Privacy Policy

Effective Date: August 15, 2025

Last Updated: April 22, 2026

This Privacy Policy (“Privacy Policy”) describes how Vyome Holdings, Inc., a Delaware corporation, and its affiliates (collectively, “Company”, “we”, “us”, or “our”) collect, use, disclose, retain, and otherwise process personal information in connection with our public-facing website, any investor-access portal, restricted pages, related digital properties, and any content, functionality, and services made available through them (collectively, “Site”). This Privacy Policy is intended to align with the Terms of Use governing the Site, including portions of the Site available only to registered or approved users such as verified investors or other authorized users.

By accessing or using the Site, or by submitting personal information to us through the Site, you acknowledge and agree to this Privacy Policy to the extent permitted by applicable law.

For purposes of applicable data protection laws, including the General Data Protection Regulation (“GDPR”) and the UK GDPR, Company is the data controller responsible for the processing of personal information described in this Privacy Policy, unless otherwise specified.

1. Scope and Applicability

This Privacy Policy applies to personal information that we collect or process:

• through the public-facing portions of the Site;

• through restricted or investor-access portions of the Site;

• when individuals register for an account or apply for access as a verified investor or other eligible user;

• when users submit information, attestations, credentials, or supporting documentation for identity, eligibility, authority, or investor-status verification;

• when users communicate with us through webforms, email, or similar channels linked from the Site; and

• through automated means such as cookies, log files, and similar technologies used on the Site.

This Privacy Policy does not apply to:

• third-party websites, platforms, or services that may be linked from the Site;

• information subject to a separate privacy notice, portal notice, confidentiality legend, or transaction-specific disclosure;

• employment-related information collected in a recruiting or workforce context, unless expressly stated otherwise; or

• information that has been deidentified or aggregated in a manner that no longer reasonably identifies an individual, where permitted by applicable law.

2. Categories of Personal Information We Collect

Depending on how you interact with the Site, we may collect the following categories of personal information.

1. Identifiers and Contact Information

• Name

• Business or personal email address

• Telephone number

• Mailing address

• Username or account identifier

• Online identifiers, IP address, device identifiers, or similar identifiers

2. Professional and Investor-Related Information

• Employer, fund, institution, or organization name

• Job title or role

• Business affiliation

• Investor category, accreditation status, eligibility status, or similar classification

• Information regarding authority to act on behalf of an entity

• Communications regarding investor access or eligibility

3. Registration, Verification, and Account Information

• Information submitted in connection with account creation

• Login credentials and authentication-related information

• Multi-factor authentication enrollment information

• Verification responses, attestations, certifications, and declarations

• Supporting documentation provided to verify identity, investor status, eligibility, or authority

• Access history and account status information

4. Internet and Electronic Network Activity Information

• Browser type and version

• Device type, operating system, and language settings

• Referring URLs and pages viewed

• Dates and times of visits

• Clickstream and navigation patterns

• Search queries entered on the Site

• Error logs, diagnostics, and performance data

5. Communications and Submission Information

• Information you include in emails, contact forms, portal submissions, or other communications

• Requests for information, support, or investor materials

• Records of correspondence and follow-up actions

6. Security and Risk Management Information

• Information used to detect, investigate, prevent, or respond to unauthorized access, fraud, misuse, or other security incidents

• Device and session signals used for authentication and access control

• Information about suspected policy violations or prohibited conduct

7. Sensitive Information

We do not seek to collect sensitive personal information through the Site except where reasonably necessary for authentication, verification, security, compliance, or as otherwise permitted by law. If certain documentation submitted for investor or eligibility verification contains information that may be considered sensitive under applicable law, we will process it only for legitimate business, legal, compliance, and security purposes and not for unrelated purposes.

3. Sources of Personal Information

We may collect personal information from the following sources:

• Directly from you, such as when you browse the Site, complete forms, register for access, upload documentation, communicate with us, or subscribe to updates;

• Automatically from your device or browser, through cookies, logs, pixels, SDKs, and similar technologies;

• From our service providers, such as hosting providers, analytics providers, identity verification vendors, authentication providers, portal administrators, and security vendors;

• From affiliates and advisors, where relevant to investor relations, legal compliance, or account administration;

• From public sources, such as public registries, professional profiles, regulatory databases, sanctions lists, or public filings, where relevant to verification or compliance; and

• From institutional representatives or other third parties acting on your behalf, such as employers, fund administrators, legal counsel, or authorized delegates.

4. Purposes of Collection, Use, and Disclosure

We collect, use, and disclose personal information for the business and commercial purposes described below.

1. Operating the Site

We use personal information to:

• provide, maintain, and improve the Site;

• operate public-facing and restricted Site functionality;

• manage content presentation, system administration, and technical support; and

• understand how users engage with the Site.

