EULA - SWPANEL End User License Agreement

This End User License Agreement (this "Agreement") is a legal contract between you, either as an individual or as an Entity (as defined below), and the company DeepThink Software SLU (owner of SWPANEL), Calle Ponent, 13-15, 17458 Fornells de la Selva, Girona, Spain, hereinafter "DeepThink" in this document.

Introduction to the End User License Agreement (EULA)

Please read the terms and conditions of this Agreement carefully before downloading, installing, activating a license, accessing, or using SWPANEL, software owned by DeepThink Software SLU (hereinafter, "DeepThink"), which includes the following modes of use:

SWPANEL SaaS: cloud version accessible through the official website https://go.swpanel.com. SWPANEL Self-Hosted: version installable locally on "User" servers or devices. Mobile applications from the SWPANEL environment, such as SWPANEL for Mobile and SWPANEL InstantPass, as well as any other tool, functionality, or complementary software that DeepThink may develop in the future and that is linked to the SWPANEL ecosystem.

All of these modalities, present or future, are governed by the terms of this Agreement and the annexes that supplement it.

In order to avoid any ambiguity in interpretation and ensure a clear understanding of the different ways in which SWPANEL can be used and deployed, this Agreement includes a specific clause on definitions (see clause 1.9: Product definitions and execution environments). This clause formally differentiates the various types of SWPANEL, detailing their technical and operational characteristics and specific conditions of use.

This Agreement may incorporate this clause as a sub-section within point 1: License, or as a separate provision, acquiring full contractual value and being applicable across the entire document.

SWPANEL is protected by intellectual property rights. Its use is granted exclusively under a license for use, and in no case does it imply the transfer of ownership of the software to the User. By downloading, installing, activating a license, or using SWPANEL in any way, you expressly declare that you have read, understood, and fully accepted this Agreement, and you agree to comply with its terms without exception.

If you are acting on behalf of a company, public or private entity, organization, educational institution, public administration, or any other type of group (hereinafter, "the User"), you represent and warrant that you have the legal authority to accept this Agreement on behalf of that entity. In such case, any reference to "the User" in this document shall include both the person accepting the terms and the entity represented.

If you do not agree with any of the terms set forth in this Agreement, you must immediately discontinue the installation, activation, or use process, reject the license (for example, by selecting the "I do not accept" option or similar), and delete any copies of SWPANEL from your device(s).

This Agreement, together with the annexes and policies expressly incorporated by reference, constitutes the entire and binding agreement between "the User" and DeepThink, superseding any communication, proposal, or prior agreement—oral or written—relating to the use of SWPANEL.

The following Annexes, which further elaborate on essential aspects, also form an integral part of this Agreement:

Annex I: Non-payment, returns, and payment claims. Annex II: Confidentiality and Data Processing by Third Parties. Annex III: Data Protection Policy (GDPR – EU). Annex IV: California Consumer Privacy Rights (CCPA). Annex V: Compliance with other International Data Privacy Legislation. Annex VI: General Data Privacy Policy. Annex VII: Cookie Policy. Annex VIII: Corporate Legal Information (Legal Notice). Annex IX: Service Quality Guarantees and Service Level Agreement (SLA). Annex A: Additional Terms. Annex A: Annex X: Glossary of Terms and Concepts.

1. License 1.1.License Grant. Subject to your full and continued compliance with the terms and conditions of this Agreement, including, without limitation, payment of all applicable license fees, DeepThink, from whom you obtained SWPANEL, grants to you, and you accept, a personal, limited, non-exclusive, non-transferable (except as provided in Section 1.6 below), non-assignable, revocable license to use SWPANEL during the Term in machine-readable form, object code only, and the user manuals accompanying SWPANEL (the "Documentation"), only as authorized herein. revocable license to use SWPANEL during the Term in machine-readable, object code only format, and the user manuals accompanying SWPANEL (the "Documentation"), only as authorized in this Agreement. For purposes of this Agreement, SWPANEL includes any updates, enhancements, modifications, revisions, or additions to the Software made by DeepThink and made available to end users. Notwithstanding the foregoing, DeepThink shall have no obligation to provide updates, enhancements, modifications, revisions, or additions to the Software. DeepThink also reserves the right to vary, if it deems appropriate, the price of the SWPANEL license(s) after each revision, modification, or enhancement that is applied. 1.2.Scope of use. Your license to use SWPANEL is subject to the following license restrictions, and any use of SWPANEL that violates any of these restrictions or any of the other terms of this Agreement is a breach of this Agreement and is unauthorized. You may use one copy of SWPANEL activated by a license key on a single virtual or physical device owned, leased, or otherwise controlled by "the user" at any one time (the "Authorized Device"). If you have multiple license keys for SWPANEL, you may install and use as many copies of SWPANEL as you have license keys, in each case, on an Authorized Device and only as authorized herein. For purposes of this Agreement, "use" of SWPANEL means loading SWPANEL into the temporary or permanent memory of an Authorized Device. Installing SWPANEL on a network server solely for distribution to other computers is not "use" of SWPANEL and is permitted, provided that "the user" has a valid license key for each Authorized Device on which SWPANEL is installed. SWPANEL may not be used, distributed, or installed on more Devices than the number of license keys available to "the user." If you use or distribute SWPANEL to multiple users, you must ensure that the number of Authorized Devices does not exceed the number of license keys you have obtained, or you will be in breach of this Agreement and such use and distribution will be unlicensed. 1.3.Prohibited Use. DeepThink's SWPANEL may not be used for any illegal or fraudulent activity or action, including, but not limited to, spamming, phishing, spear phishing, spoofing, pharming, or any other type of scam or fraud. Any such activity or action is contrary to DeepThink's code of conduct and fair use policy. DeepThink reserves the right, in its sole and exclusive option and discretion, to take any action it reasonably deems necessary (including temporary or permanent termination of licenses and reporting to law enforcement authorities) to prevent illegal or fraudulent activities and actions (including cybercrimes) without any liability to "the user" or the registered license owner. 1.4.Additional Terms. Depending on the country in which you are located, additional terms and restrictions may apply, as set forth in Appendix A (the "Additional Terms"), the terms of which are incorporated by reference herein and form part of this Agreement. 1.5.Evaluation Licenses. If you have obtained a trial or evaluation version of SWPANEL, it will come with a trial activation key that activates SWPANEL for a limited period of time (the "Trial Period"). You may use SWPANEL during the Trial Period for internal, non-commercial purposes only to evaluate the suitability of SWPANEL for your needs. Upon expiration of the Trial Period, you must either purchase an activation key or destroy SWPANEL, the Documentation, all backups thereof, and all trial activation keys you have obtained. If you do not purchase an activation key before the expiration of the Trial Period, this Agreement and all your rights and licenses under it will terminate upon the expiration of the Trial Period. 1.6.Copies and modifications. Except and only to the extent that such restriction is prohibited by applicable law, you may not reverse engineer, decompile, disassemble, or otherwise translate SWPANEL or any license key you have obtained. You may not modify or adapt SWPANEL or the license keys you have obtained in any way. All copies of SWPANEL, the Documentation, or the license keys shall include the copyright notices or other proprietary notices that were included in such materials when you first received them. Except as authorized in this Section, neither you nor anyone under your authority or control may make copies of SWPANEL, the Documentation, or the license keys, or any part thereof. 1.7.Assignment of Rights. "The user" shall not sublicense, lease, rent, or lend its rights to SWPANEL, the Documentation, or the license keys, as granted by this Agreement, without the prior written consent of DeepThink, except that "the user" may transfer this Agreement in its entirety in connection with the sale of all or substantially all of the assets related to this Agreement, provided that the assignee assumes all of its obligations hereunder, and the licenses granted hereunder shall only extend to the use of SWPANEL on the Authorized Device on which SWPANEL was installed immediately prior to the transfer. DeepThink may assign this Agreement without limitation. Any assignment in violation of the foregoing shall be null and void. Subject to the foregoing, this Agreement shall bind and inure to the benefit of the parties and their respective successors and permitted assigns. 1.8.Support and Maintenance Services; Updates; Improvements. DeepThink will not provide any support or maintenance services under this Agreement. "The user" acknowledges that DeepThink has no express or implied obligation to announce or make available updates, enhancements, modifications, revisions, or additions to the Software and that this Agreement does not give you any rights in or to any of the foregoing. DeepThink may offer support and/or maintenance services separately. If "the user" has contracted support and/or maintenance services from DeepThink with SWPANEL, these services are provided under the terms and conditions accompanying the applicable service. Any supplemental software code or related materials provided by DeepThink as part of any support and/or maintenance service are considered part of SWPANEL and are subject to the terms and conditions of this Agreement. 1.9.Definitions of SWPANEL products and execution environments. For the purposes of interpreting this contract, a distinction is expressly made between the different modes of execution of SWPANEL, all of which are subject to the conditions set forth in this Agreement: 1.9.1.SWPANEL SaaS (https://go.swpanel.com): This refers to the SWPANEL mode offered by DeepThink as a cloud service (Software as a Service), accessible from any browser via the URL https://go.swpanel.com. This version does not require local installation by "the User" and its execution, maintenance, storage, and updates are managed exclusively by DeepThink from its own infrastructure. "The User" accesses this service by authenticating with their credentials and can manage the contracted services, license configurations, payments, support, and other administrative functions related to their SWPANEL environment from there. 1.9.2.SWPANEL Self-Hosted: This refers to the version of SWPANEL that is installed and run directly on servers or devices controlled by the User. This mode requires an active license and periodic validation with the SWPANEL SaaS platform (see clauses 4.6 and 4.7). "The User" is responsible for maintaining the operating environment, as well as the security of the system and the data managed within this version. This local installation is subject to the same license, intellectual property, confidentiality, and restricted use terms as the SaaS version, and may not be run without the corresponding license active and validated by DeepThink. 1.9.3.SWPANEL ecosystem applications: 1.9.3.1.SWPANEL InstantPass: Specific application developed by DeepThink that allows secure access management through single-use codes or additional validations. This tool acts as a complement to authentication and user management in SWPANEL environments (both SaaS and Self-Hosted). 1.9.3.2.SWPANEL for Mobile: Official mobile application of the SWPANEL ecosystem, available for iOS and Android platforms. It allows the User to manage various aspects of their SWPANEL account and services from mobile devices, including support, server control, monitoring, tickets, billing, and more, depending on the plan contracted.

