Privacy Policy

Version 1.2

PRIVACY POLICY EFFECTIVE AS OF 15TH MAY, 2026

Introduction

At XTEN-AV, we are strongly committed to safeguarding the privacy of our members. Please read this Privacy Policy carefully before using the www.xtenav.com services (“Services”) operated by XTEN-AV (“us”, “we”, “our”). This Privacy Policy describes what information you share with us and how we use it. This Privacy Policy is incorporated into and subject to the Terms and Conditions of this website (“Terms and Conditions”). Each time that you access or use the Services, you acknowledge that you have read, understand and agree to be bound by the Terms and Conditions and this Privacy Policy. If you do not agree to the Terms and Conditions and this Privacy Policy, you must discontinue using our Services.

Types of Information We Collect

We must collect information from our members in order for members to properly use the services provided by XTEN-AV and to process credit card charges for transactions. We may also collect information related to your use of the Services.

Personal identifiable information (“Personal Information”) includes, but is not limited to, the following if it identifies, relates to, describes, is reasonably capable of being associated with, or could be reasonably linked, directly or indirectly, with a particular consumer or household: name; alias; unique personal identifier; online identifier; account name; signature; address; telephone number; email address; credit card number; any other financial information for purposes of completing a transaction; Internet Protocol address; commercial information, including products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies; internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer's interaction with an internet website application, or advertisement; geolocation data; professional or employment-related information; and inferences drawn from any of the information identified in this subdivision to create a profile about a consumer reflecting the consumer's preferences. “Personal information” does not include publicly available information that is truthful and lawfully made available to the general public from federal, state, or local government records. Any Personal Information that is provided by you is never disclosed to any individual or business except what is required for business transactions facilitated by XTEN-AV. Such transactions are initiated and accepted by the parties involved. We will not rent or sell your Personal Information to third parties without your explicit consent.

The following section describes the categories of Personal Information we collect, the sources from which such information is obtained, and the purposes for which it is collected and disclosed. We disclose Personal Information for business purposes only with your consent where required by applicable law, and pursuant to written agreements that specify the permitted purposes, require recipients to maintain the confidentiality of the information, and prohibit its use for any purpose other than fulfilling contractual obligations.

We may collect certain categories of personal information depending on how you interact with our services. When you browse our website or mobile app, we automatically collect identifiers and related technical information such as Internet Protocol (IP) address, device information, browser type, and online identifiers through cookies and similar technologies. This information is collected from your device and through analytics providers and is used to operate, maintain, and improve our website, enhance user experience, and ensure security.

If you create an account with us, we may additionally collect personal identifiers such as your name, email address, account credentials, and, where applicable, your telephone number. Your cell phone number is collected solely for authentication purposes, including two-factor authentication, and, with your consent, to send service-related or promotional communications. We do not sell your cell phone number to third parties.

We may also collect commercial information, including records of services purchased or subscriptions, directly from you in order to process transactions, manage accounts, and provide our services. Internet or other electronic network activity information, including browsing patterns and interactions with our platform, may be collected from both visitors and account holders through cookies and analytics tools to monitor usage, improve functionality, and maintain security.

In limited cases, we may collect professional or employment-related information from account holders where necessary to provide business- related services. Additionally, we may derive inferences from collected information to better understand user preferences, personalize content, and enhance our services.

We may collect approximate geolocation data based on your IP address to support security measures and improve service delivery. However, we do not collect precise geolocation data.

We do not collect certain categories of sensitive personal information, including protected classification characteristics under applicable law, biometric information, sensory data, non-public education records, or government-issued identification numbers.

All personal information is collected directly from users, their devices, or through authorized third-party service providers such as analytics partners. We may disclose personal information to service providers and partners strictly for business purposes, including service delivery, account management, analytics, communication, and security. Such disclosures are made under contractual obligations requiring confidentiality and limiting the use of information solely to the performance of services on our behalf.

