BVI Privacy Policy
BVI Medical, Inc. and its parent, BVI Group Limited and its subsidiaries, divisions and affiliates as set forth inAppendix A attached hereto, (collectively hereinafter referred to as "BVI”) respects individual privacy and values
the confidence of its customers, employees, vendors, business partners and others. BVI strives to collect, store,
process and distribute Personal Information in a manner consistent with the laws of the countries and jurisdictions
in which it does business and has a tradition of upholding the highest ethical standards in its business practices.
BVI has adopted this policy to establish and maintain an adequate level of privacy protection for personal
information and to outline how BVI collects, uses and discloses certain personal information, and the choices
affected individuals have regarding BVI's use of that information.
I. DEFINITIONS: For purposes of this Policy, the following definitions shall apply:"Agent" means any third party that processes Personal Information provided by BVI to perform tasks on behalf ofor at the instruction of BVI.
"Personal Information" means any information or set of information that identifies or could be used by or on behalfof BVI to identify an individual. Personal Information does not include information that is aggregated oranonymized.
"Sensitive Personal Information" means Personal Information that reveals racial or ethnic origin, trade union
membership, political opinions, religious beliefs (or beliefs of a similar nature), or that concern physical or mental
health or condition, sexual life, the commission or alleged commission of any offence or any proceedings for any
offence committed or alleged to have been committed. In addition, BVI will treat as sensitive Personal Information
any Information received from a third party where that third party treats and identifies the information as sensitive.
II. SCOPE. This Policy applies to all Personal Information received by BVI in any format including electronic, paperor verbal. BVI collects, stores and processes Personal Information concerning customers, vendors, and current andformer employees, as well as applicants for employment through its Internet websites, its intranet site, electronic
mail and in offline formats. On a global basis, BVI will, and will cause its affiliates to, establish and maintain businessprocedures that are consistent with this Policy.
III. INFORMATION COLLECTION AND USE. Personal Information collected, stored and processed by BVI from
employees and applicants for employment is maintained at its corporate offices in the United States or in the
United Kingdom, or at other BVI facilities, consistent with local legislation. BVI collects Personal Information, suchas name, contact information, taxpayer ID numbers, payroll information and employment histories for employment
related purposes and legitimate human resource business reasons such as recruitment and staffing; payroll
administration; absence monitoring; training and development; management planning; appraisal and promotion;
production and publication of company address books and telephone and e-mail directories; production of
employee Identity cards; monitoring the use of company resources; information to contact close relatives in caseof emergency; filling employment positions; administration and operations of its benefit and compensation
programs; meeting governmental reporting requirements; security, health and safety management; performance
management; company network access; and authentication. BVI does not request or gather information regarding

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political opinions, religion, philosophy or sexual preference. To the extent BVI maintains information on trade union
membership, medical health, race or ethnicity, BVI will protect, secure and process that Information in a mannerconsistent with this Policy and applicable law.
Personal Information collected by BVI from prospective customers, consumers, vendors, business partners andothers may be maintained at its corporate offices in the United States or in the United Kingdom, or at other BVI
facilities, consistent with local legislation. BVI collects Personal Information, such as name, contact information,
demographic information and payment information for legitimate business reasons such as customer service;product, warranty and claims administration; meeting governmental reporting and records requirements;
maintenance of accurate accounts payable and receivable records; internal marketing research; safety andperformance management; financial and sales data; and communications.
BVI may also collect information concerning website users through the use of "cookies" or similar data collection
technologies in order to provide better customer service. "Cookies" are small files that websites place on users'
computers to identify the user and enhance the website experience. Company personnel periodically audit BVI’scommercial websites to determine what cookies are used on each. The cookies used are typically not intrusive andare not typically used to identify visitors personally. These passive information technologies enable BVI to provide
better service to our customers, compile statistics, analyze trends and other wise administer and improve BVI’s
websites. Information collected by these technologies cannot be used to identify a specific user without additional
identifiable information and BVI will not connect additional identifiable information with information collected
through such technologies as cookies.
Visitors may set their browsers to provide notice before they receive a cookie, giving the opportunity to decide
whether to accept the cookie. Visitors can also set their browsers to turn off cookies. Visitors can learn how tocontrol or delete cookies used on BVI’s websites by visiting http://www.aboutcookies.org for detailed guidance. If
visitors do suppress the website cookies, however, some areas of BVI websites may not function properly. BVI’s
website does not respond to “Do Not Track” signals.
IV. INFORMATION SHARING. BVI may share Personal Information with third parties in a manner consistent withthis Policy. BVI shares Personal Information with Agents who complete transactions or perform services on ourbehalf or for your benefit, such as payment processing, website hosting, marketing, analytics, payroll, or to verify
personal information, such as mailing address. Under certain circumstances, BVI may be required to disclose
Personal Information in response to valid requests by public authorities, including to meet national security or law
enforcement requirements. BVI may need to disclose Personal Information to investigate claims, disputes orlitigation, when otherwise required by law, or if BVI determines its disclosure is necessary to protect the health andsafety of individuals, or to enforce legal rights or contractual commitments.
BVI may also disclose Personal Information as part of a corporate business transaction, such as a merger,
acquisition, joint venture, or financing or sale of company assets, including bankruptcy proceedings, and could betransferred to a third party as one of the business assets in such a transaction. It may also be disclosed in the eventof insolvency, bankruptcy or receivership.
BVI does not “sell” Personal Information and has not done so in the prior twelve months (or at any time).

