Privacy Policy

Legal Notice and Privacy Policy

In compliance with Law Prevention of Electronic Crimes Act, 2016 (PECA), Electronic Transactions Ordinance, 2002 (ETO 2002), and other applicable laws of Pakistan (including provincial regulations under the Sindh Protection of Personal Data Act 2023, if applicable), Pixel Flow LLP ("we", "our", "us") bearing registration No. 0292776 and registered office at Marina View, D-76, Block 7, Clifton, KDA Scheme 5, Karachi, Saddar Town, Karachi South, Sindh, Pakistan confirms its ownership of www.pixelflow.com.pk.

What is this Privacy Policy for?

This Privacy Policy ("Policy") aims to inform you, the user of Pixel Flow LLP's mobile application (the "Application") and/or its website www.pixelflow.com.pk (the "Website"), about how your personal data is collected, used, stored, and shared by Pixel Flow LLP and its affiliates ("Pixel Flow"). This Policy is issued in compliance with applicable laws of Pakistan, including but not limited to the Prevention of Electronic Crimes Act, 2016 (PECA) and the Electronic Transactions Ordinance, 2002 (ETO 2002). Pixel Flow is committed to protecting your privacy. This Policy explains the nature of the personal information we collect through the Application and the Website, how we use it, your rights in relation to that data, and the measures we take to safeguard your personal information.

By using our services, you acknowledge that you have read and understood this Policy and agree to be bound by its terms.

Third-Party Data Disclosure

If you provide Pixel Flow with any personal data relating to third parties (e.g., family members, colleagues, or other users), you confirm that you have obtained proper consent from those individuals to share their data with us. You also undertake to share the contents of this Privacy Policy with them. Pixel Flow disclaims liability for any unauthorized or unlawful sharing of third-party data by users.

Identity and Contact Details of the Data Controller

The data controller responsible for the collection, use, and protection of your personal data is: Pixel Flow LLP, registration No. 0292776 with registered office at Marina View, D-76, Block 7, Clifton, KDA Scheme 5, Karachi, Saddar Town, Karachi South, Sindh, Pakistan

Contact email: info@pixelflow.com.pk

All data collected from users will be processed in a lawful, fair, and transparent manner and maintained in a secure environment.

What Information Do We Collect from Users?

Pixel Flow provides Users with a charging service for their mobile devices through various smart charging terminals with monitors ("Battery Sharing Stations") that incorporate 5,000 mAh lithium batteries ("Powerbanks") and that can be located indoors or outdoors.

Our devices may be installed outdoors or at our (venue partners) clients' premises. Both we and our (venue partners) clients, through surveys or registration forms, may request and collect User data. In the usage of your data, please note your information will be shared within the industries mentioned in the Exhibit below. You as the user provide your consent in order to use such data for informational, commercial, or advertising purposes.

We collect the following categories of information from Users: (A) personally identifiable information; (B) passive electronically collected information; and (C) location information (collectively, the "Information").

Pixel Flow will anonymize some of the data it collects when using it for various purposes, such as market analysis, traffic flow analysis and reporting, or other internal purposes. Pixel Flow has a legitimate interest in producing these reports to improve the quality of its services.

(A) Personally Identifiable Information

Receive and store any information obtained through the provision of services that allows the User to be personally identified, contacted, or identified by other people.

Data collected from the User includes:

• The complete current registration information, consisting of the User's first name, last name, email address, date of birth, telephone number, gender, age, billing address and country of residence.
• Any data that the User provides about themselves or other people when sending an email to Pixel Flow, communicating with technical support, or directly with Pixel Flow.
• Information related to or connected to a social media account that the User uses to register or log in to the Application or the Website. For example, when the User associates their Facebook account with the Application, Pixel Flow will have access to their public profile, friends list, and email address. If the User registers or logs in with other social media accounts, such as Instagram, Twitter, Gmail, or LinkedIn, Pixel Flow may obtain similar information from those platforms. To do so, the User must accept their corresponding terms and conditions. However, of all this information, Pixel Flow will only collect relevant data for its use. Regarding this information, the User should keep in mind that social media networks have their own independent privacy policies, which inform them about how they use their Users' personal data. It is advisable to review these privacy policies and the information collected, made public, and/or decided to share through them.
• Information relating to the User's debit/credit card. This data will be minimal and limited to credit card numbers and the expiration date.
• Other information that the User may provide to receive free services, participate in a sweepstakes or contest, or make inquiries.

(B) Passive Information Collected Electronically

Pixel Flow, the entities that provide services to it (the "Service Providers"), the entities on whose premises the Battery Sharing Stations are located, or the entities that use Pixel Flow's services to advertise (the "Advertisers"), and other third parties to whom Pixel Flow communicates User data may automatically collect certain types of passive information when the User uses Pixel Flow's services. For example, we may collect identifiers such as an IDFA (for iOS) or AAID (for Android), or the hardware model, operating system version, your network provider, IP address, MAC address, and other unique device identifiers.