2. Intellectual property and confidentiality. 2.1.Usage Reporting, License Violations, and Remedies. DeepThink reserves the right, and the "user" authorizes DeepThink, to collect data on the use of keys, including license key numbers, IP addresses of Authorized Devices or other applicable device identifiers (including MAC address or UDID), domain counts, users, and other information deemed relevant to ensure that our products are being used in accordance with the terms of this Agreement. DeepThink reserves the right to remedy violations of any of the terms of this Agreement immediately upon discovery by charging the then-current list price of the unauthorized keys to the payment instrument used to make the original and authorized purchase, or by any other means necessary, including remote deactivation of SWPANEL. "The user" agrees not to block, electronically or otherwise, the transmission of data necessary for the performance of this Agreement. Any blocking of data required for the performance of this Agreement is considered a breach of this Agreement and will result in the immediate termination of this Agreement in accordance with Section 4. 2.2.License expiration. Your license may include an expiration date that may result in the termination of the license. If your license key is stolen, or if "the user" suspects any misuse or illegal use of your license beyond your control, you must immediately notify DeepThink of such occurrence. A replacement license will be issued to you and the suspected license will be allowed to expire. For monthly subscription licenses, your monthly payment for each month must be processed prior to the expiration date in order for license updates to occur. For your convenience, DeepThink may, but is not obligated to, provide license expiration warnings in the product interface. It is your responsibility to contact DeepThink regarding any potential expiration that you deem inappropriate. DeepThink is not responsible for any damages or costs incurred in connection with expired licenses. For technical and fraud prevention reasons, licenses that do not report active use for a minimum of 12 months will be automatically suspended and will require replacement or reactivation. 2.3.SWPANEL and Associated and/or Registered Trademarks. "The user" acknowledges that SWPANEL and the Documentation are the property of DeepThink, and that SWPANEL and the Documentation are protected by copyright and other intellectual property laws and international treaties. Furthermore, "the user" acknowledges and agrees that, between "the user" and DeepThink, DeepThink and its third-party licensors own and will continue to own all rights, title, and interest in SWPANEL and the Documentation, including the associated intellectual property rights under copyright, trade secret, patent, or trademark laws. Except for the limited and revocable license expressly granted to you herein, this Agreement does not grant you any ownership or other rights or interest in or to SWPANEL or the Documentation or any other intellectual property rights of DeepThink, whether by implication, estoppel, or otherwise. All trademarks or service marks used by DeepThink in connection with SWPANEL or the services provided by DeepThink are trademarks owned by DeepThink. This Agreement does not grant you any rights, license, or interest in such trademarks, and you may not assert any rights, license, or interest in such trademarks or any words or designs that are confusingly similar to such trademarks. 2.4.Confidentiality. You shall only allow the use of SWPANEL or the viewing of the Documentation to authorized users who possess legitimately obtained license keys. Except as expressly authorized by this Agreement, "the user" shall not make SWPANEL, the Documentation, or any license key available to third parties, nor shall "the user" use SWPANEL, the Documentation, or any license key for any purpose other than the exercise of the rights expressly granted to "the user" in this Agreement. "The user" agrees to cooperate and assist DeepThink in identifying and preventing any unauthorized use, copying, or disclosure of SWPANEL, the Documentation, or any part thereof. 2.5.Consent to use of data. 2.5.1."The user" agrees that DeepThink may collect and use technical data and related information, including, but not limited to, technical information about your device, system and application software, and peripherals, that is gathered periodically to facilitate the provision of software updates, product support and other services to "the user" (if any) related to SWPANEL. 2.5. 2.DeepThink may use this information, provided that it is in a form that does not personally identify you, to operate, provide, improve, and develop our products, services, and technologies, to prevent or investigate fraudulent or inappropriate use of DeepThink's products, services, and technologies, for research and development, and for the other purposes described in this Agreement or to "the user" as part of our products and services. 2.5.3.In addition, "the user" agrees that DeepThink may collect the IP addresses of the servers on which a DeepThink product is installed. As this information may be considered personal data, DeepThink will handle it in accordance with DeepThink's Privacy Policy, available at www.swpanel.com/en/legal/rgpd, and will limit the use of this information to the prevention of fraudulent use of DeepThink products. Subject to your consent in accordance with applicable laws in your region, DeepThink's websites and online services may use "cookies," which allow you to personalize your experience on DeepThink sites and provide information to DeepThink, such as which websites have been visited and which advertisements and web searches are effective. If you wish to disable cookies, check your browser settings or refuse the use of cookies when entering DeepThink websites; you can find detailed information at www.swpanel.com/en/legal/cookies. 2.5.4.DeepThink may, for example, in order to provide technical support to "the user," in the course of your use of SWPANEL, supply or have access to information that may qualify as personal data in some or all jurisdictions (such as the administrator's email address). 2.5.5.By accepting this Agreement, "the user" agrees and acknowledges that DeepThink may collect, use, process, record, organize, accumulate, retain, update, extract, transfer (including cross-border transfer), access, depersonalize, block, or delete such personal data in the performance of its contractual duties (Art. 6.1(b) GDPR) and for general administrative purposes, and may also disclose personal data to its affiliates in its country of residence and abroad to the extent necessary for the performance of its duties under this Agreement and always in accordance with the provisions of applicable data protection laws in force (e.g., GDPR). In the event that a third-party product is resold or distributed by DeepThink, the third-party supplier in question may receive your license data for the purpose of entering into a license relationship with "the user" for its products or to provide adequate technical support to "the user" if necessary. 2.5.5.1.By implementing and maintaining sufficient technical and organizational measures, as required by applicable data protection laws, DeepThink ensures that your personal data is kept strictly confidential and sufficiently protected against further disclosure. 2.5.5.2."The user" may, at its sole option and discretion, at any time request DeepThink for information about the data collected or processed, as well as request the alteration, anonymization, or deletion or transfer of such data in accordance with its rights as a data subject. However, in some cases this may have delayed effects on the availability of other DeepThink services (e.g., support services). Please direct any requests related to data protection to [email protected]. 2.6.Audit Rights. During the term of this Agreement and for five (5) years after the termination or expiration of this Agreement, DeepThink may audit, upon written notice to "the user," its books, records, and computer devices to determine its compliance with this Agreement and its payment of applicable license fees, if any, to SWPANEL. In the event that such audit reveals an underpayment by "the user" of more than five percent (5%) of the license fees owed to DeepThink in the audited period, or that "the user" has breached any term of this Agreement, then, in addition to any other rights and remedies DeepThink may have, "the user" shall promptly pay DeepThink any insufficient payment plus the cost of the audit and all expenses incurred in connection therewith.

3. License Fees 3.1.Obtaining and Activating the License: SWPANEL will be available for use only after you receive one or more license keys. Such keys are obtained upon prior payment of the applicable fees, using the procedure set forth on the DeepThink website or on the website of an authorized distributor. 3.2.Payment and renewal terms: Licenses with specific terms require you to make payment before the contracted period begins. In addition, when renewing a term-based license, automatic billing may be made to the original payment method you used. Your license will automatically terminate without notice if you notify DeepThink in advance of your intention not to renew, or if you fail to make the renewal payment by the due date. 3.3.Refund policy: All payments made to obtain licenses are final. DeepThink will not issue refunds under any circumstances, except as expressly required by applicable law. By accepting this agreement, you understand and agree that after making payment, you waive any right or remedy to request a refund. 3.4.Conditions in case of downgrade: 3.4.1.If your license allows you to downgrade its category or duration, the adjusted rate will take effect on the first day of the next full calendar month after you make the change. 3.4.2. No refunds or pro-rated payments will be made for unused periods or for the use and resources associated with the license to which the downgrade has been applied. 3.5. Right of termination for misuse: DeepThink reserves the unilateral right to terminate your license without compensation if it detects unusual, suspicious, or potentially abusive use related to category or term change options (downgrade/upgrade). 3.6.Revocation of the Right of Withdrawal Given that SWPANEL is customized software, adapted and activated specifically according to the needs of "the user," "the user" expressly acknowledges and accepts that, once the software has been activated or delivered through personalized license keys, they will automatically lose the right of withdrawal provided for in European regulations. This exception to the right of withdrawal is based on the provisions of Article 16(m) of Directive 2011/83/EU of the European Parliament and of the Council of October 25, 2011, on consumer rights, as well as its transposition into Spanish law in Article 103. m of Royal Legislative Decree 1/2007, which approves the General Law for the Protection of Consumers and Users and other complementary laws. 3.6.1.By accepting this contract, you declare that you have been clearly informed about this exception and expressly waive the right of withdrawal from the moment you start using SWPANEL through the personalized activation of your license.