HOW WE COLLECT YOUR INFORMATION

• We collect all of the information you provide to us through the activities described above.
• We collect information through technology, such as cookies and Web beacons, including when you visit our site or use our applications (see description below).
• We collect your cell phone number from you when you sign up for an account, for two-step authentication to secure your account.
• We may acquire information from other sources to update or supplement the information you provided or we collected automatically.

COOKIES AND WEB BEACONS

Where necessary, this website uses cookies to store information about a visitor’s preferences and history in order to better serve the visitor and/or present the visitor with customized content. Note, you can choose to accept or decline cookies. See Controlling Your Privacy section below for details on the ability to opt out of the use of cookies.

Through cookies and Web beacons, we may collect device information about the device you use to access the Services, including but not limited to IP addresses for your devices, unique device identifiers, browser types, browser language and other transactional information that does not personally identify you. We may also log user history information which is certain usage information about your use of the Services, which may include a history of the pages you view. If you download and use any XTEN-AV software application on your device, the log files will automatically be collected by the application and sent to our servers.

Advertising partners and other third parties may also use cookies, scripts and/or web beacons to track visitors to our site in order to display advertisements and other useful information. Such tracking is done directly by the third parties through their own servers and is subject to their own privacy policies.

Information such as IP addresses, Internet domain and host names, clickstream patterns, browser details and operating systems, and time stamped access of our web site, may be recorded by tracking technologies. The information is tracked for routine administration and maintenance purposes, as well as to improve our website and our user experience. We may also analyze information that does not contain Personal Information for trends and statistics.

If you reside in a location that prohibits the collection of any of the above information without your consent, we will not collect this information without your consent.

We use cookies and similar tracking technologies for a variety of purposes. Certain cookies are necessary for the technical operation of our website, while others enable us to perform analytics, enhance functionality, and deliver relevant advertising.

(i) Essential Cookies.
These cookies are strictly necessary for the operation of our website and to provide services requested by you. They enable core functionalities such as security, network management, and accessibility. As these cookies are essential, they cannot be disabled.

(ii) Functionality Cookies.
These cookies are used to improve the performance and functionality of our website by remembering user preferences and settings. While not strictly necessary, disabling these cookies may affect the availability or performance of certain features.

(iii) Analytics Cookies.
These cookies collect information about how users interact with our website, typically in an aggregated and anonymized form. This information helps us analyze website usage, measure the effectiveness of marketing efforts, and improve overall user experience.

(iv) Advertising Cookies.
These cookies are used to deliver advertisements that are more relevant to you and your interests. They also help limit the frequency of ad displays, ensure proper delivery of advertisements, and may be used to measure the effectiveness of advertising campaigns.

Cookie Duration and Retention

In addition to the categories of cookies described above, we provide the following information regarding how long cookies remain on your device:

Cookies used on our website may be classified as either session cookies or persistent cookies.

• Session cookies are temporary cookies that are automatically deleted from your device once you close your browser. These cookies are typically used to maintain your session, enable secure logins, and ensure the proper functioning of the website during your visit.are temporary cookies that are automatically deleted from your device once you close your browser. These cookies are typically used to maintain your session, enable secure logins, and ensure the proper functioning of the website during your visit.
• Persistent cookies remain on your device for a defined period of time or until you delete them manually. These cookies allow us to recognize your device and remember your preferences or actions across multiple sessions.

The retention period for persistent cookies varies depending on their purpose:

• Essential Cookies may be stored for the duration of your session and, where necessary, may persist for a short period thereafter, typically up to 30 days, to maintain security, prevent fraud, and ensure the proper functioning of our services.
• Functionality Cookies may remain on your device for a defined period, typically ranging from 30 days to 12 months, so that your preferences (such as language, login details, or display settings) can be remembered for future visits.
• Analytics Cookies are generally retained for a limited duration, typically ranging from 1 month up to 24 months, to help us analyze usage trends, measure the effectiveness of features and marketing efforts, and improve our services.
• Advertising Cookies may persist for varying durations depending on the practices of third-party providers, but typically range from 30 days up to 24 months, and are used to deliver relevant advertisements, limit ad frequency, and measure the effectiveness of advertising campaigns.