Information about your use of the service, frequency of use of the service, pages, forms, or screens visited, session status, and similar data associated with your mobile device or charging unit usage will also be collected.

(C) Location Information via Pixel Flow Charging Devices

This information is derived from GPS, Wi-Fi, Bluetooth, compass, accelerometer, IP address, or posts containing location information. The User will share certain charging device location information in certain cases:

• when the Battery Sharing Stations are located within the facilities and in the private areas of our Clients, through the installed Beacons.
• The Application may use this type of information when the User uses certain location-based features, such as the Compass (to locate nearby Battery Sharing Stations), Map (to navigate to the nearest Battery Sharing Station), and when the User shares his or her location with other Pixel Flow Users;
• When the User removes the Powerbanks, in order to track and confirm whether or not they are returned to the Battery Sharing Stations.

The entities, as well as all third parties that use Pixel Flow's services to obtain data from Users (our clients, which may be referred to as "Partners" in this Privacy Policy), some of which operate Battery Sharing Stations or the facilities in which the Battery Sharing Stations are located, are not affiliated with Pixel Flow and may have their own privacy policies and terms of use, which you may be asked to accept before using a Pixel Flow charging device or which may govern the use of information collected from your use of the services provided.

We also inform you that the collection and processing of some of this information is necessary for Pixel Flow to provide some of its services, particularly the ability to charge your mobile device with Power Banks.

For What Purposes and Legitimacy Do We Use Your Data?

Pixel Flow always uses the data collected for the proper functioning of its hardware and software tools that we make available to our clients for the following purposes:

Purposes Necessary for the Provision of the Service and Compliance with the Contractual Relationship:

• Allow the User to use the Application and the Website, manage the account and indicate where the Battery Sharing Stations are located.
• Communicating User data to those Partners and/or Advertisers with whom Users interact, for example, with Partners that operate Battery Sharing Stations where Users charge their devices and, where applicable, to the Advertisers displayed there.
• Allow Pixel Flow Partners, through the Pixel Flow website, access to a personalized control panel where they can view all the data generated by users at the Battery Sharing Stations.
• Communicate the data collected from users to other Pixel Flow Partners.
• For marketing, promotional, and customer prospecting or satisfaction survey activities by Pixel Flow, Partners, and Advertisers, such as promoting products and services through generic notifications or personalized offers from Partners with whom the user has interacted at Battery Sharing Stations.

Purposes Based on Legitimate Interest:

• Prevent fraud and other prohibited or illegal activities, and generally ensure Pixel Flow complies with applicable laws. Pixel Flow has a legitimate interest in trying to prevent potential fraud related to the provision of the service. Furthermore, this data processing is necessary to comply with applicable law.
• Personalize, analyze, evaluate, adjust, and improve the services provided to meet the needs and expectations of Users, Advertisers, or Partners, as well as provide the User with functionality changes. All of this is done with the aim of improving the quality of the services provided.
• Anonymize or aggregate data for various purposes, such as market analysis, traffic flow analysis and reporting, or other internal purposes. Pixel Flow has a legitimate interest in producing these reports for the same purpose of improving the quality of service delivery.
• Conducting satisfaction surveys on Pixel Flow services among its Users.

Purposes Requiring Consent

If you accept this Privacy Policy, you may subsequently grant consent for your data to be processed for other purposes. However, the User has the option to customize their consent or, where appropriate and at any time, modify, grant, or revoke the consents granted:

• Advertising and promotion. Our clients may contact you with information about their activities and advertising.
• Profiling. We will create a commercial profile of the User based on the information provided so we can communicate information tailored to their interests, for example, by sending them advertising related to their interests and/or about Partners or services similar to those with which they primarily interact.
• Communicate the existence of establishments, promotions, or offers from Partners and Advertisers near the User.

How Long Will We Keep Your Data?

At Pixel Flow, we aim to retain the personal data provided only for as long as necessary to fulfill the purpose for which it was collected and to determine any potential liabilities that may arise from the purpose for which it was collected.

Data retention criteria: Data will be retained for the period established by law, as long as the data subject continues to use the Application and/or Website, as long as there is a mutual interest in maintaining the purpose of the processing and until it is no longer necessary for that purpose, as long as the contractual relationship is maintained, as long as its deletion is not requested by the data subject, and it does not need to be deleted because it is necessary for compliance with a legal obligation or for the formulation, exercise, or defense of legal claims. Data will be deleted with appropriate security measures to guarantee the pseudonymization of the data or its total destruction.

If the User revokes their consent or exercises their right to cancellation or deletion, their personal data will be kept and stored at the disposal of the Administration of Justice for the legally established periods to address potential liabilities arising from their processing. They will then be deleted with appropriate security measures to ensure pseudonymization of the data or their complete destruction.

User Acceptance

By accepting this Privacy Policy, the User confirms having read, understood and agreed to its terms.