4. Term and termination 4.1.Start and duration of the Agreement: The Agreement comes into force from the moment you accept it or from the moment you download, install, access, or use SWPANEL, even if you have not formally accepted it. This Agreement shall remain in force until its expiration or termination, as specified in the Agreement itself. 4.2.Expiration of fixed-term licenses: Licenses that have a predefined term will automatically expire at the end of the prepaid period, unless you make the appropriate payments to renew or extend the term. 4.3.Automatic termination for breach: DeepThink may terminate this Agreement immediately and without prior notice if you breach any of the limitations or requirements described herein, including the payment of applicable fees. In such cases, you agree that DeepThink has the additional right to remotely deactivate SWPANEL, without prejudice to any other legal actions it may take. 4.4.Voluntary termination by "the user": You have the right to voluntarily terminate the Agreement at any time. To do so, you must notify DeepThink of your decision, requesting the cancellation of the license(s) for your Device(s) through the "user" account on the SWPANEL website at go.swpanel.com. 4.4.1.Upon requesting the cancellation of the license, SWPANEL will cease to be operational on your Device. 4.4.2.As a user of SWPANEL SaaS (the website go.swpanel.com), you will always have access to it and will be able to continue managing other licenses if you have them. The website go.swpanel.com will continue to maintain the "user" account active with a record of all history for at least a period of 10 years of inactivity. 4.5.Obligations after termination or expiration of the Agreement: Once this Agreement has been terminated or has expired for any reason, you expressly agree to: 4.5.1.Uninstall SWPANEL from your Device(s). 4.5.2.Return to DeepThink SWPANEL all associated documentation, existing copies, and license keys you have received. 4.5.3.If you do not return these materials, you must destroy them completely and provide DeepThink with written confirmation certifying that such destruction has been carried out. 4.6.Cancellation of the license and termination of services. In the event of cancellation, expiration, or termination of the SWPANEL license for any reason, "the User" expressly agrees and acknowledges that all services, features, resources, and tools provided by SWPANEL that are installed, configured, or running on their Device will immediately cease to be operational. These services can only operate under a valid, active, and properly validated license. Once the license is canceled or expires, "the User" will automatically lose the right to use any component of SWPANEL, and all associated software will cease to operate without further notice. 4.6.1.The SWPANEL license requires periodic and continuous online validation, performed through the SWPANEL SaaS platform (accessible from https://go.swpanel.com). If this validation does not occur, whether due to a connection failure, revocation of the license, or any other cause, the software and all associated tools on the "User's" Device will be automatically deactivated. 4.6.2.No functionality, service, tool, or resource provided by SWPANEL is designed to operate without a valid, active, and correctly verified license. Therefore, it is expressly stated that the existence of an active license is an essential requirement for the technical functionality of the software. 4.6.3.SWPANEL incorporates automatic mechanisms for constant verification of the license status. If any irregularity is detected, such as expiry, revocation, non-payment or cancellation of the license, the system will automatically proceed to the total and immediate deactivation of all the software's functionalities. For more information, "the User" may consult the provisions of Annex I: Non-Payments, Returns and Payment Claims. 4.7.Suspension of service due to non-payment. In the event that "the User" fails to pay for the license or its renewal for any Device on which SWPANEL is installed, the software will be automatically blocked as a precautionary measure until the payment situation is regularized. This measure is immediate, irrevocable while the non-payment persists, and necessary to ensure the legality of the use of the software. 4.7.1.During the suspension period, "the User" will not be able to access or use SWPANEL on any of the devices on which it is installed. This restriction will remain in effect until "the User" has paid the outstanding amounts in full. DeepThink will make the SWPANEL SaaS platform (https://go.swpanel.com) available to "the User," where they can check their status, issue invoices, and make payments using the enabled methods. 4.7.2."The User" declares that they have been informed of and expressly accept this condition. Likewise, they exempt DeepThink from any liability, damage, loss, or claim arising from the suspension of the service due to non-payment. "The User" acknowledges that this situation is a direct consequence of their breach of the financial obligations assumed in this contract, and undertakes to hold DeepThink harmless against any action, claim, or damage that may arise from this cause.

5. Indemnification 5.1.Indemnification obligation. "The User" expressly agrees to indemnify, defend, and hold harmless DeepThink, as well as its officers, directors, employees, representatives, subsidiaries, and business partners, from any claim, demand, legal action, judicial or extrajudicial proceeding, damage, loss, penalty, fine, harm, or liability of any nature, including those arising from: 5.1.1.The improper, unlawful, or unauthorized use of SWPANEL or any of its components (in any of its versions: SaaS, Self-Hosted, mobile applications, etc.); 5.1.2.The violation of the terms of this Agreement or any of its Annexes; 5.1.3. Failure to comply with any applicable law, regulation, rule or provision, whether national or international; 5.1.4. Infringement of third-party rights, including, but not limited to, intellectual property rights, privacy, data protection, trade secrets or trademarks; 5.1.5.Any action, omission, or negligence on the part of "the User," its employees, agents, suppliers, subcontractors, or any third party accessing SWPANEL under its account, control, or authorization. 5.2.Scope of indemnification. The indemnification obligation includes, but is not limited to: 5.2.1.Reimbursement of all reasonable costs incurred by DeepThink for its legal defense, including attorneys' fees, court costs, expert witness fees, and other professional expenses; 5.2.2.Compensation for any direct or indirect damage caused to DeepThink or third parties; 5.2.3.Payment of any fines, penalties, or compensation arising from administrative or judicial decisions. 5.3.Conditions of defense. DeepThink reserves the right, at its sole discretion, to assume the exclusive defense and control of any matter subject to indemnification by the User. In such a case, the User agrees to cooperate fully and diligently with DeepThink in the preparation of the defense and in providing any necessary evidence, documentation, or testimony. The User may not enter into any out-of-court settlements or accept any liability on behalf of DeepThink without the prior express written consent of DeepThink. 5.4.Duration of the obligation. The indemnification obligation shall remain in effect even after the termination, resolution, or expiration of this Agreement, as long as the claims arise from events that occurred during its term.

6. Third-Party Software 6.1.Definition and scope of Third-Party SWPANEL: SWPANEL may contain components or services from third parties ("Third-Party Software"), which together with the main SWPANEL are referred to as the "Package." These components are subject to specific and different terms ("Third-Party Terms"). 6.2.Information about third-party terms: Details about these specific terms are indicated in the "Notices.txt" file included in the documentation provided (if applicable). Additionally, this information is also available on the official website: www.swpanel.com. 6.3.Use of Third-Party SWPANEL: You may use Third-Party SWPANEL included in the Package provided that such use complies with and is consistent with the terms of this Agreement. However, you may have additional rights under the Third-Party SWPANEL's own license terms. 6.4.No imposition of additional restrictions: This Agreement does not intend to impose additional limitations or restrictions on the use of Third-Party SWPANEL beyond those set forth in its own specific terms and conditions. 6.5.Compatibility and interoperability: The SWPANEL provided may allow interoperability with third-party operating systems or applications.

7. Limited warranty, disclaimer, and limitation of liability 7.1.Limited warranty: DeepThink warrants that it has the necessary rights to grant the license for SWPANEL and that the software will perform substantially in accordance with the official documentation for a minimum period of 90 days from the date of purchase. 7.2.Disclaimer of Warranties: Except for the limited warranty set forth above in Section 7.1, DeepThink provides SWPANEL and its documentation "as is," without any other warranties of any kind. DeepThink makes no other express, implied, or statutory warranties, including, without limitation, warranties of merchantability, satisfactory quality, fitness for a particular purpose, accuracy, timeliness, title, or non-infringement of third-party rights. DeepThink also does not warrant that SWPANEL will meet all of the "user's" expectations or that its operation will be uninterrupted, timely, secure, or error-free. Furthermore, DeepThink does not warrant that all errors in the software will be corrected, nor does it guarantee compatibility with future DeepThink products. "The user" assumes all risk regarding the selection, quality, performance, and results of the use of SWPANEL, including the possible loss, corruption, or destruction of data stored or transmitted through the software. 7.3.Limitation of Liability: DeepThink shall not be liable to "the user" or any third party related to "the user" for any indirect, incidental, consequential, special, or punitive damages, including, without limitation, loss of profits, business interruption, loss of business information, loss or corruption of data, or other financial losses. This limitation applies regardless of whether the claim is based on an Agreement, warranty, civil liability (including negligence) or any other legal theory, even if DeepThink has been previously informed of the possibility of such damages. In no event shall DeepThink's total cumulative liability arising out of any claim related to this Agreement exceed the total amount paid by "the user" for the SWPANEL license during the twelve months prior to the incident giving rise to the claim. These limitations shall apply even if any remedy provided fails of its essential purpose. 7.4.Legal exceptions: Some jurisdictions may not allow the exclusion or limitation of certain warranties or liabilities. In such specific cases, the limitations and exclusions provided in this section shall apply to the maximum extent permitted by the applicable law in such jurisdiction.