You have the ability to control and manage cookies through your browser settings. Most browsers allow you to refuse or delete cookies, as well as to set preferences for certain types of cookies. Please note that disabling or removing certain cookies may impact the functionality and performance of our website.

HOW WE USE YOUR INFORMATION WE COLLECT

XTEN-AV uses your information that it collects from you and about you for the purposes set forth below:

• Provide you with the products and services you request;
• Communicate with you about your account or transactions;
• Personalize your experience on our site and application;
• Send you information about new XTEN-AV features or changes to our policies;
• Detect, investigate and prevent activities that may violate our policies or be illegal; and
• Review whether it is responsive to a subpoena or other legal request we have received.

WHEN WE SHARE YOUR INFORMATION

We may share any of your information in the following instances:

• When you direct us to share your information with third-party sites or platforms;
• When we share your information with third parties in connection with the sale of a business, to enforce our Terms and Conditions or rules, to ensure the safety and security of our guests and third parties, or to protect our rights and property and the rights and property of our guests and third parties;
• When we determine your information is responsive to a subpoena or other legal request
• To our third party service providers who provide services such as website hosting, maintenance, data analysis, payment processing, order fulfillment, infrastructure provision, IT services, customer service, email delivery services, credit card processing, auditing services and other similar services, but only to the extent necessary or useful to provide such services, and only pursuant to contractual obligations requiring such third parties to maintain the privacy and security of your Personal Information

WHEN WE SELL YOUR INFORMATION

We will always ask for your consent before selling your information to third party AV manufacturers or marketing agencies. We will disclose to you the type of information we will sell to a third-party so that you may make an informed decision.

Please note that once we share your information with another company, the other company’s privacy practices will govern their use of the information.

WE NEVER SHARE OR SELL THE FOLLOWING INFORMATION AND IT IS KEPT CONFIDENTIAL TO YOUR ACCOUNT AND ONLY YOU AND YOUR ORGANIZATION WILL HAVE ACCESS TO IT

• Any Information about your projects which you create on XTEN-AV platform
• Any Information about your client/customers which you save on XTEN-AV platform
• Any Information about your proposals which you create and save on XTEN-AV platform
• Any information about your dealer/transfer pricing for different manufacturers which you upload on XTEN-AV platform
• We may ask if you consent to sharing data, and if you permit us to, we may share your browsing habits within your account and we may share which products you selected for your proposals and projects

HOW LONG WE WILL STORE YOUR INFORMATION

XTEN-AV will continue to store and process your information until the earlier of (i) you request that we delete your personal information in accordance with the procedures set forth in this privacy policy, or (ii) XTEN-AV decide to delete your personal information such as because you failed to use XTEN-AV’s Services for a prolonged period of time (as determined in XTEN-AV’s sole discretion) or another business reason makes it desirable for us to delete your information.

CONTROLLING YOUR PRIVACY

You can choose to accept or decline cookies. You can always change your browser settings to disable cookies if you have privacy concerns. Disabling cookies for all sites is not recommended as it may interfere with your use of some sites. The best option is to disable or enable cookies on a per-site basis. Consult your browser documentation for instructions on how to block cookies and other tracking mechanisms. You can also disable personal information sharing under the privacy settings in your profile section of XTEN-AV account.

For certain users, your location may require that you consent first to the use of cookies before being allowed access to our Services.

THIRD-PARTY USE OF COOKIES AND OTHER TRACKING TECHNOLOGIES

Our website and software may provide you with hyperlinks to other sites not owned or controlled by us, and we are not responsible for the privacy practices of any site that is not owned or controlled by us. We encourage you to be aware when you leave our site or applications and to read the privacy policies of these other sites.

Additionally, there may be some content or applications, including advertisements, on our website that are served by third-parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our website. The information they collect may be associated with your personal information, or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content. We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way.