2. Registration, Authentication, and Investor Access

We use personal information to:

• process requests for verified investor or other restricted access;

• verify identity, eligibility, investor status, authority, and continuing qualification;

• establish and administer user accounts;

• authenticate users and enable secure login, including multi-factor authentication; and

• approve, deny, limit, suspend, or revoke access where appropriate.

3. Communications

We use personal information to:

• respond to inquiries and requests;

• provide administrative, legal, security, or service-related notices;

• send updates regarding Site functionality, account status, or requested materials; and

• communicate regarding investor-access procedures, eligibility requirements, or portal restrictions.

4. Security, Integrity, and Risk Management

We use personal information to:

• protect the Site, our systems, and users;

• detect and address unauthorized access, credential compromise, misuse, scraping, fraud, malware, and other harmful activity;

• investigate suspected violations of our Terms of Use or other applicable terms;

• preserve the integrity and confidentiality of restricted materials; and

• document and respond to legal, regulatory, or operational risks.

5. Compliance and Legal Obligations

We use personal information to:

• comply with applicable law, regulation, legal process, or government request;

• support internal legal, compliance, audit, and governance functions;

• enforce our Terms of Use and other legal rights;

• maintain records required for legal, regulatory, or operational purposes; and

• defend against claims and resolve disputes.

6. Business Administration and Corporate Operations

We use personal information to:

• manage relationships with investors, analysts, institutional representatives, and business contacts;

• support corporate communications and investor relations activities;

• administer vendors, advisors, and affiliates supporting Site operations; and

• evaluate and improve security controls, workflows, and user experience.

7. Legal Bases for Processing (EEA/UK)

If you are located in the European Economic Area (“EEA”), the United Kingdom, or another jurisdiction with similar data protection laws, we process your personal information only where we have a valid legal basis to do so under applicable law.

Depending on the circumstances, we may rely on the following legal bases:

1. Performance of a Contract

We process personal information where necessary to enter into or perform a contract with you, including to provide access to the Site, administer accounts, authenticate users, and provide requested services or information.

2. Legitimate Interests

We process personal information where necessary for our legitimate interests, provided that such interests are not overridden by your fundamental rights and freedoms. These interests include, for example:

• operating, maintaining, and improving the Site;

• managing investor relations and communications;

• verifying identity, eligibility, and authority for restricted access;

• protecting the security and integrity of our systems and content;

• detecting and preventing fraud, misuse, or unauthorized access; and

• supporting internal administrative, legal, and business operations.

3. Compliance with Legal Obligations

We process personal information where necessary to comply with applicable legal or regulatory obligations, including obligations relating to securities laws, anti-fraud requirements, recordkeeping, and responding to lawful requests from authorities.

4. Consent

We process personal information based on your consent where required by law, including, where applicable, for the use of certain cookies or similar technologies. You may withdraw your consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.

5. Establishment, Exercise, or Defense of Legal Claims

We may process personal information where necessary to establish, exercise, or defend legal claims or in connection with legal proceedings.

5. Cookies and Similar Technologies

We and our service providers may use cookies and similar technologies on the Site, including browser cookies, local storage, log files, session-replay tools, pixels, tags, and similar technologies.

1. Types of Technologies We May Use

Category

Purpose

Strictly necessary cookies

Enable core Site functions, authentication, login sessions, security, load balancing, and user-requested services

Functional cookies

Remember settings, preferences, or user choices

Analytics cookies

Measure traffic, understand usage patterns, and improve Site performance

Security technologies

Detect abuse, bots, malicious activity, credential misuse, and other threats

2. How We Use These Technologies

We may use these technologies to:

• recognize devices and sessions;

• maintain secure login states;

• facilitate navigation and Site functionality;

• analyze Site traffic and performance;

• understand engagement with public and restricted content; and

• support fraud prevention, system security, and incident detection.

3. Your Choices

You may be able to control certain cookies through your browser settings or any cookie management tool we make available on the Site. Blocking some cookies may affect Site functionality, including access to restricted areas, account authentication, and user preferences.

We do not use personal information collected through the Site for cross-context behavioral advertising, and we do not sell personal information through the Site.

6. Investor and Account Registration Information

Certain portions of the Site may be available only to users who register and are approved as verified investors or otherwise eligible users.

In connection with such registration or access requests, we may collect:

• contact and professional details;

• institutional affiliation information;

• representations and attestations regarding investor status, eligibility, and authority;

• identification, credentials, or supporting documents;

• account creation and login information; and

• information needed to administer access restrictions and confidentiality requirements.

We may use this information to:

• assess eligibility for restricted access;

• verify identity and authority;

• determine whether access should be granted, denied, suspended, limited, or revoked;

• support legal and regulatory compliance;

• maintain records of user representations and access decisions; and

• protect confidential, proprietary, or non-public materials.

If you provide information about another individual in connection with an account, authorization, or investor-access request, you represent that you are authorized to do so.

