Effective Date: October 31, 2025

This Privacy Policy (the “Policy”) is issued to all our customers, delegates, vendors, suppliers, consultants, business partners, and/or any other individuals whose personal data is collected and processed by APEIROGON TECHNOLOGIES SDN. BHD. (Company Registration No.: 1582496M) (collectively, “the Company,” “we,” “us,” or “our”).

This Policy is formulated in compliance with the Personal Data Protection Act 2010 (“PDPA”) of Malaysia.

1. Personal Data Protection Principles (PDPA 2010)

We adhere strictly to the seven Personal Data Protection Principles outlined in the PDPA: General, Notice and Choice, Disclosure, Security, Retention, Data Integrity, and Access.

2. Collection of Personal Data

2.1 Types of Personal Data

The Personal Data we collect may include, but is not limited to:

• Identification and Contact Details: Name, job title, company name, address, telephone number, email address, national identification card number (NRIC), passport number.
• Professional Details: Employment history, educational background, professional qualifications, and business profiles.
• Technical Data: IP address, cookies, browser type, operating system, and data collected through your interaction with our Website or Services.
• Commercial Data: Transaction history, financial details (where necessary for payment of services), and services purchased or inquired about.

2.2 Source of Personal Data

We may collect Personal Data from the following sources, including but not limited to:

• Directly from you when you fill out forms, register for events, communicate with us, or use our Services.
• From third-party sources such as business partners, public registers, and credit reference agencies.
• From cookies and technical systems when you visit our Website.

3. Purpose of Processing Personal Data (General Principle)

We process your Personal Data for lawful purposes directly related to our business activities, including business management consultancy, computer programming, and general trading. These purposes include, but are not limited to:

1. To provide, administer, and manage the Services you have requested.
2. To verify your identity and to communicate with you regarding our Services, updates, or events.
3. To perform statistical analysis for internal business purposes, market research, and trend analysis.
4. For business development, including providing you with marketing, promotional, and educational materials relating to our current or future Services (subject to your consent/choice).
5. To comply with legal, regulatory, and statutory requirements in Malaysia (including tax and accounting obligations).
6. To conduct credit checks, internal risk management, and to enforce and defend our legal rights.

4. Notice and Choice Principle (Your Rights)

As a Data Subject, you have the right to be informed and to make choices regarding the processing of your Personal Data.

4.1 Consequences of Failure to Supply Personal Data

The supply of Personal Data is voluntary. However, if you fail to provide the necessary Personal Data, we may not be able to:

• Provide you with the requested Services.
• Enter into a contract or transaction with you.
• Process your inquiries or applications.

4.2 Withdrawal of Consent and Opt-Out

You have the right to withdraw your consent to the processing of your Personal Data for specific purposes (e.g., direct marketing) at any time.

Direct Marketing Opt-Out: If you wish to stop receiving direct marketing materials, you may contact us via the designated channels provided on our main corporate website or follow the unsubscribe links in our emails. We will comply with your written request to cease or not begin processing your Personal Data for direct marketing within a reasonable timeframe.

5. Disclosure Principle (Third Parties)

We may disclose your Personal Data to the following classes of third parties, both within and outside Malaysia, for the Purposes stated in Section 3:

• Our related, associated, or affiliated companies within the Company Group.
• Our professional advisors (such as lawyers, auditors, and consultants).
• Service providers, contractors, and agents acting on our behalf (e.g., IT support, cloud providers, event organisers).
• Regulatory, governmental, and statutory authorities in order to comply with legal obligations.

6. Security Principle

We are committed to protecting the security of your Personal Data. We implement technical and organisational security measures to protect Personal Data from loss, misuse, modification, unauthorised or accidental access or disclosure, alteration, or destruction.

7. Retention Principle

We shall not retain your Personal Data longer than is necessary for the fulfilment of the Purposes for which it was processed. We will take all reasonable steps to destroy or permanently delete Personal Data that is no longer required, subject to any legal or regulatory requirements (e.g., for tax or financial record-keeping).

8. Access and Correction Principle

You have the right to request access to, and correction of, your Personal Data held by us.

8.1 How to Exercise Your Rights and Contact Us

If you wish to make a request for access to or correction of your Personal Data, or if you have any inquiry or complaint regarding our processing of your Personal Data, please address your correspondence to our Data Protection Officer via the designated channels provided on our main corporate website.

9. Language of Notice

In accordance with Section 7(3) of the PDPA, this Policy is available in the national language (Bahasa Melayu) and English. In the event of any inconsistency, the English version shall prevail.