1. POLICY STATEMENT

1.1 DroneShield Group Pty Ltd (ABN 44 668 560 610) is a business registered in Australia (hereafter DroneShield, we, or us) and is committed to keeping your information safe and secure in accordance with the Privacy Act 1988 (Cth) (the Privacy Act), the Australian Privacy Principles contained therein, and any applicable State or Territory law governing your data collection or privacy.

1.2 By using DroneShield's website (the Website), DroneShield's products or platforms (together, Platforms), obtaining DroneShield services, or accessing DroneShield's facilities, you are giving consent to DroneShield for the collection, storage, and/or use of your private and personal information in the manner set out in this Privacy Policy.

1.3 This Privacy Policy explains how DroneShield collects, uses, stores, discloses and protects your personal information, your rights, and how you may contact DroneShield or the Office of the Australian Information Commissioner (OAIC).

1.4 To the extent DroneShield must comply with General Data Protection Regulation (GDPR) as applied respectively by the European Economic Area (EEA), the United Kingdom, or Switzerland, and the information that we collect, receive or use for our business purposes is information that relates to an identified or identifiable individual in one of those geographic areas, we will treat such information as personal information as required by the GDPR, any other applicable data protection laws, and pursuant to section 10 of this Privacy Policy.

2. COLLECTION OF PERSONAL INFORMATION

2.1 The Privacy Act defines 'Personal Information' as information or an opinion about an identified individual or an individual who is reasonably identifiable. For the purposes of this Privacy Policy, personal information is taken to broadly mean any information that identifies or can be used to identify you.

2.2 DroneShield may collect and use the following kinds of personal information while you use the Website, Platforms, access a DroneShield facility, or otherwise obtain DroneShield services:

(a) Information about your internet or other electronic network activity, which includes:

    (i) information about your use of the Website (including your IP address; browser type, version and language; operating system; identification number; location; pages viewed while browsing the Website, Platforms, or services; page access times; "cookies"; and referring website address);

    (ii) information about your login and use of Platforms (including your IP address, username, password, email, access times, and name and type of downloaded files, if any);

(b) information about your personal details or professional/employment-related details that you provide (including name; phone contact details; email; postal address; employer name; and your business or professional role);

(c) any other information you provide during your interactions with DroneShield; and

(d) information derived or inferred from any of the above types of personal information.

2.3 Your personal information may be collected by DroneShield in a variety of ways, including, but not limited to:

(a) when you register for the Website, Platforms, or any other DroneShield service or product (including without limitation registering and/or logging into a customer portal, subscribing/opting-in to a DroneShield direct marketing list, subscribing/opting-in to receive SMS/email alert notifications, making an online submission via 'Connect with us' or any other information you input onto the Website, or registering to download a file from DroneShield);

(b) when you interact with DroneShield electronically, via telephone, in writing, or in person;

(c) when you apply for a job or provide us with goods and/or services (as an employee, contractor, volunteer, or agent);

(d) when you access a DroneShield facility, the Website, Platforms, or any other DroneShield system;

(e) from a third party who is a DroneShield partner or customer, such as your employer, so we can provide information, services, or the Platforms to that DroneShield partner or customer, or from companies contracted by us or you to provide information, services or the Platforms to you or another third party connected to you; and

(f) any other manner or form you may provide your personal information to DroneShield from time to time, whether directly, indirectly, or via a third party.

2.4 We have relationships with third parties to receive data that you post publicly or have otherwise made publicly available. We may also have access to information that you post on other social media platforms. This Privacy Policy does not cover the use of personal information by any third parties that you submit to such third parties, and we are not responsible for their privacy policies and practices. To learn more about how third-party data sources treat your personal information, you should reference their privacy terms.

2.5 You have the option of not identifying yourself or of using a pseudonym when dealing with DroneShield. However, non-identification will be impracticable for DroneShield to provide you with services, information, or Platforms, and may limit the accuracy, functionality, use and/or purpose of what DroneShield may be providing.