8. General Conditions 8.1.Feedback. If "the user" provides any ideas, comments, suggestions, materials, information, opinions, or other input to DeepThink ("Feedback"), regardless of any accompanying communication, DeepThink has no obligation to review, consider, or implement your Feedback, all such submissions are made on a non-confidential basis, DeepThink and its successors and assigns have the unconditional and unlimited right to use, reproduce, modify, and disclose such feedback without any compensation or attribution, and "the user" waives and agrees not to assert any so-called "moral rights" that they may have in the feedback. 8.2.Applicable law and choice of forum. This Agreement shall be governed by and construed in accordance with the laws of Spain, without regard to its conflict of law provisions. Any claim or dispute arising out of or in connection with this Agreement shall be resolved in the applicable courts located in Girona, Spain. To the fullest extent permitted by law, "the user" hereby accepts the jurisdiction and venue of such courts and waives any objection to the jurisdiction or venue of such courts. This Agreement shall not be governed by the United Nations Convention on Contracts for the International Sale of Goods, the application of which is expressly excluded. 8.3.Severability. If any term or provision of this Agreement is held by any judicial or administrative authority to be invalid or unenforceable in any particular situation, such holding shall not affect the validity or enforceability of the remaining terms and provisions of this Agreement or the validity or enforceability of the offending term or provision in any other situation. To the extent possible, the provision shall be interpreted and applied to the greatest extent legally permissible to effect the original intent, and if such interpretation or application is not legally permissible, it shall be deemed severable from the Agreement. 8.4.Survival. Articles 2, 5, 7, and 8 of this Agreement and all of its Sections shall survive the termination or expiration of this Agreement, regardless of the cause of termination or expiration, and shall remain valid and binding indefinitely. 8.5.Headings. The headings of the Articles and Sections contained in this Agreement are included for reference purposes only and shall not affect the meaning or interpretation thereof. 8.6.No waiver. The failure of either party to enforce any rights granted hereunder or to take action against the other party in the event of a breach hereunder shall not be deemed a waiver by such party as to subsequent enforcement of rights or subsequent actions in the event of future breaches. 8.7.Modification. DeepThink reserves the right, in its sole discretion, to modify this Agreement from time to time by posting an updated version of the Agreement at www.swpanel.com, provided that disputes arising under this Agreement shall be resolved in accordance with the terms of the Agreement in effect at the time the dispute arose. We recommend that you review the posted Agreement from time to time to be aware of any changes. Substantial changes to these terms will become effective upon (i) your first use of SWPANEL with actual knowledge of such change, or (ii) 30 days after the modified Agreement is posted at www.swpanel.com, whichever occurs first. In the event of a conflict between this Agreement and the most recent version of this Agreement posted at www.swpanel.com, the most recent version will prevail. The use of SWPANEL by "the user" after the effective date of the amended Agreement constitutes "the user's" acceptance of the amended Agreement. If you do not agree to the changes made to SWPANEL, it is your responsibility to terminate this Agreement in accordance with Section 4. 8.8.Taxes. "The user" shall, in addition to the license fees required under this Agreement, pay all applicable sales, use, transfer, or other taxes and all duties, whether national, state, or local, however designated, that are collected or imposed in connection with the transaction contemplated by this Agreement, excluding income taxes on DeepThink's net profits. "User" shall reimburse DeepThink for the amount of such taxes or duties paid or incurred directly by DeepThink as a result of this transaction, and ‘User’ agrees that DeepThink may charge such reimbursable taxes to the payment instrument used for its initial payment. 8.9.Export Controls. "The user" may not use, export, re-export, import, sell, or transfer SWPANEL except as authorized by the laws of the jurisdiction in which you obtained SWPANEL and by any other applicable laws and regulations. "The user" represents and warrants that (i) they are not located in a country subject to international embargo or designated by a European government or the US government as a ‘terrorist-supporting’ country; and (ii) they are not listed on any prohibited or restricted party list of the European, US, or Japanese government. You also acknowledge that SWPANEL may be subject to other European, US, or Japanese laws and regulations governing the export of software by physical and electronic means. "You" agree to comply with all European, US, and Japanese laws applicable to DeepThink, as well as any end-user, end-use, and destination restrictions imposed by the European, US, or Japanese governments. "The user" also agrees not to use SWPANEL for any purpose prohibited by the laws of Europe, the US, or Japan, including, without limitation, the development, design, manufacture, or production of nuclear missiles or any form of weapons. 8.10.US Government Rights of Use. SWPANEL and any related technical data, including manuals and documentation, are considered commercial items as defined in the US Federal Acquisition Regulation (FAR) 2.101. In the event that SWPANEL is acquired by or on behalf of an agency, department or entity belonging to the United States Government ("Government"), the use, duplication, reproduction, distribution, modification, disclosure or transfer of the software and related technical data shall be expressly restricted in accordance with the terms and conditions specified in this agreement and as provided in FAR 12. 212 for civilian agencies and Defense Federal Acquisition Regulation Supplement (DFARS) 227.7202 for military agencies. Any use not expressly contemplated in this agreement is strictly prohibited.

Appendix I: Non-payments, refunds, and payment claims

1.Definitions: 1.1.Non-payment: Failure to pay any invoice corresponding to the SWPANEL license or its renewals within the established period is considered non-payment. 1.2.Payment refund: This refers to the reversal of payment due to disputes, claims or insufficient funds after the charge has been processed. 1.3.Claim or dispute: Process initiated by "the user" or cardholder with the financial institution or payment platform (PayPal, Stripe, Visa, etc.) to reverse or question an authorized charge.

2.DeepThink's actions in the event of non-payment, refunds, or claims: 2.1.Non-payments: Immediate blocking of the license(s) associated with the "user's" account and suspension of services until the debt is paid in full. 2.2.Returns: Immediate blocking of the license(s) associated with the "user" account and suspension of services until the incident is resolved and the amounts owed are paid. 2.3.Claims (payment disputes): 2.3.a.Temporary precautionary blocking of the license(s) associated with the "user" account while the dispute is being processed. 2.3.b.Suspension of related services: all services linked to the license(s) associated with the "user" account will be suspended until the claim is finally resolved. 2.3.c.Preventive blocking of all active licenses of the "user" involved, in order to prevent possible risks while the dispute is being investigated.

3.Responsibilities of the "user": 3.1.Proactive communication: "The user" undertakes to notify DeepThink in advance of any problem that could affect the timely payment of invoices, in order to seek a solution and avoid automatic blocking actions. 3.2.Cooperation in resolution: "The user" shall actively cooperate with DeepThink and/or the payment entity in the resolution of disputes or claims, providing any information necessary to clarify the situation. Failure to cooperate may result in the blocking measures being maintained until the incident has been fully clarified.

Note: The measures described in this annex seek to protect the sustainability of the service and the users themselves from possible fraud. DeepThink may, at its discretion, reverse the blocking actions once the non-payment situation has been resolved or the dispute has been clarified, restoring the services and licenses as soon as feasible. Restoration times may vary depending on the form of resolution (e.g., confirmation of payment by the bank). Likewise, DeepThink may charge a fee for both blocking and unblocking the "user's" account and pass on all costs arising from non-payment or dispute processes that have been charged or deducted from DeepThink.

Annex II: Confidentiality and Data Processing by Third Parties

1.Confidentiality commitment: DeepThink undertakes to treat as confidential all information and data (including personal data) to which it has access by virtue of the provision of SWPANEL. This confidentiality obligation extends to all DeepThink employees, collaborators, and subprocessors involved in the processing of such data. DeepThink will not disclose any confidential "User" information to third parties, except with the express consent of the User, legal obligation, administrative or judicial order, or if such information was already public at the time of disclosure without breach of this Agreement.

2.Use of subprocessors: "The User" authorizes DeepThink to use third-party processors (subprocessors) to perform the functions necessary for the provision of SWPANEL (e.g., hosting or data replication services, analysis tools, technical support, etc.), provided that DeepThink imposes on such subprocessors contractual obligations regarding data protection and confidentiality equivalent to those set forth in this Agreement. DeepThink will keep an updated list of its subprocessors available to "the User" upon written request. In any case, DeepThink will remain liable to "the User" for compliance with the obligations assumed in relation to data protection, even when the processing is carried out by such subprocessors.

