PRIVACY POLICY

Controller (Verantwortlicher): Studio 073X e.K., a sole proprietorship (Einzelkaufmann) represented by its owner Benjamin Zvonar, Rienzistr. 12, 70597 Stuttgart, Germany. Email: project@aetop.co. Phone: +49 (0) 152 04094564. ("we," "us," "our," or the "Controller").

This Privacy Notice describes how and why we collect, store, use, and/or share ("process") your personal data when you use our services ("Services"), including when you:

• Visit our website at https://www.aetop.co, or any website of ours that links to this Privacy Notice
• Engage with us in other related ways, including any sales, marketing, or events

Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. Contact us at project@aetop.co.

SUMMARY OF KEY POINTS

This summary provides key points from our Privacy Notice, but you can find out more details about any of these topics by clicking the link following each key point or by using our table of contents below to find the section you are looking for.

What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use. Learn more about personal information you disclose to us.

Do we process any sensitive personal information? Some of the information may be considered "special" or "sensitive" in certain jurisdictions, for example your racial or ethnic origins, sexual orientation, and religious beliefs. We do not process sensitive personal information.

Do we collect any information from third parties? We do not collect any information from third parties.

How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so. Learn more about how we process your information.

In what situations and with which parties do we share personal information? We may share information in specific situations and with specific third parties. Learn more about when and with whom we share your personal information.

How do we keep your information safe? We have adequate organizational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Learn more about how we keep your information safe.

What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information. Learn more about your privacy rights.

How do you exercise your rights? The easiest way to exercise your rights is by submitting a data subject access request, or by contacting us. We will consider and act upon any request in accordance with applicable data protection laws.

Want to learn more about what we do with any information we collect? Review the Privacy Notice in full.

TABLE OF CONTENTS

1. WHAT INFORMATION DO WE COLLECT?
2. HOW DO WE PROCESS YOUR INFORMATION?
3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?
4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
6. HOW LONG DO WE KEEP YOUR INFORMATION?
7. HOW DO WE KEEP YOUR INFORMATION SAFE?
8. DO WE COLLECT INFORMATION FROM MINORS?
9. WHAT ARE YOUR PRIVACY RIGHTS?
10. CONTROLS FOR DO-NOT-TRACK FEATURES
11. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
12. DO WE MAKE UPDATES TO THIS NOTICE?
13. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
14. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:

• contact preferences
• contact or authentication data
• billing addresses
• names
• phone numbers
• email addresses

Sensitive Information. We do not process sensitive information.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Information automatically collected

In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies. The information we collect includes:

• Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called "crash dumps"), and hardware settings).
• Device Data. We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.
• Location Data. We collect location data such as information about your device's location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Services. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device. However, if you choose to opt out, you may not be able to use certain aspects of the Services.

2. HOW DO WE PROCESS YOUR INFORMATION?

In Short: We process your personal data only for the specific purposes listed below and only where we have a valid legal basis to do so.

We process your personal information for the following purposes:

• To respond to contact and inquiry requests. When you submit a contact form or reach out to us by email, we process the data you provide (name, email, message) to respond to your request.
• To send the Grok Bot Setup Spec (double opt-in). If you request the free spec at https://www.aetop.co/en/grokbot/free-setup-spec, we store your email with Resend Contacts, send a confirmation mail, and after you press Confirm send the PDF plus up to three follow-up mails about Grok Bot Workforce over about eight days. We do not send the PDF or follow-up until Confirm. You can withdraw via the unsubscribe link in those mails or by writing project@aetop.co. The contact record is stored in the United States by Resend (see processors below).
• To deliver services and fulfill contracts. Where you engage AETOP. for services, we process your contact and billing information to administer the engagement, issue invoices, and fulfil our contractual obligations.
• For accounting and legal compliance. Invoice and transaction data is retained to comply with German commercial and tax law (§§ 147 AO, 257 HGB).
• For website analytics and improvement. We use analytics tools to understand how visitors use our website, with the aim of improving our Services. This processing relies on your consent (for cookies) and our legitimate interests.
• For security and fraud prevention. We process technical data (IP addresses, log data) to protect the security and integrity of our Services.
• To save or protect vital interests. In exceptional cases, we may process information where necessary to protect the vital interests of any person.

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?

In Short: We only process your personal data where we have a valid legal basis under the GDPR (Art. 6 DSGVO).

The General Data Protection Regulation (GDPR / DSGVO) requires us to state the legal basis for each processing activity. We rely on the following:

• Consent (Art. 6(1)(a) GDPR). For analytics and marketing cookies and pixels, and for the Grok Bot Setup Spec mailing list (confirmation mail, PDF delivery, and up to three follow-up mails). You may withdraw cookie consent via the cookie preferences banner in the footer. You may withdraw mailing-list consent via the unsubscribe link in each mail after confirm, or by emailing project@aetop.co.
• Contract performance (Art. 6(1)(b) GDPR). To deliver services you have engaged us for and to manage the client relationship.
• Legal obligation (Art. 6(1)(c) GDPR). To comply with German commercial and tax law (e.g., invoice retention under §§ 147 AO, 257 HGB).
• Legitimate interests (Art. 6(1)(f) GDPR). To operate and secure this website, respond to inquiries, and improve our Services, where these interests are not overridden by your rights. You may object to this processing at any time.
• Vital interests (Art. 6(1)(d) GDPR). In exceptional circumstances only, where necessary to protect the vital interests of any person.

A data protection officer (Datenschutzbeauftragte/r) has not been appointed, as the legal thresholds under Art. 37 GDPR are not met.