3. USE OF PERSONAL INFORMATION

3.1 DroneShield may use your personal information in relation to its business, including, but not limited to:

(a) enabling and/or providing access to DroneShield facilities, the Website, Platforms, or any other DroneShield system that we deem necessary for you to access;

(b) track usage and measure traffic statistics of the Website and Platforms;

(c) contact you regarding your use of the Website and Platforms;

(d) contact you in relation to comments, complaints, feedback, enquiries or dispute resolution;

(e) issuing formal legal notices to you;

(f) collect payments from you;

(g) to improve the Website or Platforms;

(h) to provide the Website, Platforms or services to you, anyone using or obtaining any of the aforementioned, and/or our partners/customers;

(i) to verify your identity;

(j) to apply for legal, governmental, or regulatory permits, authorisations, exemptions, or the equivalent;

(k) to conduct background checks, to the extent permitted by applicable laws;

(l) to consider you for a job with us (whether as an employee or contractor) or in the context of other relationships with us;

(m) to address any issues or complaints that we or you have regarding our relationship;

(n) communicate with third party providers or associate parties with respect to the provision of any Platforms and/or services;

(o) send you marketing communications;

(p) if you have subscribed/opted-in, send you SMS/email alert notifications; and

(q) as reasonably necessary to comply with any legal, governmental, and/or regulatory requirements.

3.2 DroneShield may also use your personal information to protect the copyright, trademarks, or other intellectual property or legal rights, property, or safety of DroneShield, the Website, the Platforms, and its customers or third parties.

4. DISCLOSURE OF PERSONAL INFORMATION

4.1 DroneShield will not disclose personal information about you, unless it is required, incidental or otherwise related to the primary purpose of providing the Platform or services to you or a third party.

4.2 For customers, DroneShield may disclose your personal information to its business partners who can assist them to provide the Platform or services to you as a customer or to maintain its products or systems. This includes but is not limited to providing personal information to:

(a) our employees and related bodies corporate;

(b) our contractors and other third parties that provide goods and services to us (including website and data hosting providers, processors/sub-processors (including, without limitation, AWS, Oracle, Salesforce, Microsoft Azure, HubSpot) and other suppliers);

(c) our accountants, insurers, lawyers, auditors and other professional advisers and agents;

(d) payment system operators or credit reporting bodies (if you fail to make a payment);

(e) any third parties necessary to verify your information, conduct background checks, or for other vetting purposes (e.g. referees or ID verifiers);

(f) in the event that we or our assets may be acquired or considered for acquisition by a third party, that third party and its advisors;

(g) third parties that require the information for law enforcement or to prevent a serious threat to public safety; and

(h) otherwise as permitted or required by law.

4.3 DroneShield, in its sole discretion, may disclose your personal information if it is required to do so by law or legal process, including:

(a) in order to establish, exercise or defend its legal rights (including but not limited to debt recovery, credit rating services, and employment related matters);

(b) as required or authorised by law, regulation, or the ASX; or

(c) to the extent required to permit DroneShield to investigate suspected fraud, harassment or other violations of any law, rule or regulation, our policies, or the rights of third parties or any other suspected conduct DroneShield deem improper.

4.4 If you are an individual contractor to us or a prospective or current employee then we may disclose the information to our related companies and HR related service providers (e.g. for outsourced payroll processing, employment-related compliance, etc.).

4.5 If there is a change of control in our business or a sale or transfer of business assets, we reserve the right to transfer to the extent permissible at law our user databases, together with any personal information and non-personal information contained in those databases. This information may be disclosed to a potential purchaser under an agreement to maintain confidentiality. DroneShield uses reasonable effort to only disclose personal information in good faith and where required by any of the above circumstances.

5. RETENTION

5.1 DroneShield will retain the personal information you provide for as long as is reasonably necessary for the purposes explained in this Privacy Policy, in accordance with tax or accounting requirements or as required by applicable law.

6. SECURITY AND ACCURACY

6.1 If DroneShield requires personal information in order to provide the Platforms or relevant services, you must ensure your personal information remains accurate, complete, and up-to-date in order for DroneShield to continue providing the Platforms or services to you.