3.International data transfers: In the event that DeepThink or its subprocessors must transfer personal data "of the User" to countries outside the European Economic Area or other jurisdictions of origin of the data, DeepThink guarantees that it will only make such transfers when the appropriate safeguards required by data protection regulations are in place. This may include transfer to jurisdictions with a recognized adequacy decision, the signing of standard contractual clauses approved by the European Commission or another competent authority, or the implementation of approved binding corporate rules. DeepThink will inform the User, upon request, about international data transfers affecting their data and the safeguards applied.

4.Technical and organizational measures: DeepThink declares that it has the appropriate technical and organizational measures in place to ensure a level of security appropriate to the risk involved in the processing of the "User's" data. These measures include, among others, restricted access controls to personal information, encryption of sensitive data in communications and storage where applicable, backup and recovery procedures, processing activity logs, internal data protection policies, and regular training of its personnel on privacy and information security. DeepThink reviews and updates these measures regularly to adapt to evolving risks and current regulations.

5.Data retention and deletion: DeepThink will process the "User's" personal data only for as long as necessary to fulfill SWPANEL's contractual purposes or the corresponding legal requirements. Once the contractual relationship with the "User" has ended, or at the express request of the "User," DeepThink will cease processing the "User's" personal data, except to the extent necessary to keep it blocked during the legal limitation periods for possible liabilities. After this period, DeepThink will proceed to the secure deletion or irreversible anonymization of the personal data of the User, as appropriate.

Annex III: Data Protection Policy (GDPR – EU)

This annex regulates the processing of personal data in accordance with Regulation (EU) 2016/679 of April 27, 2016 (GDPR) and Spanish Organic Law 3/2018, of December 5 (LOPDGDD), applicable to personal data provided by the User or collected by DeepThink in the context of the use of SWPANEL, in any of its versions (SaaS, Self-Hosted or mobile).

1.Data controller The data controller responsible for the processing of the User's personal data is: DeepThink Software SLu Calle Ponent 13-15, 17458 Fornells de la Selva, Girona, Spain Email: [email protected]

2.Purposes of the processing DeepThink will process the User's personal data for the following legitimate purposes: 2.1.To provide SWPANEL services, including user account management, authentication, technical support, billing, and maintenance of services. 2.2.To prevent fraud, ensure system security, monitor the proper use of the platform, and detect irregular or illegal activities. 2.3.To develop and improve SWPANEL's functionalities, evaluate the use of tools, and introduce improvements based on technical or statistical analysis (in an anonymized or aggregated form whenever possible). 2.4.To comply with legal and regulatory obligations applicable to DeepThink, such as accounting, tax, cybersecurity, and data protection regulations. 2.5.Send the User, where appropriate, electronic commercial communications or direct marketing relating to products or services of DeepThink or the Prime Partners group, always related to or compatible with the services contracted, based on their legitimate interest or consent, when required. 2.6.Share certain personal data with other companies in the Prime Quad Partners SL business group (hereinafter, "Prime Partners"), of which DeepThink is a member, for the following specific purposes: 2.6.1.To improve the commercial relationship and customer service. 2.6.2.To offer complementary or escalated technical support, when necessary. 2.6.3.To present products or services that are integrable, related, or complementary to SWPANEL that may be of interest to the User. 2.6.4.To guarantee the operational continuity of the service, inter-company assistance, and incident tracking, always under the principles of data minimization and confidentiality. These transfers of data between companies within the group are carried out on the basis of legitimate interest (Art. 6.1.f GDPR) and never involve incompatible, unreported or infringing purposes that violate the User's rights.

3.Legal basis for processing. The bases that legitimize DeepThink for the processing of the User's personal data are: 3.1.Execution of the contract: processing necessary for the provision of the services contracted by the User (art. 6.1.b GDPR). 3.2.Legal compliance: DeepThink's obligation to comply with applicable regulations (Art. 6.1.c GDPR). 3.3.Legitimate interest: to ensure security, quality of service, internal control, and continuous improvement, as well as communications about similar products or services of our own or those of the Prime Partners group (Art. 6.1.f GDPR). 3.4.Consent: in cases where required by law, such as in electronic communications where there is no prior contractual relationship or for the use of non-essential cookies (see Annex VII).

4.Transfer and disclosure of personal data 4.1.The User's personal data may be disclosed to third parties exclusively in the following cases: 4.1.1.To service providers contracted by DeepThink (e.g., payment platforms, hosting services, external technical support), under data processor contracts in accordance with Article 28 of the GDPR. 4.1.2.To administrative, fiscal, or judicial authorities when legally required. 4.1.3.To companies in the Prime Partners group, as indicated in section 2.6 of this annex, under inter-company contracts of shared responsibility or processing orders, depending on the purpose and nature of the exchange. 4.2.In the event of international transfers outside the European Economic Area (EEA), DeepThink will ensure compliance with the GDPR through: 4.2.a.Standard contractual clauses (SCCs) approved by the European Commission. 4.2.b.Binding corporate rules (BCRs). 4.2.c.Recognized adequacy mechanisms or, failing that, explicit consent of the data subject where necessary.

5.Rights of the data subject As the owner of their personal data, Users may exercise the rights recognized by the GDPR: 5.1.Access: to know what personal data is being processed and to obtain a copy. 5.2.Rectification: to correct errors or update inaccurate data. 5.3.Deletion (right to be forgotten): delete data when it is no longer necessary or there is a legal reason to do so. 5.4.Restriction of processing: temporarily suspend the use of data in certain circumstances. 5.5.Portability: receive your data in an interoperable format and transfer it to another controller. 5.6.Objection: refuse processing based on legitimate interest or for direct marketing purposes. Users may exercise these rights free of charge by contacting DeepThink via email at [email protected] You must identify yourself properly and indicate the right you wish to exercise. DeepThink may request additional information to verify the identity of the applicant. If you are a registered User, you can access, rectify, or delete part of your data directly from your private area in SWPANEL.

6.Data Protection Officer (DPO) DeepThink is not currently required to appoint a Data Protection Officer under the GDPR. However, it has a team responsible for privacy compliance, which handles queries or requests via email at [email protected] If a DPO is appointed in the future, Users will be duly informed.

7.Additional information and transparency DeepThink provides Users with the information required by Articles 13 and 14 of the GDPR at the time of data collection, whether in forms, registration processes, contracts, or contact. Any substantial change in the purposes of the processing or in the data shared will be notified to the User, and when legally required, their consent will be requested again.

8.Complaints to the Supervisory Authority Users have the right to lodge a complaint with the Spanish Data Protection Agency (AEPD) or another competent authority in their country of residence. However, DeepThink recommends resolving any incidents amicably by contacting its privacy department directly.

Appendix IV: California Consumer Privacy Rights (CCPA)

This addendum details the privacy rights applicable to Users residing in the state of California (USA), in accordance with the California Consumer Privacy Act (CCPA) and, where applicable, the California Privacy Rights Act (CPRA). To the extent that DeepThink acts as a "business" under the CCPA with respect to the personal data of California consumers, it guarantees full compliance with the regulations, offering the guarantees and rights listed below:

1.Categories of personal information collected 1.1.DeepThink may collect the following categories of personal information from California consumers: 1.1.a.Identifiers (name, email address, postal address, phone number, account ID). 1.1.b.Commercial information (history of services purchased, payments, billing). 1.1.c.Information about activity on the Internet or other electronic networks (access logs, IP addresses, cookies, browser). 1.1.dProfessional or employment information (when the User registers on behalf of a company). 1.2.This information is obtained directly from the User (for example, when registering or using the service), as well as indirectly through automatic interaction with the SWPANEL platform.

2.Purpose of the use of personal information 2.1.The personal information collected is used to: 2.1.a.Provide and maintain the contracted services (account management, payment processing, support). 2.1.b.Personalize the User's experience and improve the functionality of the service. 2.1.c.Ensure the security and integrity of SWPANEL (incident detection, debugging, fraud prevention). 2.1.d.Comply with applicable legal or regulatory obligations. 2.1.e.Send service or marketing communications (with prior consent, when required). 2.2.DeepThink will not use personal information for purposes other than those described herein, except upon prior notification and obtaining consent, when legally required.

3.Disclosure of personal information to third parties 3.1.DeepThink may disclose personal information to third parties, exclusively in the following cases: 3.1.a.To service providers contracted for specific functions (hosting, payments, analytics, technical support), who are prohibited from using the data for purposes other than those agreed upon in the contract. 3.1.b.To public or regulatory authorities, when required by law or valid court order. 3.1.c.To other companies in the Prime Quad Partners SL business group (hereinafter, "Prime Partners"), of which DeepThink is a member, only in the following legitimate cases: 3.1.1.To improve the commercial relationship with the User and optimize communication and support channels. 3.1.2.To provide additional or specialized technical support related to the use of SWPANEL. 3.1.3.To offer complementary products or services that may be integrated or useful to the User, always within the framework of legitimate interest or applicable consent. 3.2.These group companies are contractually obliged to process personal data in accordance with applicable law and may not sell, reuse or process the data for purposes other than those permitted by this Annex.