You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI”) on the NAI’s website. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

CHANGES TO THIS PRIVACY POLICY

Although most changes are likely to be minor, XTEN-AV may change its Privacy Policy from time to time, and at our sole discretion. Should such changes occur, XTEN-AV will post the new Privacy Policy with a new Effective Date to notify you of these changes. XTEN-AV will provide notice to you, and, if XTEN-AV is required by applicable law, XTEN-AV will obtain your consent. If XTEN-AV has not obtained your consent, you are deemed to consent to our then-current Privacy Policy by accessing the Services after the Effective Date, unless you are an EU Resident for whom different methods of consent apply (as discussed below in the Notice to Non-U.S. Users section). If you are concerned about how your information is used, you should check back to this Privacy Policy frequently for updates.

HOW WE PROTECT CHILDREN’S PRIVACY

We do not knowingly allow children under the age of 18 to use or register for XTEN-AV, and therefore we do not knowingly collect personal information from children under the age of 18. If you are under 18, do not use or provide any information on this website or through any of its features, register on the website, make any purchases through the website, use any of the interactive features of this website, or provide any information about yourself to us, including but not limited to your name, address, telephone number, email address, or any screen name or username you may use. If we learn we have collected or received Personal Information from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 18, please contact us at support@xtenav.com .

NOTICE TO NON-U.S. USERS

These Services are operated in the United States and is intended for users located in the United States and internationally. If you are located anywhere outside of the United States, please be aware that information we collect, including personal information, will be transferred to, processed and stored in the United States. The data protection laws in the United States may differ from those of the country in which you are located, and your personal information may be subject to access requests from governments, courts, or law enforcement in the United States according to the laws of the United States. By using the Services or providing us with any information, you consent to the transfer, processing and storage of your information in the United States. You are also consenting to the application of United States federal and Illinois state law in all matters concerning the Services and this Policy.

SPECIAL POLICIES FOR EUROPEAN ECONOMIC AREA AND UNITED KINGDOM RESIDENTS

XTEN-AV only collects and uses your personal information only where it has a legal basis to do so, including:

• XTEN-AV needs it to provide you the Online Services and XTEN-AV’s other services, including to provide customer support;
• XTEN-AV needs it to satisfy a legitimate interest (which is not overridden by your data protection interests), such as for research and development, to market and promote XTEN-AV services and to protect XTEN-AV’s legal rights and interests;
• XTEN-AV has obtained your specific consent to do so for a specific purpose; or
• XTEN-AV needs to process your personal information to comply with a legal obligation.

YOUR RIGHTS TO CONTROL YOUR INFORMATION

To exercise any of your rights set forth in this section, please contact us support@xtenav.com . Subject to our authentication of your identity, we will act on your request promptly.

Right to Withdraw Consent and Stop Our Use of Your Personal Information: If you have consented for XTEN-AV to use your personal information for a specific purpose or purposes, you may contact us to instruct us that you withdraw your consent that we use your personal information for that purpose or those purposes. Note however, this will not affect any processing or use of your personal information that took place before you withdrew your consent.

Right to Access and Port Your Personal Information: You may contact us to receive a copy of your personal information and it shall be provided in a structured, commonly used and machine readable format, which you may then port elsewhere for your purposes.

Right to View, Correct or Change Your Personal Information: You have the right to know whether we process your personal information and to view the information we collect from you. If your personal information has changed or you discover our records of your personal information are otherwise incorrect, you may contact us to change your personal information accordingly.

Right to Be Forgotten: If you do not wish for XTEN-AV to have your personal information anymore, you may contact us to instruct us to delete your personal information from our records. We will delete your personal information from our database. Note, however, if you have communicated to us through email or other channels, we may incidentally have portions of your personal information within our internal archives of such communications, however, we will not use such Personal Information for any purpose inconsistent with your right to be forgotten or the record-keeping purposes of the archive. We may also preserve your personal information if we are required to do so by law, however, we will not use such Personal Information for any purpose inconsistent with your right to be forgotten or such legal obligation.