6.2 DroneShield will take commercially reasonable steps to protect your personal information from misuse, loss, unauthorised access, modification and disclosure. However, DroneShield is not liable for any unauthorised access to your personal information beyond its reasonable control.

6.3 DroneShield will take commercially reasonable steps to destroy or permanently de-identify personal information if it is no longer needed for the purposes of providing the Website, Platforms or our services to you, there is no legitimate interest need, or where DroneShield is not required to retain that information by law.

6.4 In the event of a data breach that is likely to result in serious harm, the Notifiable Data Breaches Scheme in the Privacy Act sets out obligations for notifying affected individuals, and the OAIC about an "eligible data breach". Where a data breach occurs and serious harm to affected individuals is likely, we will notify those individuals and the Commissioner in accordance with our legal obligations.

7. ACCESS AND CORRECTION

7.1 You are responsible to ensure that the information you provide to DroneShield is accurate, complete and up-to-date.

7.2 By request, you may contact DroneShield and ask to know what sort of personal information is held about you, for what purposes, and how it is collected, held, used, and disclosed.

7.3 By request, you may access your personal information by contacting DroneShield at legal@droneshield.com. DroneShield reserves the right to charge a reasonable administration fee for this access.

7.4 DroneShield in its sole discretion, may consider that there is a sound reason under the Privacy Act, Freedom of Information Act or other relevant law to withhold personal information, or not make the requested changes.

8. IDENTIFIERS AND ANONYMITY

8.1 You acknowledge that DroneShield retains, collects and maintains your personal information for statistical analysis purposes (whether for commercial or non-commercial purposes). You agree that DroneShield may share, distribute and/or transfer information which you have provided to DroneShield to third parties, after that information has been de-identified or has otherwise been aggregated in a way that prevents you from being identified.

9. SENSITIVE INFORMATION

9.1 Sensitive information is defined in the Privacy Act to include information or opinion about such things as an individual's racial or ethnic origin, political opinions, membership of a political association, trade union or professional/trade association, religious or philosophical beliefs, criminal record, sexual preferences or practices, health information, or genetic information.

9.2 DroneShield does not collect sensitive information by default and asks that you do not provide unsolicited sensitive information to us. However, if DroneShield needs to obtain your sensitive information to comply with the law, then DroneShield will:

(a) only collect your sensitive information with your prior consent;

(b) not use your sensitive information for a secondary purpose of direct marketing;

(c) not share your sensitive information with any DroneShield Affiliates or Related Bodies Corporate without your prior consent.

9.3 Sensitive information will be used by DroneShield only:

(a) for the primary purpose for which it was obtained;

(b) for a secondary purpose that is directly related to the primary purpose;

(c) with your consent; or

(d) where required or authorised by law.

10. TRANS-BORDER DATA FLOWS

10.1 DroneShield has its headquarters in Australia, so information we collect from you will be processed in Australia. Your personal information may also be transferred to other DroneShield affiliates, including those outside of Australia, in which case it will be stored and processed through global systems (e.g., the US in the case of DroneShield LLC, the EEA in the case of DroneShield B.V., etc.)

10.2 DroneShield may use cloud services or other electronic networks to facilitate the use of the Website, the Platforms, or other DroneShield services, in which case, the cloud or electronic network servers may be located in Australia or overseas.

10.3 You acknowledge, agree and understand that your personal information may be transferred to, within, and between; stored in; and processed in Australia and/or other foreign jurisdictions, including without limitation Japan, the US, the UK, the EEA, and/or any other jurisdiction which the cloud services or other electronic network provider may direct the data to be stored. You consent for us to transfer your information into Australia and foreign jurisdictions for the purposes of providing you with the Website, the Platforms, or any DroneShield services.