4.No sale of personal information 4.1.DeepThink declares that it does not sell personal information of California consumers, as defined by "sale" in the CCPA, nor does it receive direct or indirect financial compensation for sharing it with non-provider third parties. 4.2.Personal information is also not shared with external third parties in terms that constitute a "sale" of data under California law. 4.3.In the event that this policy changes in the future, DeepThink will: 4.3.a.Notify the User expressly. 4.3.b.Enable an opt-out mechanism, including a visible link on the website ("Do not sell my personal information"). 4.3.c.Respect global preference signals (such as Global Privacy Control) if required by applicable law.

5.Consumer rights under the CCPA California consumers have the following rights: 5.1.Right to know (access): The User has the right to request what personal data DeepThink has collected about them in the last 12 months, including the categories, sources, uses, third parties with whom it is shared, and the specific data collected. 5.2.Right to deletion: The User may request the deletion of their personal data, unless there is a legal exception to retain it (such as to fulfill a contract, legal obligation, or legitimate security interest). 5.3.Right to opt out of data sales: Not currently applicable. It will apply if any "sale" of personal data occurs under the CCPA in the future. 5.4.Right to non-discrimination: DeepThink will not discriminate against or penalize the User for exercising their rights. There will be no changes in prices, quality of service, or conditions for exercising access, deletion, or opposition, unless expressly permitted by law.

6.Exercising rights 6.1.To exercise their rights under the CCPA, the User (or their authorized representative) may contact DeepThink: 6.1.a.By sending an email to: [email protected] 6.1.b.Indicating in the subject line: "CCPA Request" 6.1.c.Clearly describing the request (access, deletion, etc.) 6.2.DeepThink may require verification of the identity of the applicant before processing the request, by means of: 6.2.a.Confirmation of existing data in your account. 6.2.b.Documentary proof, in the case of authorized representatives. 6.3.The response time will be up to 45 days, extendable once for an additional 45 days upon notification to the User.

7.Additional rules 7.1.If the User benefits from additional state privacy laws, DeepThink undertakes to comply with them to the extent that they are applicable, without contravening current federal or state regulations. 7.2.DeepThink may update this Annex to adapt to future legal reforms in California, such as the evolution of the CCPA or the entry into force of new similar laws in other states (Colorado, Virginia, etc.).

Annex V: Compliance with Other International Data Privacy Laws

In addition to the provisions of Annex III (Data Protection Policy (GDPR – EU)) and Annex IV (California Consumer Privacy Rights (CCPA)), DeepThink undertakes to respect and comply with the personal data protection laws applicable in other relevant jurisdictions where it may provide services or have Users. These obligations apply without prejudice to DeepThink's membership of the Prime Quad Partners SL ("Prime Partners") business group, which includes various entities specializing in digital technology and services.

In this context, DeepThink may exchange User personal information with other companies in the group only in the cases provided for by applicable law, and always in accordance with the confidentiality, data protection, and contractual guarantees provided for in Annexes II, III, IV, and V.

The main legal frameworks of reference and how DeepThink ensures compliance are described below:

1.Brazil (Lei Geral de Proteção de Dados - LGPD) 1.1.In the event that the LGPD (Law No. 13,709/2018) is applicable, DeepThink guarantees: 1.1.1.Compliance with the principles of purpose, necessity, transparency, security, non-discrimination, and accountability. 1.1.2.Respect for the rights of Brazilian data subjects: access, rectification, cancellation, opposition, portability, information about sharing, and revocation of consent. 1.1.3.The handling of requests through the contact channel [email protected], respecting the deadlines and procedures set forth in the LGPD. 1.1.4.In the event of international data transfers from Brazil, DeepThink will adopt appropriate legal mechanisms (such as standard contractual clauses or binding corporate rules) to ensure an adequate level of protection. 1.2.The exchange of data between companies in the Prime Partners group will also be subject to these guarantees and will be limited to the legitimate and explicit purposes informed to the data subject.

2.Canada (Personal Information Protection and Electronic Documents Act - PIPEDA) 2.1.For Users located in Canada, DeepThink acts in accordance with the Ten Privacy Principles established by PIPEDA, including: 2.1.1.Accountability: DeepThink is responsible for the data under its control and adopts internal compliance policies. 2.1.2.Identification of purposes before collecting personal data. 2.1.3.Informed consent when required. 2.1.4.Limitation of collection, use, and retention to the legitimate purposes disclosed. 2.1.5.Accuracy and security of data through appropriate technical and organizational measures. 2.1.6.Transparency and individual access, including mechanisms for challenging compliance and filing complaints. 2.2.Any transfer of personal data to other Prime Partners group companies within Canada or from Canada to other jurisdictions will be carried out in accordance with the principle of accountability and will require appropriate contractual safeguards, in accordance with PIPEDA.

3.Japan (Act on the Protection of Personal Information - APPI) 3.1.DeepThink guarantees compliance with the Japanese Personal Information Protection Act (APPI) in the following aspects: 3.1.1.Prior and clear notification of the purpose of use of personal data. 3.1.2.Obtaining consent when legally required, especially for special categories of personal data. 3.1.3.Prohibition of transfer to third parties without consent, except for legal exceptions (e.g., use by subprocessors under contract). 3.1.4.Response to requests for access, correction, suspension, or deletion of data by the data subject. 3.2.In the event of international transfers, DeepThink will ensure that the recipient (even if part of the Prime Partners group) has an equivalent level of protection to that required by the APPI, either through explicit consent or contracts incorporating appropriate clauses.

4.Other relevant jurisdictions 4.1.DeepThink seeks to comply with the fundamental privacy principles of other jurisdictions, including: 4.1.1.United Kingdom: Compliance with the UK GDPR and the Data Protection Act 2018, on an equal footing with the GDPR. 4.1.2.EEA States: Compliance with local legislation that supplements the GDPR (e.g., requirements regarding explicit consent or processing records). 4.1.3.United States (outside California): DeepThink adopts practices compatible with emerging state laws (Colorado, Virginia, Connecticut, Utah, etc.), offering rights similar to those provided under the CCPA where reasonable and applicable. 4.2.DeepThink also respects the principles of the APEC Cross-Border Privacy Rules (CBPR) for its operations in the Asia-Pacific region, to the extent of its participation in those markets.

5.Data sharing within the business group 5.1.In all cases, if DeepThink shares User personal data with other companies in the Prime Partners group, it will ensure that: 5.1.1.It has a valid legal basis for such communication, whether it be legitimate interest, contractual compliance, or consent, in accordance with applicable law. 5.1.2.Establish appropriate inter-company contracts that clearly define the purposes, responsibilities, and protective measures. 5.1.3.Ensure that the transfer of data does not involve a sale of data or entail uses not disclosed to the User. 5.2.Such transfers shall be limited to the purposes already communicated to the User in Annexes III (Data Protection Policy (GDPR – EU)), Annex IV (California Consumer Privacy Rights (CCPA)), Annex V (Compliance with other International Data Privacy Legislation) and Annex VI (General Data Privacy Policy), including: 5.2.a.Provision of specialized technical support. 5.2.b.Improvement of the User experience. 5.2.c.Proposal of complementary technological services.

6.Commitment to continuous improvement and transparency 6.1.DeepThink actively monitors international legislative changes and adapts its privacy policies and practices to maintain a consistent and high level of regulatory compliance. 6.2.If any national or sectoral law applicable to a User grants more rights or requires greater guarantees than those provided in this annex, DeepThink will act in accordance with the principle of maximum protection. 6.3.The User may consult DeepThink about the processing of their data in their specific country and exercise their rights by emailing [email protected].

Annex VI: General Data Privacy Policy

1.Privacy commitment and scope 1.1.DeepThink Software SLU (hereinafter, "DeepThink"), as the owner of the rights to the SWPANEL software, declares its firm commitment to protecting the privacy and security of the personal data of all Users, regardless of their country of residence or establishment. 1.2.This annex sets out DeepThink's general practices regarding the collection, use, storage, retention, transfer, communication, and protection of personal data in the context of the use of any of the SWPANEL modalities (SaaS, Self-Hosted, or mobile applications). 1.3.These practices apply globally, subject to the specific annexes that set out the particular requirements of each jurisdiction: 1.3.a.Annex III: Data Protection Policy (GDPR – EU). 1.3.b.Annex IV: California Consumer Privacy Rights (CCPA). 1.3.c.Annex V: Compliance with other International Data Privacy Legislation. 1.4.In the event of a conflict between the provisions of this Annex VI and the provisions of the aforementioned annexes, the strictest or most protective regulations for the User shall always prevail.

2.Organizational context and communications within the business group 2.1.DeepThink is part of the business group Prime Quad Partners SL (hereinafter, "Prime Partners"), made up of several companies specializing in technology services, IT infrastructure, and digital solutions. 2.2.DeepThink may share certain personal data of the User with other companies in the group, only when such communication: 2.2.1.Is necessary and legitimate for the fulfillment of the contract with the User. 2.2.2.Contributes to improving the quality of the service or attention provided. 2.2.3. Allows the offering of complementary products or services that may be integrated or useful to the User. 2.2.4. Facilitates second or third level technical support, especially in situations requiring specialized or multi-component intervention. 2.2.5. Results in the improvement of the user experience through advice, integration, or additional services compatible with SWPANEL. 2.3.These communications will be made exclusively between entities contractually linked within the Prime Partners group, under confidentiality and data processing agreements that guarantee compliance with applicable regulations.