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V. LEGAL BASIS FOR PROCESSING. Our legal basis for processing personal data as described above:••

To comply with legal obligations;To perform contracts;•

To pursue our legitimate interests of:o Delivering our goods or services;o Administering the employment relationship or considering prospective employees;o Providing our website and related services;o business development and general marketing;o providing you with information on our services and events, ando ensuring we build and maintain a good working relationship with you
Your consent, where we make it clear to you in advance that we are relying on you consent.

•

VI. PRIVACY PRINCIPLES.
NOTICE: Where BVI collects Personal Information directly from individuals, it will inform them about the purposes
for which it collects, stores and processes Personal Information about them, the types of non-Agent third parties
to which BVI discloses that information, and the choices and means, if any, BVI offers individuals for limiting theuse and disclosure of their Personal Information. Notice will be provided in clear and conspicuous language when
individuals are first asked to provide Personal Information to BVI, or as soon as practicable thereafter, and in any
event before BVI uses the information for a purpose other than that for which it was originally collected.
CHOICE: BVI offers individuals the opportunity to choose (opt-out) whether their Personal Information is (a) to bedisclosed to a non-Agent third party, or (b) to be used for a purpose other than the purpose for which it was
originally collected or subsequently authorized by the individual. To exercise this choice an individual may contact
us using the contact information provided below indicating their opt-out request. For Sensitive Personal
Information, BVI will give individuals the opportunity to affirmatively and explicitly (opt-in) consent to thedisclosure of the information to a non-agent third party or the use of the information for a purpose other than the
purpose for which it was originally collected or subsequently authorized by the individual.
ACCOUNTABILITY FOR ONWARD TRANSFER: Where required we will enter into contracts with its Agents that they
will safeguard Personal Information consistent with the Principles and limiting their use of the information to thespecified services provided on our behalf. Where BVI has knowledge that an Agent is using or disclosing Personal
Information in a manner contrary to this Policy, BVI will take reasonable steps to prevent or stop the use or
disclosure. BVI holds it Agents accountable for maintaining the trust our employees and customers place in thecompany. Under certain circumstances, BVI may remain liable under the Principles if the third party Agents process
Personal Information in a manner inconsistent with the Principles.
ACCESS AND CORRECTION: In some circumstances, individuals have the right to access the personal informationthat we maintain about them. Upon request, BVI will grant individuals reasonable access to Personal Informationthat it holds about them. In addition, BVI will take reasonable steps to permit individuals to correct, amend ordelete information that is demonstrated to be inaccurate, incomplete or has been processed in violation of the
Principles. These access rights may not apply fully in some cases, including where providing access is unreasonably
burdensome or expensive under the circumstances or where it would violate the rights of someone other than the
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individual requesting access. Any consumers who would like to request access to, correction, amendment ordeletion of their Personal Information, you can submit a written request to the contact information provided
below. We may request specific information from you to confirm your identity. Any employees that desire to review
or update their Personal Information can do so by contacting their local Human Resources Representative.
RECOURSE, ENFORCEMENT AND LIABILITY: BVI will conduct compliance audits of its relevant privacy practices toverify adherence to this Policy. Any employee that BVI determines is in violation of this Policy will be subject todisciplinary action up to and including termination of employment.
VII. COMPLAINTS AND DISPUTE RESOLUTION. BVI commits to resolve complaints about your privacy and ourcollection or use of your personal information. Any questions or concerns regarding the use or disclosure of
Personal Information should be directed to BVI’s Data Protection and Privacy Officer. European Union or Swiss
citizens with inquiries or complaints regarding this Privacy Policy should contact BVI at:
BVI Privacy Inquiries
Attention: Global Data Protection and Privacy Officer
BVI
10 CityPoint
500 Totten Pond Road
Waltham, MA 02451
Phone No. 781-906-7903
For complaints concerning the personal information of BVI employees BVI commits to cooperate with the panel
established by the EU data protection authorities (DPAs) and/or the Swiss Federal Data Protection and Information
Commissioner, respectively, and comply with the advice given by the panel and/or Commissioner with regard tohuman resources data transferred from the EU and/or Switzerland, respectively, in the context of the employment
relationship.
VIII. RIGHTS IN CONNECTION WITH PERSONAL INFORMATION. If your Personal Information is protected under
the EU General Data Protection Regulation, the UK Data Protection Act 2018 or the California Consumer Privacy
Act in certain circumstances, you may have the right to:
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Request access to your Personal information (commonly known as a “data subject access request”). This
enables you to request a copy of the Personal information we hold about you and to check that we areprocessing it lawfully.
Request correction of the Personal information that we hold about you. This enables you to have any
incomplete or inaccurate information we hold about you corrected.
Request erasure of your Personal information. This enables you to ask us to delete or remove Personal
information where there is no good reason for us continuing to process it.
Object to the processing of your Personal information where we are relying on a legitimate interest (orthose of a third party) and, other than for the purposes of direct marketing, there is something about yourparticular situation which makes you want to object to processing on this ground. You have the right toobject to our use of your personal information for direct marketing at any time.

