conduct and Ethics (this “Code”) outlines the principles and policies that all employees, officers, and directors of SCALES AND EMBER (PTY) LTD are expected to adhere to. It reflects the Company’s dedication to fostering a culture of honesty, integrity, and accountability in all aspects of its operations. In addition to complying with this Code, employees, officers, and directors are encouraged to seek guidance whenever there is uncertainty about complying with the Company’s policies and applicable laws. While this Code provides general principles, specific policies and procedures are detailed in the Employee Handbooks of SCALES AND EMBER (PTY) LTD and its subsidiaries, the Code of Conduct applicable to vendors and licensees, and other policy statements such as the Securities Trading Policy, Related Person Transactions Policy, Whistleblower Policy, and Anti-Bribery Policy. Your cooperation is essential to uphold SCALES AND EMBER (PTY) LTD’s commitment to ethical business practices and to maintain its reputation as a responsible corporate citizen.

SCALES & EMBER (PTY) LTD Pursuant to Article 37 GDPR, the Data Controller has designated the Data Protection Officer (hereinafter only "DPO"), who can be reached at the following address: info@scalesandember.com.

Privacy Policy: Data Collection: Browsing Data: We collect browsing data, including IP addresses and URI addresses, which are necessary for the operation of our website. This data is used for anonymous statistical purposes and to ensure proper functionality. It is promptly deleted after processing. In case of potential computer crimes, this data may be used to ascertain responsibility and kept for this purpose only. Voluntarily Supplied Data: Users may voluntarily provide identification information such as name, surname, email, telephone number, and tax code. This information is provided, for instance, during registration or when requesting specific services on our platform. Cookies: For details regarding cookies used on our platform, please consult our Cookie Policy. This policy applies to all users of Scales & Ember and outlines our commitment to protecting your privacy while using our services. For further information or questions about our privacy practices, please contact us.

At Scales & Ember, safeguarding the safety and privacy of minors is a top priority for us. By registering on our website in the designated section, completing any data collection forms, or subscribing to our Newsletter service, users confirm that they are at least 16 years old or meet the minimum age required by their country of residence legislation. This ensures compliance with applicable age restrictions.

The processing of Data of Data Subjects is conducted - with electronic methods - involving operations such as collection, registration, updating, organization, storage, consultation, elaboration, modification, selection, extraction, comparison, use, interconnection, blocking, deletion, and destruction of the Data. Scales & Ember and its employees process data using computer systems (as well as manual methods), adhering to the principles of fairness, loyalty, and transparency as stipulated by relevant legislation on personal data protection. The confidentiality of the Data Subject and their rights are safeguarded through the implementation of appropriate technical and organizational measures to ensure a level of security commensurate with the risks involved. Specific security protocols are in place to prevent data loss, unlawful or improper use, and unauthorized access.

With reference to the purposes outlined in points A) of par. 5 (Purposes of the processing), Data will be processed throughout the duration of the relationship to achieve the aforementioned purposes. Data necessary for compliance with any legal obligations will be retained beyond this period, in accordance with such obligations and as per the retention periods stipulated by applicable regulations. For Data provided for purposes B, specifically nos. 1 (marketing) and 2 (profiling) as described in par. 5 (Purposes of the processing), considering the nature of personal data related to purchases of 'high-end' products and the infrequent frequency of purchases annually per customer, your provided Data will be retained for a maximum of 7 years. This timeframe is deemed suitable and proportionate to the intended purposes and the type of personal data being processed. Upon expiration of this period, the data will be securely deleted or anonymized. Data Subjects may always provide new consent to Scales & Ember for continued processing for these purposes. For Data provided for purpose B, no. 3 (use of Facebook Business Tools) as outlined in par. 5 (Purposes of the processing), the Data will be processed in accordance with Facebook's Data Policy, which can be reviewed at Facebook Data Policy. For Data provided for purpose B, no. 4 (use of Facebook custom audience services) as outlined in par. 5 (Purposes of the processing), the Data will be processed by Scales & Ember for the duration of its contractual relationship with Facebook and until the Data Subject modifies their consent or requests deletion.