3.Categories of personal data collected 3.1.Identification and contact details: 3.1.1.Name, surname, email address, telephone number. 3.1.2.Postal address and country. 3.1.3.Name of the company or organization represented. 3.1.4.Tax and billing information, including tax ID number, bank or card details. 3.2.Account credentials: 3.2.1.Username and encrypted password. 3.2.2.Additional authentication mechanisms, where applicable. 3.3.Technical and browsing data: 3.3.1.IP address used. 3.3.2.Browser, operating system, and device type. 3.3.3.Cookies and similar technologies (see Annex VII). 3.3.4.Information about browsing and actions within SWPANEL. 3.4.Data derived from the use of the software: 3.4.1.Actions within the platform. 3.4.2.Settings, preferences, and customizations. 3.4.3.Third-party data managed by the User (in which case DeepThink acts as data processor, in accordance with Annex II).

4.Purposes of processing and legal bases 4.1.Execution of the contract: 4.1.1.Account registration and management. 4.1.2.Payment, billing, and subscription management. 4.1.3.Access to contracted features. 4.1.4.Provision of technical support. 4.2.Security and control: 4.2.1.Access and activity monitoring. 4.2.2.Prevention of fraud or misuse. 4.2.3.Protection of systems and infrastructure. 4.3.Service improvement: 4.3.1.Statistical and technical analysis. 4.3.2.Error resolution and performance improvement. 4.3.3.Development of new features or services. 4.4.Legal compliance: 4.4.1.Tax, accounting, and administrative obligations. 4.4.2.Response to regulatory or legal requirements. 4.5.Operational communications: 4.5.1.Scheduled maintenance. 4.5.2.Contractual or policy changes. 4.5.3.Technical or critical service notices. 4.6.Legitimate commercial communications: 4.6.1.Sending information about complementary services offered by Prime Partners or the Prime Partners group. 4.6.2.Exercise of the right to object or withdraw consent, where applicable.

5.Communication and transfer of personal data 5.1.DeepThink will only transfer personal data in the following cases: 5.1.1.To suppliers or sub-processors under contract, in accordance with Annex II. 5.1.2.To competent authorities, upon legal request. 5.1.3.To companies in the Prime Partners group, for legitimate purposes related to the service. 5.1.4.In corporate transactions (merger, sale, spin-off), provided that the acquirer complies with this policy. 5.2.In the case of international data transfers: 5.2.1.The use of valid legal mechanisms, such as standard contractual clauses approved by the European Commission, or equivalent protection measures, shall be ensured.

6.Retention of personal data 6.1.DeepThink shall retain personal data: 6.1.1.During the contractual relationship. 6.1.2. After termination, for the mandatory legal retention periods (5-10 years). 6.1.3. For as long as legal liabilities may arise. 6.1.4. Until consent is revoked, in the case of voluntary processing. 6.2. After these periods, the data will be: 6.2.1.Safely deleted, or 6.2.2.Irreversibly anonymized.

7.Security measures 7.1.DeepThink implements appropriate technical and organizational measures, including: 7.1.1.Data encryption (in transit and at rest). 7.1.2.Access control and secure authentication. 7.1.3.Access logging and auditing. 7.1.4.Firewalls and anti-malware protection. 7.1.5.Backup and contingency plans. 7.2.The User is responsible for: 7.2.1.Maintaining the confidentiality of their credentials. 7.2.2.Using secure passwords. 7.2.3.Reporting unauthorized access.

8.User rights and exercise 8.1.The User may exercise the following rights, in accordance with applicable legislation: 8.1.1.Access. 8.1.2.Rectification. 8.1.3.Erasure. 8.1.4.Restriction of processing. 8.1.5.Objection. 8.1.6.Portability. 8.2.These rights may be exercised by: 8.2.1.The SWPANEL user panel. 8.2.2.Email to [email protected]. 8.3.The User may also: 8.3.1.Withdraw consent at any time. 8.3.2.Lodge a complaint with the competent supervisory authority.

9.Updates and validity 9.1.DeepThink may update this policy in the event of: 9.1.1.Changes in legislation or regulations. 9.1.2.The introduction of new technologies or processes. 9.1.3.Changes in the services provided. 9.2.The User will be informed when: 9.2.1.It is required by law. 9.2.2. The change significantly affects their rights or the processing of their data. 9.3. In the event of a regulatory discrepancy, the following shall prevail: 9.3.1. The most up-to-date version of this annex, or 9.3.2. The most protective regulation according to the User's jurisdiction.

Annex VII: Cookie Policy

For the proper functioning of DeepThink's websites and online services (including SWPANEL), the navigation system and software used collect certain browsing data through the use of cookies. Cookies are small text files that are stored on the user's device when they browse websites or use applications. These cookies may collect technical information such as the IP address used, the URL of the page requested, the time of connection, the type of browser, and other parameters of the user's device operating system. Under no circumstances is this information directly associated with an identified person, but is used primarily to recognize the user's session, facilitate navigation, and perform anonymous statistical analysis on the use of the site.

Below is specific information about the cookies used on the DeepThink and SWPANEL websites, as well as the most common ways for the User to manage or disable them:

1.Cookie management: Although DeepThink does not use cookies to collect personally identifiable information, we inform Users about how they can restrict or block cookies when browsing our sites: 1.a.We recommend visiting the website aboutcookies.org, which provides detailed information on how to manage cookies in various browsers. 1.b.In the help or privacy settings section of most web browsers (Chrome, Firefox, Safari, Edge, etc.), the User can set their preferences regarding the use of cookies (for example, accept all cookies, reject them, or receive a notification when a cookie is sent). Please note that if cookies are completely disabled, some services on DeepThink websites may not function properly.

2.Cookies stored by www.swpanel.com: When Users browse the main corporate website (www.swpanel.com), certain cookies are stored to facilitate navigation and access to content. The cookies stored by www.swpanel.com include: 2.1.swpanel_session: Identifies the User's session and is used to manage their basket of products or services on the site. 2.2.SERVERID: Ensures the proper functioning of the site and the persistence of the "User" session when load balancers (traffic distribution between several servers) are used. 2.3.In addition, DeepThink portals use third-party cookies and technologies for anonymous traffic analysis and measurement: 2.3.a.Google Analytics: A service provided by Google, Inc. that uses cookies to collect information from the User's computer (e.g., browsing data and IP address) in order to evaluate the use of the website and compile reports on site activity. • Google stores the information collected by its cookies on servers located in the United States. • Google may transfer this information to third parties when required by law or when such third parties process the information on Google's behalf. According to Google, the User's IP address is not associated with any other data held by Google. • "The User" can obtain more information about how Google processes the data collected by Google Analytics, as well as the options for disabling these cookies, in the Google Privacy Policy and on the opt-out pages provided by Google. 2.3.b.Facebook: On some DeepThink pages that integrate Facebook content (such as social network plugins), Facebook may set its own cookies to select the content displayed in those spaces. • For more information about Facebook cookies and how to manage them, please refer to the Facebook Cookies Policy. 2.3.c.Twitter: On DeepThink pages with integrated Twitter content, this platform may place cookies to manage interaction with such content. • "The User" can find information about Twitter's privacy practices in the Twitter Privacy Policy.

3.Cookies stored by go.swpanel.com: 3.a.None of the cookies used on go.swpanel.com are shared with external third parties. 3.b.All cookies on go.swpanel.com are stored in encrypted form to ensure their confidentiality. 3.c.When an authenticated User accesses their private area on SWPANEL (go.swpanel.com), several cookies are stored to facilitate navigation and usability of the panel. The specific cookies used by SWPANEL SaaS are: 3.1.ASPSESSIONID (session identifier): Manages the "User" session data within SWPANEL, allowing successive requests from the same User to be recognized. 3.2.ENCRYPTED_ID_COOKIE: Stores an encrypted session identifier for managing certain searches or listings in the panel. 3.3.SWwidthlinea: Identifies the width of the browser in pixels. It is used to manage the resizing and display of elements that SWPANEL must show to the user.

4.Third-party website cookies: Third-party content (e.g., videos hosted on YouTube or photos from Flickr) is occasionally integrated into DeepThink's information portals. When this embedded content is displayed, external websites may set their own cookies on the User's browser. DeepThink has no control over such third-party cookies or their management, so the User is advised to review the cookie and privacy policies of these external providers for further information. • Similarly, if the User decides to share content from DeepThink sites on social media (e.g., by clicking on "Share" buttons or posting a link), those social media platforms may set cookies on the User's device. DeepThink does not control these social media cookies and recommends consulting the policies of each platform (Facebook, Twitter, LinkedIn, Instagram, etc.) to learn about their use of cookies and data.