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•
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Opt-out of the sale of your Personal information. Since we do not sell your Personal information, you arealready opted-out of such sales.
Request the restriction of processing of your Personal information. This enables you to ask us to suspend
the processing of Personal information about you, for example if you want us to establish its accuracy or
the reason for processing it.
Request the transfer of your Personal information to another party. This right will only apply in limited
circumstances, where we process your Personal information based on your consent or where theprocessing of Personal information is necessary for the performance of a contract between us.

The rights described herein are not absolute and we reserve all of our rights available to us under applicable law inthis regard. We do not discriminate against you, for example, by charging you a different price or offering a
different level of service, for exercising any of these rights.
You also have the right to lodge a complaint with your competent Data Protection Supervisory Authority. We
would, however, appreciate the opportunity to address your concerns before you approach a supervisory
authority, so please contact us in the first instance.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right toaccess the information (or to exercise any of your other rights), and in some instances, provide a signed declaration
under penalty of perjury that you are the individual whose personal information is the subject of the request. If it
is necessary to collect additional information from you, we will use the information only for verification purposes
and will delete it as soon as practicable after complying with the request. For requests related to particularly
sensitive information, we may require additional proof of identification. This is another appropriate security
measure to ensure that Personal information is not disclosed to any person who has no right to receive it.
If you make a request through an authorized agent, we will require written proof that the agent is authorized toact on your behalf.
California Residents – “Shine the Light”
We do not provide your Personal information to third parties for such third parties’ direct marketing purposes.
Please note that California Civil Code Section 1798.83 permits California residents to request certain information
regarding disclosure of such individuals’ personal information to third parties for such third parties’ direct
marketing purposes. As noted in the “How We Use Personal information” section above, your personal information
may be subject to certain third parties’ privacy policies.
IX. DATA RETENTION. BVI will only retain your Personal Information for as long as necessary to fulfill the purposes
we collected it for, including for the purposes of satisfying any legal, accounting, or tax requirements.
To determine the appropriate retention period for Personal Information, we consider the amount, nature, andsensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal
Information, the purposes for which we process your Personal Information and whether we can achieve those
purposes through other means, and the applicable legal requirements.