Data processing at Scales & Ember is conducted by internal staff designated for this purpose as Data Processors or persons in charge of processing. The data collected for the purposes mentioned above may also be processed by third parties appointed as external Data Processors or, where applicable, disclosed to them as independent Data Controllers, specifically: - Companies within our corporate group for the specified purposes - Individuals, companies, associations, or professional firms providing assistance and consultancy services to Scales & Ember, including accounting, administrative, legal, tax, and financial matters - Companies, bodies, or associations providing services essential for website navigation by Data Subjects, as well as couriers for product delivery, customer service, analysis, market research, and management of credit card payments and computer systems maintenance - Public administrations for institutional functions within legal limits - Public Bodies, Judicial Authorities, and Police Bodies where required by law or for verification purposes For a complete and updated list of entities processing Data as Data Processors and Independent Data Controllers, please contact Scales & Ember at info@scalesandember.com.

Data Subjects may exercise, in relation to the data processing described herein, the rights provided for by the European Regulation (Articles 15-21), including the right: - To receive confirmation of the existence of their personal data and access to its contents (right of access). - To update, modify, and/or correct their personal data (right of rectification). - To request the deletion or limitation of data processed unlawfully, including data unnecessary for the purposes for which they were collected or processed (right to erasure and right to restriction). - To object to the processing of personal data (right to object). - To withdraw consent, where given, without affecting the lawfulness of processing based on consent before withdrawal. - To lodge a complaint with the Supervisory Authority if there is a breach of personal data protection regulations. - To receive a copy of the personal data provided to Scales & Ember in a structured, commonly used, and machine-readable format, and to request its transmission to another data controller (right to data portability). Requests should be directed to Scales & Ember via email at info@scalesandember.com Scales & Ember (PTY) LTD

Consistent with applicable laws and in accordance with our commitment to safeguarding your privacy, you have specific rights concerning the processing of your personal information by Scales & Ember. These rights include: Access to Your Personal Information: You have the right to confirm whether we have collected or processed personal information about you and to request a copy of the information we hold, which will be provided to you in electronic format. Correction of Your Data: You can request the correction of incomplete or inaccurate personal information we process about you. Certain corrections can be made directly through your online account. Deletion of Your Data: You have the right to request that we delete personal information we hold about you, with exceptions for situations where we need to retain such data to fulfill legal obligations, contractual obligations, or to defend legal claims. Process to Submit Requests: 1. Directly by You: - Submit a request via email to info@scalesandember.com; or - Call us at +27 644649528 and provide the necessary information. 2. Authorized Agent: If you authorize someone else to submit a request on your behalf, they must (1) complete and sign a power of attorney or written authorization, and (2) include the signed documents when submitting your request. For your privacy and security, and at our discretion, we may verify your identity before providing copies of your personal information, or processing deletion or correction requests. Additionally, we will only provide your personal information to you, even if you use an Authorized Agent to submit the request. Managing Marketing Communications: Opt-Out / Unsubscribe– Direct Mail: To opt-out of receiving direct mail from us, please contact us at info@scalesandember.com (for US and Canadian customers) and indicate “Opt-Out of Direct Mail” in the subject line. Note that we may still contact you regarding your account, transactions, and communications. Unsubscribe from Email Marketing: To unsubscribe from promotional emails, follow the unsubscribe instructions in each email you receive from us. We may still contact you regarding your accounts, transactions, and communications. Additional Specific Privacy Rights: Canadian Residents: Canadian residents have the right to withdraw consent to processing similar to the deletion right. To withdraw consent, submit a deletion request using the process described above. Colorado, Connecticut, Virginia, and Utah Residents: Residents of these states have the right to opt-out of targeted advertising. To opt-out, submit a request using the process described above. California Residents: California Shine the Light: California residents may request that we stop sharing their personal information with third parties for direct marketing purposes. Opt-out by emailing dpo@scalesandember.com with “Exercising my rights under CA Shine the Light” in the subject line, and include your first name, last name, and email associated with your Scales & Ember account. California Privacy Rights (CCPA and CPRA): Details regarding the categories of personal information we collect, sources of information, purposes of processing, and parties with whom we share information are available upon request by emailing info@scalesandember.com. Right to Opt-Out of Sale or Share of Personal Information: California consumers can direct us to not sell or share their personal information for targeted advertising purposes at any time by submitting a request using the process described above.

This Privacy Policy may be modified over time and we therefore invite users to periodically consult this page. To this end, the policy highlights the date of update. Version of June 2023

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