10.4 In addition to the above, DroneShield will transfer personal information to someone in a foreign country where:

(a) DroneShield reasonably believes that the recipient of the information is subject to a law, binding scheme or contract which effectively upholds principles for fair handling of the information that are substantially similar to the Australian Privacy Principles or the GDPR, as applicable;

(b) the individual consents to the transfer;

(c) the transfer is necessary for the performance of a contract between you and DroneShield, or for the implementation of pre-contractual measures taken in response to your request;

(d) the transfer is necessary for the conclusion or performance of a contract concluded in your interest between DroneShield and a third party;

(e) all of the following apply:

    (i) the transfer is for your benefit;

    (ii) it is impracticable to obtain your consent to that transfer; and

    (iii) if it were practicable to obtain such consent, you would be likely to give it;

(f) DroneShield has taken reasonable steps to ensure that the information which it has transferred will not be held, used or disclosed by the recipient of the information inconsistently with the Australian Privacy Principles; or

(g) if DroneShield is compelled to do so under any applicable law.

11. EEA, UK & SWISS RESIDENTS

11.1 If the data privacy laws of EEA, United Kingdom, or Switzerland, apply to you, then you have the right to access personal information, right to rectification or erasure, right to restriction of processing, right to object to the processing, and the right to data portability.

11.2 Processing: We process your personal information on one or more of the following legal bases, depending on the nature of the information and the context in which it has been collected:

(a) as necessary to enter into a contract with you or a legal entity you represent, to perform our contractual obligations, to provide the Platform or services, to respond to requests from you, to provide customer support, or to otherwise take steps at your request prior to entering into a contract with you;

(b) where we have a legitimate interest, as described in this Privacy Policy (for examples of what may be considered legitimate interest see section 3 'Use of Personal Information' above and section 11.3 'Legitimate Interest' below);

(c) as necessary to comply with applicable laws and legal obligations, including, without limitation, to: comply with any applicable privacy, financial, accounting, export control, employment, or equivalent law; respond to lawful requests and orders from courts, regulators or other lawful authorities; meet record keeping, reporting, and audit obligations; or manage compliance, risk and governance requirements;

(d) with your consent;

(e) as necessary to perform a task carried out in the public interest; or

(f) as necessary to protect the vital interests of you or another natural person.

11.3 Legitimate Interest: We process the following categories of Personal Data, such as contact data; background check data, subject to applicable laws and your consent, where required; account data; log data; web analytics; and publicly available information, when we believe it furthers the legitimate interest of us or third parties, such as:

(a) operation, maintenance, development, and improvement of DroneShield's business, the Website, Platforms, or DroneShield services;

(b) marketing of our products and services;

(c) communicating with business partners, service providers, contractors, customers, or yourself in the ordinary course of business;

(d) provision of customer support;

(e) corresponding with you;

(f) protection from fraud, misuse, or security threats;

(g) monitoring usage, performance and security of any DroneShield system, Website, Platforms, or DroneShield service;

(h) considering the engagement of individuals as an employee, contractor or through some other business relationship, and any vetting or background checks required as part of this consideration;

(i) compliance with legal obligations;

(j) establishing, exercising, or defending a legal right; and

(k) management and completion of corporate transactions, restructures, asset transfers, or the like, provided that the legitimate interests are not otherwise overridden by your interests, rights, and freedoms under applicable laws requiring protection of personal data. Where we rely on legitimate interests as a legal basis, we assess and balance those interests against the potential impact on individuals first to determine if any appropriate safeguards may need to be implemented.

11.4 Your Rights: Subject to applicable law, you have the right to:

(a) ask whether we hold personal information about you and request copies of such personal information and information about how it is processed;

(b) request that inaccurate personal information is corrected;

(c) request deletion of personal information that is no longer necessary for the purposes underlying the processing, processed based on withdrawn consent, or processed in non-compliance with applicable legal requirements;

(d) request us to restrict the processing of personal information where the processing is inappropriate;

(e) object to the processing of personal information; and

(f) if technically feasible, request portability of personal information that you have provided to us (which does not include information derived from the collected information), where the processing of such personal information is based on consent or the formation/performance of a contract with you and is carried out by automated means.