Users must modify the data entered in the Application as it becomes outdated, and are responsible, in all cases, for the truthfulness and accuracy of the data provided at all times. Pixel Flow reserves the right at its sole discretion, where applicable and without prejudice to any other actions it may take, to refuse to provide services or to terminate the membership of any User who provides false or incomplete data.

Pixel Flow assumes no liability for any damages or losses that may arise from the falsity or inaccuracy of the data provided, for which the User shall be solely responsible.

Pixel Flow may also disclose the personal data collected in specific cases where it is required by applicable laws, regulations, or court orders, mandated by competent regulatory or enforcement authorities and/or necessary to protect Pixel Flow's rights, property, or safety, or that of Users or the public.

Data Communication

All data communications indicated below are necessary for the fulfillment of the aforementioned purposes, or are carried out in compliance with a legal obligation:

1. Authorities and law enforcement agencies. Public authorities or law enforcement personnel, if requested for the purposes set out in this notice, if required by law, or if necessary to protect our legitimate interests in accordance with applicable laws.
2. Pixel Flow Partners. In order to provide the User with free access to Pixel Flow Points and to offers and services that Pixel Flow and/or the Partners consider valuable, Pixel Flow will share the User's data and any additional information collected at such points with the Partners that operate the facilities where the Pixel Flow Points are located. For example, if the User uses a Pixel Flow Point, the Partner that operates it will receive or have access to the User's data collected by Pixel Flow and may send the User an offer or promotion for its products or services.
3. Service Providers. Pixel Flow may share User data with third parties that provide services on Pixel Flow's behalf. These may include, for example (but not limited to), storage service providers, data processing services, technical and customer support providers, survey and market research service providers, and other service providers that assist in providing services to the User. Pixel Flow contractually requires these third-party service providers to protect User data. These service providers are not entitled to use or transfer the data for any purpose other than performing services on Pixel Flow's behalf.

Recipients of User Data

Pixel Flow will share User data with various recipients, in accordance with the guidelines outlined above. Users can learn more below about the categories of recipients with whom they allow their data to be shared and communicated.

Likewise, the User can also customize the recipients and/or categories of recipients to whom they allow their data to be shared by sending an email with their username and telephone number to info@pixelflow.com.pk and object to and/or withdraw consent for those recipients with whom they choose not to share their personal data.

Data Protection Rights of Users

At any time, and/or whenever they deem it appropriate, Users may exercise their rights of Access, Rectification, Cancellation, Objection, Portability, and To Be Forgotten by writing to the contact email address we have enabled for this purpose: info@pixelflow.com.pk, attaching a copy of the data subject's passport or ID card and stating the request they wish to make in the subject line: access, rectification, cancellation, objection, portability, or to be forgotten.

We briefly explain each of the rights you can exercise:

• Access: By exercising this right, you can learn what personal data of yours is being processed by Pixel Flow, its purpose, origin, and possible transfer to third parties.
• Rectification: This allows you to modify your personal data that is inaccurate or incomplete, and you must specify in the request which data you wish to have modified.
• Cancellation: Allows the cancellation of your personal data due to inadequacy or excessive data.
• Opposition: With the right to object, you can object to the processing of your data in cases such as advertising and commercial prospecting activities, profiling, or when such processing is intended to make a decision about you based solely on the automated processing of your personal data.
• Portability: You may receive your personal data provided in a structured, commonly used, and machine-readable format, and may transmit it to another controller, where technically feasible.
• Suppression or forgetting: You may request the deletion of personal data without undue delay when any of the aforementioned circumstances apply. For example, unlawful data processing, or when the purpose for which the data was processed or collected has ceased to exist.

Use of Cookies

While browsing the Website, cookies will be used, the use of which will be regulated in accordance with the provisions of the applicable regulations and the Website Cookie Policy, hosted at the URL https://pixelflow.com.pk/cookie-policy, where you can access its full text.

Privacy Policy Changes

Pixel Flow may update its privacy policy and will promptly inform users of any changes and the new policy.

Pixel Flow reserves the right to modify this Privacy Policy at any time in accordance with applicable law. Users will be able to review any updates on the Website. Continued use of the service after such changes have been made will constitute acceptance of the updated Privacy Policy.

If you have any questions about our Privacy Policy, please contact us by sending an email to info@pixelflow.com.pk. Likewise, if you consider that your rights are not being properly respected, you have the right to file a complaint with the relevant authorities in Pakistan.

Exhibit

PIXEL FLOW RECIPIENT CATEGORIES

Below, you can see the categories of recipients of your data:

• Catering industry recipients.
• Textile industry recipients.
• Recipients of financial institutions.
• Recipients of public institutions.
• Recipients of the IT and ICT industry.
• Recipients: marketing and advertising agencies.
• Recipients of the consulting sector.
• Food industry recipients.
• Recipients of the transport industry.
• Real estate and real estate industry recipients.
• Recipients of the Leisure and Events industry.
• Recipients of the Beverage and Tobacco industry.
• Or other industries recognized as stakeholders under the Laws of the Islamic Republic of Pakistan