Core Privacy Principles

1. Fairness, Lawfulness & Transparency – We process personal data in a fair, lawful, and transparent way—always informing individuals why we collect their information and how it will be used.

2. Purpose Limitation – Data is collected solely for specific, legitimate purposes and never used beyond those purposes without additional consent.

3. Data Minimization (Proportionality) – We only gather data that is adequate and necessary for the intended purpose.

4. Accuracy & Data Integrity – Personal information is maintained accurately and kept current, as required.

5. Retention & Disposal (Storage Limitation) – Data is retained only as long as needed, after which it is securely deleted, anonymized, or disposed of.

6. Security (Integrity & Confidentiality) – We implement appropriate technical and organizational measures to protect data against unauthorized access, disclosure, or loss.

7. Respect for Individual Rights – We uphold individuals’ rights to access, correct, delete, and restrict processing of their personal data.

8. Accountability – nexCanopy maintains governance, policies, and controls to demonstrate compliance with this Privacy Commitment.

Privacy Governance Program

• Global Applicability & Scope Applies to all nexCanopy employees, contractors, and partners globally whenever personal data is processed.

• Legal Compliance & Risk Resolution We comply with all applicable privacy laws. In the rare event of legal conflicts, our Chief Privacy Officer evaluates the situation and works with regulators to resolve them.

• Privacy by Design and Default Privacy and security considerations are embedded into every stage of our product and service lifecycle.

• Employee Awareness & Training Team members receive regular training on privacy and data protection best practices.

• Incident Response & Vendor Oversight We maintain robust procedures for detecting and responding to data incidents. All third-party vendors must comply with our stringent data protection standards.

• Continuous Monitoring & Review We execute self‑assessments, internal/external audits, and other controls to measure compliance and identify improvements.