The User may at any time configure their browser to accept or reject cookies, as well as to delete cookies stored after browsing. Many browsers offer private browsing modes or "Do Not Track" settings that may limit the placement of certain cookies. DeepThink provides the legally required cookie notices and consents on its sites; by continuing to browse after viewing the cookie notice, you agree to the use of the cookies disclosed, unless you have expressly configured or rejected them.

Annex VIII: Corporate Legal Information (Legal Notice)

1.Company information DeepThink Software SLU, with registered office at Calle Ponent 13-15, 17458 Fornells de la Selva, Girona, Spain, Tax ID Number ESB219174639, and contact email address [email protected], is the owner of the SWPANEL platform and the associated websites, services, and applications. DeepThink is part of the Prime Quad Partners SL business group, which is made up of various entities specializing in the development of technological solutions, IT infrastructure services, and digital products. In this context, DeepThink may maintain relationships of collaboration, coordination, and transfer of information with other companies in the group, always within the legal framework provided for in this contract and in accordance with the confidentiality and data protection annexes (Annexes II, III, IV, and V). The transfer or exchange of personal information between companies in the group will only take place when there is a valid legal basis, such as the execution of the contract, legitimate interest or the consent of the User, and for legitimate and specific purposes, such as: • Improving customer service and communication with the User. • Providing additional or specialized technical support. • Offering complementary, integrable, or related technological services to SWPANEL. All these activities will be governed by the principles of confidentiality, integrity, and respect for the User's rights. Commercial relations arising from the contracting of services will be governed by Spanish law and jurisdiction, and will be formalized through the corresponding individual commercial agreements.

2.Intellectual and industrial property This website has been created by DeepThink for informational and professional purposes. The private part of the site, called SWPANEL, is intended exclusively for DeepThink customers as a tool for managing and controlling their contracted services. DeepThink is the owner of all intellectual and industrial property rights over this website, its contents, and the domain name www.swpanel.com. The reproduction, distribution, or modification of this site or its contents, in whole or in part, is expressly prohibited without prior written authorization. The insertion of links or references from other websites that maintain the frames of the original site is also prohibited, in order to avoid confusion about the ownership of the content. The User must be able to clearly identify that they are accessing a site managed by DeepThink.

3.Terms and conditions of use of the site The content, products, and services on this site are not intended for users in jurisdictions where access is prohibited. Access to the website is the sole responsibility of the User and does not imply any commercial relationship with DeepThink, except in the case of the effective contracting of services. Access and navigation imply knowledge and acceptance of the legal conditions, warnings, and terms of use contained herein.

4.Contents and limitation of liability DeepThink makes reasonable efforts to avoid errors in the contents of the site, but does not guarantee their accuracy nor is it responsible for errors arising from content provided by third parties. It is not responsible for differences between printed and electronic versions; in case of discrepancy, the published electronic version shall prevail. DeepThink assumes no responsibility for forums, chats, or other external interactive channels. It will cooperate with the authorities if illegal or harmful content is detected. It is expressly prohibited to transmit through the site any content that is illegal, offensive, or infringes on the rights of third parties. DeepThink may deny access to any User who violates these conditions and reserves the right to take legal action in the event of illegal conduct.

5.Navigation, access, and security The site has been designed to offer safe and efficient navigation. DeepThink does not guarantee compatibility with all browsers, nor is it responsible for any damage resulting from their use. Access to secure areas (such as payment or account management areas) is via an SSL encrypted connection with 1024-bit RSA keys, verified by a certificate issued by Thawte. DeepThink does not guarantee that access will be continuous or error-free, nor that the content is free of viruses or technical faults. Under no circumstances will it be liable for damages arising from the use of the website, telecommunications failures or external interruptions.

6.Updating of information DeepThink will indicate on its website the date of the last update. The information displayed is valid as of that date. The company reserves the right to update, modify, or delete content, features, or access without prior notice. It is also not permitted to alter, copy, or adapt the website without authorization. DeepThink may modify its content or structure when it deems appropriate.

Annex IX: Service Quality Guarantees and Service Level Agreement (SLA)

This annex establishes DeepThink's commitment to the quality of the SWPANEL service in its SaaS (Software as a Service) mode, accessible through the web platform managed directly by DeepThink. The service levels described herein do not apply to self-hosted SWPANEL installations on the User's servers or other environments outside the infrastructure controlled by DeepThink. They are also not applicable to third-party services or tools integrated into SWPANEL, whose guarantees will be subject to the conditions of the corresponding provider.

1.Scope of the SLA 1.1.This SLA applies exclusively to the availability, operability, and support of the SWPANEL platform managed directly by DeepThink. 1.2.It does not extend to: 1.2.a.SWPANEL Self-Hosted license installations made by the User on their own or third-party infrastructure. 1.2.b.Hosting platforms or servers where a local instance of SWPANEL is running. 1.2.c.Third-party tools accessible from SWPANEL, such as extensions, modules, external systems, or APIs. Such services shall be subject to the SLAs, availability, and warranties of the responsible third party.

2.Availability commitment 2.1.DeepThink undertakes to maintain the operational availability of the SWPANEL SaaS platform with a target monthly availability of 99.9% (calculated on a 24/7 basis). 2.2.DeepThink may establish scheduled maintenance windows, during which the platform may be unavailable. These technical interventions are necessary for: 2.2.a.Apply functional improvements. 2.2.b.Introduce security updates. 2.2.c.Ensure compliance with current regulations. 2.2.d.Optimize overall system performance. 2.3.These windows will be communicated to the User as far in advance as possible through the usual channels. Whenever possible, they will be scheduled at times of low impact for the User. 2.4.DeepThink may also carry out emergency maintenance without prior notice when there are critical vulnerabilities or operational risks that may affect the integrity, confidentiality, or availability of the service.

3.Technical support and assistance 3.1.DeepThink provides technical support exclusively in relation to the use and operation of the SWPANEL platform in its SaaS mode, accessible on the website managed by DeepThink. This support does not include assistance with third-party environments, custom configurations, operating systems, networks, User servers, or external services integrated by third parties. 3.2.Support requests must be related to: 3.2.a.Functional questions about the general use of SWPANEL. 3.2.b.Problems accessing the platform. 3.2.c.Anomalies or errors detected in the interface, internal processes, or standard system workflows. 3.3.DeepThink provides the User with the following channels for handling these queries: 3.3.a.Knowledge base and updated technical documentation, accessible from the platform itself. 3.3.b.Intelligent virtual assistant (AI) integrated into SWPANEL, capable of providing contextual help and automated responses in real time. 3.3.c.Technical contact system via the form or ticket available on the platform, for cases where the intervention of a DeepThink technician is necessary. 3.4.DeepThink does not guarantee telephone support or immediate availability by human technicians, except in exceptional internal situations that require it. Support is offered during business hours and will be responded to within a reasonable time frame depending on availability and operational load, with no binding commitments on response or resolution times. 3.5.Under no circumstances will DeepThink provide: 3.5.a.Support for systems, servers, configurations, or integrations made by the User. 3.5.b.Customer service to third-party end customers who use SWPANEL as part of their services. 3.6.Important: DeepThink markets SWPANEL both directly and through external suppliers or authorized integrators, who may include their own technical support as part of the service offered to their customers. In these cases, support requests should be directed exclusively to the supplier or company responsible for the contracted service, and not to DeepThink directly. DeepThink will not respond to queries from third parties or end users if there is no direct contractual relationship with them.

4.Best practices and constant updates 4.1.DeepThink guarantees that its technical and support team: 4.1.a.Is trained and certified in technologies associated with SWPANEL. 4.1.b.Operates under internal quality procedures and technical documentation. 4.1.c.Applies principles inspired by ITIL management models and established practices from other providers such as Plesk or cPanel. 4.2.DeepThink ensures the continuous evolution of the system, including: 4.2.a. Regular application of security updates. 4.2.b. Adaptation to relevant regulatory changes (e.g., data protection, cybersecurity, industry standards). 4.2.c. Optimization of platform performance to ensure service scalability and stability.

5.SLA limitations and exclusions 5.1.The SLA shall not apply when service interruptions or deficiencies are the result of: 5.1.a.Errors, misconfiguration, or failures in the User's environment. 5.1.b.Local SWPANEL installations (Self-Hosted mode), whose continuity depends exclusively on the server provider. 5.1.c.Third-party services accessible from SWPANEL that are not managed by DeepThink (e.g., domain providers, SSL certificates, integration APIs, etc.). 5.1.a.Causes of force majeure, such as natural disasters, government decisions, general Internet outages, or other events beyond DeepThink's reasonable control. 5.2.DeepThink does not offer financial compensation or refunds for service unavailability, and this addendum does not constitute a contractual guarantee of compensation. DeepThink is committed to always acting with the utmost technical diligence, speed, and responsibility to restore service in the shortest time possible.

6.General quality commitment 6.1.DeepThink reaffirms its commitment to: 6.1.a.Maintain a high standard of technical and human quality in the management of SWPANEL. 6.1.b.Listening to and valuing the opinions of Users for continuous improvement. 6.1.c.Resolving incidents quickly, transparently, and with a willingness to serve. 6.1.d.Promoting a secure, stable digital environment adapted to current technological challenges.