11.5 If you wish to exercise any of your rights, please contact us using the details provided in section 16 'How to Contact Us' below. We may charge you a nominal fee in relation to servicing a request exercising your rights.

11.6 When you consent to our processing your personal information for a specified purpose, you may withdraw your consent at any time, and we will stop any further processing of your data for that purpose. Withdrawing consent will not alter the lawfulness of any personal information processing prior to you withdrawing consent, nor will it affect any ongoing processing of your personal information conducted in reliance on lawful processing grounds other than consent.

11.7 Transfers outside of the EEA: Where clause 11.1 applies to you and we transfer your personal information outside the EEA, the UK, or Switzerland (as applicable), we do so in accordance with the terms of this Privacy Policy and applicable data protection laws. If your personal information will be transferred to a country that the European Commission, the UK Information Commissioner's Office, or the Swiss Federal Data Protection and Information Commissioner (as applicable) does not recognise as offering an adequate level of personal data protection, such transfers will be covered by alternative safeguards, including the application of the EU standard contractual clauses for the transfer of data (as amended for Switzerland or to incorporate the UK Privacy Addendum, if applicable).

12. COMPLAINTS

12.1 As a valuable customer, if you have any complaints in relation to this Privacy Policy or privacy practice, please feel free to contact DroneShield via legal@droneshield.com.

12.2    A complaint should identify whether it is about:

(a) the collection of personal information;

(b) the use of personal information;

(c) the disclosure of personal information;

(d) the security or storage of personal information;

(e) the accuracy of personal information;

(f) a refusal to give access to or provide about their personal information; or

(g) a refusal to change or delete personal information.

12.3    DroneShield values your opinions and takes complaints very seriously. Upon receiving written notice of your complaint about privacy, DroneShield may require additional information to confirm your identity and will respond in a timely manner to advise you of the outcome. You will also be invited to respond to its outcome. If a response is received, DroneShield will assess your response and advise if it has changed its view.

12.4 If you are unsatisfied with the final outcome, DroneShield will advise further options including, if appropriate, making a complaint with the OAIC. Should you wish to report a complaint to the OAIC, you may do so by completing an online submission here or by mailing your complaint to GPO Box 5288, Sydney NSW 2001.

12.5 For residents of the EEA or the UK, you may lodge a complaint with a data protection authority for your country or region or where any alleged infringement of applicable data protection law occurs. A list of data protection authorities is available here.

13. OPTING OUT OF DIRECT MARKETING & NOTIFICATION SERVICES

13.1 DroneShield aims to give you a highly personalised experience when using the Website, the Platform and associated services. To the extent permitted by applicable law, and where required based on your prior consent, DroneShield may use your personal information to send you marketing and promotional communications via email, regarding DroneShield, its products, services, Platforms, events, announcements, industry insights, thought leadership content, newsletters, and related updates.

13.2 Where you have expressly opted in to receive marketing communications on the Website or in any other communication with DroneShield, you consent to DroneShield and its related bodies corporate (including DroneShield Limited, DroneShield LLC, and DroneShield B.V.) using your personal information to:

(a) send you marketing and promotional materials;

(b) add you to DroneShield marketing and mailing lists;

(c) personalise marketing and promotional communications based on your interactions with DroneShield; and

(d) retain records for the purpose of proving your express consent (including, without limitation, the date, time, method, source, and version of the applicable consent language accepted), as required by applicable laws.

13.3 Where DroneShield relies on your consent under clause 13.2, you have the right at any time to withdraw that consent by requesting that we stop contacting you for advertising or marketing purposes. If you decide you do not want to receive any advertising or marketing material from DroneShield or no longer be on our mailing list, you can request to unsubscribe by clicking the 'Unsubscribe' link within any DroneShield marketing/promotional email or by emailing your request to support@droneshield.com. DroneShield will take all commercially reasonable steps to promptly process unsubscribe requests and will cease sending you marketing communications within the applicable statutory timeframe.