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

In Short: We share data only with the processors listed below, each under a Data Processing Agreement (Art. 28 GDPR). US-based processors operate under the EU–US Data Privacy Framework (DPF) or Standard Contractual Clauses (SCCs, Art. 46(2)(c) GDPR) as the transfer mechanism.

We use the following third-party processors:

Business Transfers. We may share or transfer your information in connection with a merger, sale of company assets, or acquisition. You will be notified of any such change via a prominent notice on this website.

5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In Short: We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Notice.

6. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information only as long as necessary for each purpose, subject to the statutory minimum retention periods under German law.

Specific retention periods by data category:

• Contact and inquiry data (name, email, message): 3 years from last contact, in line with the standard limitation period (§ 195 BGB).
• Grok Bot Setup Spec list (email, consent text and version, confirm timestamp, unsubscribe timestamp): until you unsubscribe or ask us to erase it. After unsubscribe we keep the address marked unsubscribed as a suppression record so we do not mail you again. Unconfirmed pending addresses are not marketed to.
• Invoicing and contract data: 10 years from invoice date, as required by §§ 147 AO, 257 HGB.
• Analytics data (Google Analytics, PostHog): maximum 13 months, per German DSK guidance. Configured accordingly in our analytics accounts.
• Marketing pixel data (Meta, Twitter/X, TikTok): maximum 90 days, unless you have given extended consent.
• Server log data (IP addresses, access logs): 7 days for security purposes, then deleted.

When the applicable retention period expires, data is deleted or anonymized. Where deletion is not immediately possible (e.g., backup archives), data is isolated from further processing until deletion occurs.

7. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

8. DO WE COLLECT INFORMATION FROM MINORS?

In Short: We do not knowingly collect data from or market to children under 18 years of age.

We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent's use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at project@aetop.co.

9. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: In some regions, such as the European Economic Area (EEA) and United Kingdom (UK), you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.

In some regions (like the EEA and UK), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us by using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below.

We will consider and act upon any request in accordance with applicable data protection laws.

If you are located in Germany and believe we are unlawfully processing your personal data, you have the right to lodge a complaint with the competent supervisory authority:

Landesbeauftragter für den Datenschutz und die Informationsfreiheit Baden-Württemberg (LfDI BW)
Königstraße 10a, 70173 Stuttgart
www.baden-wuerttemberg.datenschutz.de

For other EEA member states, contact details for national supervisory authorities are available at: ec.europa.eu/justice/data-protection/bodies/authorities.

If you are located in Switzerland, the contact details for the data protection authorities are available here: edoeb.admin.ch.

Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below. If you joined the Grok Bot Setup Spec list, you can also withdraw by using the unsubscribe link in the PDF or follow-up mail.

However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services. If you have questions or comments about your privacy rights, you may email us at project@aetop.co.

10. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Notice.

California law requires us to let you know how we respond to web browser DNT signals. Because there currently is not an industry or legal standard for recognizing or honoring DNT signals, we do not respond to them at this time.

11. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: If you are a resident of California or another US state with applicable privacy law, you may have the right to request access to and receive details about the personal information we maintain about you and how we have processed it, correct inaccuracies, get a copy of, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. More information is provided below.

Categories of Personal Information We Collect

We have collected the following categories of personal information in the past twelve (12) months:

We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of:

• Receiving help through our customer support channels;
• Participation in customer surveys or contests; and
• Facilitation in the delivery of our Services and to respond to your inquiries.

Sources of Personal Information

Learn more about the sources of personal information we collect in "WHAT INFORMATION DO WE COLLECT?"

How We Use and Share Personal Information

Learn more about how we use your personal information in the section, "HOW DO WE PROCESS YOUR INFORMATION?"

Will your information be shared with anyone else?

We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Learn more about how we disclose personal information to in the section, "WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?"

We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be "selling" of your personal information.

We have not disclosed, sold, or shared any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. We will not sell or share personal information in the future belonging to website visitors, users, and other consumers.

Your Rights

You have rights under certain US state data protection laws. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law. These rights include:

• Right to know whether or not we are processing your personal data
• Right to access your personal data
• Right to correct inaccuracies in your personal data
• Right to request the deletion of your personal data
• Right to obtain a copy of the personal data you previously shared with us
• Right to non-discrimination for exercising your rights
• Right to opt out of the processing of your personal data if it is used for targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects ("profiling")

How to Exercise Your Rights

To exercise these rights, you can contact us by submitting a data subject access request, by emailing us at project@aetop.co, or by referring to the contact details at the bottom of this document.

Under certain US state data protection laws, you can designate an authorized agent to make a request on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with applicable laws.

Request Verification

Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. We will only use personal information provided in your request to verify your identity or authority to make the request. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes.

If you submit the request through an authorized agent, we may need to collect additional information to verify your identity before processing your request and the agent will need to provide a written and signed permission from you to submit such request on your behalf.

12. DO WE MAKE UPDATES TO THIS NOTICE?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this Privacy Notice from time to time. The updated version will be indicated by an updated "Revised" date at the top of this Privacy Notice. If we make material changes to this Privacy Notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Notice frequently to be informed of how we are protecting your information.

13. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, or wish to exercise any of your data subject rights (access, rectification, erasure, restriction, portability, objection), please contact us:

Studio 073X e.K.

Benjamin Zvonar

Rienzistr. 12, 70597 Stuttgart, Germany

Email: project@aetop.co

Phone: +49 (0) 152 04094564

We will respond to all data subject requests within one month as required by Art. 12(3) GDPR.

14. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Based on the applicable laws of your country or state of residence in the US, you may have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. To request to review, update, or delete your personal information, please fill out and submit a data subject access request.