Right to Review Decision-Making: If you question why you have received a communication or other material from XTEN-AV, you may contact us to learn what about your personal information led us to send you the communication or other material. You have the right to object to a decision based solely on automated processing, including profiling, which produces legal effects concerning or affecting you.

Right to Restriction of Processing: If any of the following conditions apply, you have the right to request a restriction on the processing of your data: (1) accuracy of the data is contested; (2)the processing is unlawful and you oppose erasure of the data; (3) the controller no longer needs your personal data for processing but legal claims require data not to be erased; and (4) you object to the processing of your personal information in accordance with Article 21(1) of the GDPR.

Right to Object: You have the right to object to the processing of personal data concerning yourself in accordance with Article 21 of the GDPR and that do not fall under any exception.

SECURITY

The security of your Personal Information is important to us, because we know that the security of your information is important to you. We have implemented reasonable security procedures that are intended to protect your information. All information you provide to us is stored on our secure servers behind firewalls. Any payment transactions – available only in the United States – will be encrypted pursuant to Payment Card Industry Data Security Standards (“PCI DSS”). From time to time, we review and update our procedures to consider appropriate new security technology and methods.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Please be aware that no security measures are perfect or impenetrable. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the website. If, despite our security measures, your most sensitive information, such as your payment information, has been compromised, we will notify you in accordance with our legal obligations in your jurisdiction.

We operate globally, and although we do not currently do so, we may transfer your Personal Information to locations around the world. Wherever we control the transfer, storage, or processing of your Personal Information, we will take reasonable steps to safeguard the privacy of your Personal Information.

NOTICE

XTEN-AV does not intend to transfer or sell Personal Information without your consent to third parties who are not bound to act on XTEN-AV’s behalf unless such transfer is legally required.

Record of Processing Activities for Controllers & Processors

This Record of Processing Activities (Record) describes how XTEN-AV controls and processes personal data. XTEN-AV maintains documentation, as required by one or more laws, on controllers and processors. This Record is confidential company information, but XTEN-AV will provide it to the appropriate supervisory authority on request as required by applicable law.

Controller/Processor Details:

Name: XTEN-AV
Address: 33170 Alvarado Niles Rd., #2231, Union City, CA 94587
Email Address: support@xtenav.com
Website: https://xtenav.com/

Categories of Data Subjects

XTEN-AV collects personal data from the following categories of data subjects:

• XTEN-AV’s customers or consumers.
• XTEN-AV’s vendors or suppliers.
• XTEN-AV’s employees and job applicants.

XTEN-AV collects and processes personal data about vendors or suppliers for the following purposes:

• To obtain products and services.
• Vendor administration, order management, and accounts payable.
• Evaluating potential suppliers.

Categories of Personal Data Recipients

XTEN-AV discloses personal data, by consent if required, to the following categories of recipients, some of which may be located in third countries or may be international organizations:

• Business partners.
• Auditors and professional advisors, such as lawyers and consultants.
• Federal, state, and local enforcement officials.
• Third-party service providers, such as providers of:
• IT system management;
• Payment processing;
• Analytics and search engine providers;
• Customer relations management; and
• Information security.

XTEN-AV makes limited personal data transfers subject to the second subparagraph of Article 49(1) of the Fourth Geneva Convention (1949), which are necessary for XTEN-AV’s compelling legitimate interests. XTEN-AV’s provides appropriate safeguards for these limited personal data transfers through contractual clauses.

Technical and Organizational Security Measures

XTEN-AV has implemented the following technical and organizational security measures to protect personal data:

• Pseudonymization of personal data.
• Encryption of personal data.
• Segregation of personal data from other networks.
• Access control and user authentication.
• Employee training on information security.
• Written information security policies and procedures.

CONTACT INFORMATION

If you have any questions regarding the use of your information, this Privacy Policy or the Terms and Conditions, please contact us at support@xtenav.com .