13.4 For clarity, opting out of marketing communications does not affect communications that DroneShield may need to send you purely for service, transactional, security, compliance, account management, support, administrative, or other strictly non-marketing purposes.

13.5 DroneShield Platforms may include the option for you to subscribe to a notification service via SMS or email (Notification Service). Subject to the requirements of the applicable laws, if you opt-in to this Notification Service:

(a) you will receive SMS or email notifications whenever there is an 'alert' in the selected location where your Platform-linked devices have been installed. Please note that message frequency will vary and SMS and data rates may apply; and

(b) DroneShield may store and process your personal information, including the following personal information directly provided to the Platform for the purposes of the Notification Service: your name (or given alias) and either your phone number (and country code) or email address (Mobile Opt-In Data).

13.6 At any time, you can request to unsubscribe or 'opt-out' of the Notification Service by either:

(a) if subscribed via SMS, replying STOP; or

(b) if subscribed via email or SMS, accessing the relevant Platform's UI and deleting the user listed in User Management, Alert Recipient (or the equivalent); or

(c) if neither of the above options work, contacting support@droneshield.com.

13.7 If you opt-in to the Notification Service, you consent to DroneShield using and disclosing your Mobile Opt-In Data strictly for the purposes of providing that Notification Service and related support, including sharing your Mobile Opt-In Data with its related bodies corporate (including DroneShield Limited, DroneShield LLC, and DroneShield B.V.) where necessary for those purposes and subject to applicable laws. DroneShield will not share your Mobile Opt-In Data with any other third parties for their own marketing purposes unless you have separately consented to this or such disclosure is required by law.

14.  COOKIES

14.1 DroneShield uses cookies and measurement software (Cookies) on the Website to:

(a) store details about your use of the Website to provide you with a personalised experience tailored to you, for example remembering your preferences;

(b) identify and interact more effectively with your device;

(c) analyse Website traffic, trends, and reporting statistics to improve the Website and maintain its security; and

(d) provide you with targeted and personalised marketing communications.

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14.2 We use Google Analytics remarketing codes to log when users view specific pages or take specific actions on the Website. This allows us to provide targeted advertising in the future.

14.3 You may reject or delete the use of Cookies through the settings on your browser or mobile settings.

14.4 Your web browser may use Cookies associated with DroneShield that you accept or decline the use of cookies through a functionality built into your web browser.

14.5 DroneShield does not track its customers over time and across third party websites to provide targeted advertising and therefore does not respond to Do Not Track (DNT) signals.

15.  THIRD PARTY SITES

15.1 The Website may from time to time have links to other websites not owned or controlled by DroneShield, including in the Platforms. These links are meant for your convenience only. Links to third party websites do not constitute sponsorship or endorsement or approval of these websites. Please be aware that DroneShield is not responsible for the privacy practises of other such websites. We encourage our users to be aware, when they leave our website, to read the privacy statements of each and every website that collects personal identifiable information.

16.  HOW TO CONTACT US

16.1 If you have a query in relation to this privacy policy, the personal information we hold on you (if any), would like to exercise one of your data protection rights, or would like to complain about DroneShield's handling of your personal information, please contact our Privacy and Data Protection Officer by email at legal@droneshield.com or by mail to:

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Privacy and Data Protection
Officer Level 5, 126 Phillip St Sydney, NSW 2000 Australia

17. VARIATION TO THIS PRIVACY POLICY

17.1 This Privacy Policy is available online via legal@DroneShield.com.

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17.2 DroneShield reserves the right to modify or amend this Privacy Policy at any time, for any reason, and without any notice, by posting a revised version on our Website or Platforms. If revisions materially affect how we handle personal information or impact individual rights, we will take reasonable steps to notify affected individuals, including by posting a prominent notice on our Website or Platform.

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17.3 Any changes to this Privacy Policy will become effective when DroneShield posts the revised Privacy Policy on the Website or Platforms. Your browsing of our Website or use of the Platforms following these changes means that you accept the revised Privacy Policy.

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17.4 This policy was last modified on 11 June 2026.