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X. INTERNATIONAL TRANSFERS. Where applicable, to protect your Personal Data under applicable privacy laws,
we ensure your Personal Information is adequately protected and that such transfers are carried out in accordancewith the law by ensuring at least one of the following safeguards is implemented:•••

The country to which a transfer is made has been deemed to provide an adequate level of protection by
the European Commission;
There are specific contracts in place with the recipient of your Personal Information (“Standard Contractual
Clauses”) which have been approved by the European Commission as providing your Personal Information
with an adequate level of protection: or
In certain circumstances, where you have given us your explicit consent to the transfer of your Personal
Data outside the EEA.

Please contact us if you want further information on the specific mechanism used by us when transferring your
Personal Information or to obtain a copy of any Standard Contractual Clauses utilized.
XI. THIRD PARTY LINKS. BVI websites may contain links to other "non-BVI" websites. BVI assumes no responsibility
for the content or the privacy policies and practices on those websites. BVI encourages all users to read the privacy
statements of those sites; their privacy practices may differ from those of BVI.
XII. CHILDREN. BVI does not knowingly solicit or collect any Personal Information directly from children undersixteen (16) years of age. If you are under sixteen (16) years of age, do not send any information about yourself to
us. Please contact us as provided below in the Contact Us section if you believe we may have collected suchinformation. BVI may collect certain information about minors in the context of an employment relationship, forexample, information about dependents.
XIII. CONTACT INFORMATION. Questions or comments regarding this Policy should be submitted to:
By Email: data_privacy@bvimedical.com
By Mail: BVI Privacy Inquiries
Attention: Global Data Protection and Privacy Officer
BVI
10 CityPoint
500 Totten Pond Road
Waltham, MA 02451
Phone No. 781-906-7903
Any inquiries should include the individual/company name, address, and other relevant contact information(phone number, email address). BVI will use all reasonable efforts to respond to such requests as quickly as
possible.
XIV. CHANGES TO THIS PRIVACY POLICY. The practices described in this Policy are current Personal Information
protection policies as of May 1, 2024. BVI reserves the right to modify or amend this Policy at any time consistent
with the requirements of the Privacy Principles. Appropriate notice will be given concerning such amendments.

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Appendix A - BVI Privacy Policy
BVI Group Limited
Subsidiaries, Divisions and Affiliates

Arcadophta SARL
Beaver Visitec International Japan KK
Beaver-Visitec International (UK) Limited
Beaver-Visitec International (US), Inc.
Beaver-Visitec International Australia Pty Ltd
Beaver-Visitec International Inc.
Beaver-Visitec International Ireland Limited
Beaver-Visitec International Limited
Beaver-Visitec International Sales Limited
Beaver-Visitec International Sales Limited (Russian Branch)
Beaver-Visitec International Sales Limited (Belgian Branch)
Beaver-Visitec International Sales Limited (French Branch)
Beaver-Visitec International Sales Limited (German Branch)
Beaver-Visitec International Sales Limited (Italian Branch)
Beaver-Visitec International Sales PTE LTD
Benz R&D LLC
BVI Audley Inc.
BVI Brasil Produtos Medicos Limitada (Brazil)
BVI EU BVBVI Florida Inc.
BVI France SAS
BVI Holdings Kensington Limited
BVI Holdings Limited
BVI Holdings Mayfair Limited
BVI Italy SRL
BVI Knightsbridge Limited
BVI Medical Inc.
BVI Medical Holdings Spain, S.L.U.
BVI Medical Portugal, Lda
BVI Norway

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BVI Ovington Limited
BVI Oxford Inc.
BVI Sweden
BVI Victoria Limited
BVI Visualization, Inc.
Crea IP BVDJ Instrumenter A/SJohn Bannon Limited
Malosa (BVI) Limited
Malosa (HK) Limited
Malosa Limited
Malosa Medical Instruments (Changshu) Limited
Medical Mix, S.L.U.
Optikon 2000 SPA
PhysIOL Group SA
PhysIOL SA
SpecialEyes LLC
Vitreq BV
Vitreq Holding BV

BVI – May 1, 2024