7. Verification and Security-Related Processing

Because certain Site content may be limited to approved users and may involve confidential, proprietary, or non-public materials, we may process personal information for verification and security purposes, including to:

• confirm your identity;

• validate your investor status, eligibility, or authority;

• authenticate account access and maintain account security;

• monitor for suspicious, fraudulent, abusive, or unauthorized activity;

• investigate possible breaches of our Terms of Use or other restrictions;

• preserve evidence, logs, and related records for security and compliance purposes; and

• take protective actions, including credential resets, access suspension, or access revocation.

Where permitted by law, these activities may involve automated tools, manual review, or both.

8. How We Disclose Personal Information

We may disclose personal information to the categories of recipients listed below, subject to applicable law and appropriate confidentiality protections.

1. Service Providers and Contractors

We may disclose personal information to vendors and service providers that perform services on our behalf, such as:

• website hosting and infrastructure providers;

• cloud storage providers;

• authentication and identity verification vendors;

• portal management vendors;

• cybersecurity, monitoring, and fraud detection providers;

• analytics and IT support providers;

• communications and email delivery vendors; and

• document management and administrative support providers.

These parties are required by written contract to process personal information only as authorized by us and solely for permitted business purposes, and not to retain, use, or disclose personal information for any other purpose.

2. Affiliates

We may disclose personal information within our corporate family for purposes consistent with this Privacy Policy, including administration, security, investor relations support, legal compliance, and business operations.

3. Advisors and Professional Services Firms

We may disclose personal information to our legal counsel, auditors, accountants, consultants, financial advisors, compliance advisors, and other professional service providers as reasonably necessary for corporate, legal, regulatory, transactional, or governance purposes.

4. Corporate Transactions

We may disclose personal information in connection with an actual or proposed financing, merger, acquisition, reorganization, asset sale, investment, bankruptcy, dissolution, or other corporate transaction, subject to customary confidentiality protections.

5. Legal and Regulatory Disclosures

We may disclose personal information:

• to comply with applicable law, regulation, subpoena, court order, or other legal process;

• to respond to lawful requests from public authorities, regulators, or law enforcement;

• to enforce our legal rights, Terms of Use, or contractual arrangements;

• to protect the Site, our users, Company, or others from harm, fraud, or security threats; or

• where disclosure is otherwise required or permitted by law.

6. With Your Direction or Consent

We may disclose personal information to other parties when you request, direct, or consent to the disclosure.

9. Retention of Personal Information

We retain personal information for as long as reasonably necessary for the purposes described in this Privacy Policy, including to:

• provide and maintain the Site;

• administer accounts and investor-access requests;

• maintain security, fraud prevention, and audit records;

• comply with legal, tax, accounting, reporting, and regulatory obligations;

• preserve evidence relevant to claims, disputes, or investigations; and

• enforce our agreements and protect our rights.

Retention periods may vary depending on the nature of the information, the sensitivity of the data, the existence of an ongoing relationship, applicable legal requirements, and operational necessity. We may retain certain records for longer periods where required or permitted by law, including where needed to document verification, authorization, access decisions, or security-related events.

10. Data Security

We implement reasonable administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, destruction, loss, alteration, disclosure, or misuse. These measures may include access controls, authentication safeguards, role-based restrictions, logging, monitoring, encryption or comparable protections where appropriate, and vendor management procedures.

However, no method of internet transmission or electronic storage is completely secure, and we cannot guarantee absolute security. You are responsible for maintaining the confidentiality of your account credentials and for notifying us promptly of any actual or suspected unauthorized access to or use of your account.

11. User Rights and Choices

Subject to applicable law, users may have certain rights regarding their personal information.

1. General Rights

Depending on your jurisdiction, you may have the right to request:

• access to personal information we maintain about you;

• correction of inaccurate personal information;

• deletion of personal information, subject to applicable exceptions;

• a copy of certain personal information in a portable format, where applicable;

• information about categories of personal information collected, disclosed, or otherwise processed; and

• limitation of or objection to certain processing activities, where available under applicable law.

2. Account and Communication Choices

You may also be able to:

• update certain account information through your account or by contacting us;

• change your cookie settings through browser controls or available consent tools;

• opt out of non-essential communications by following any available unsubscribe instructions; and

• request closure of an account, subject to legal, security, contractual, and recordkeeping requirements.

3. Verification of Requests

To protect personal information and Site security, we may take reasonable steps to verify your identity before responding to a privacy request. This may include matching information you provide against our records, requesting additional identifying information, or using other appropriate verification procedures. We may deny or limit a request where we cannot verify the requester’s identity or authority, or where an exemption or legal exception applies.

4. Authorized Agents

Where required by law, we will permit authorized agents to submit requests on behalf of individuals, subject to appropriate proof of authorization and identity verification.

5. Submission Methods

To submit a privacy request, please contact us using the details in the Contact Information section below or through the following method(s). We will endeavor to respond to verifiable requests within the timeframe required by applicable law, including any extension period permitted by law.

Email: contact@vyometx.com

6. EEA/UK

If you are located in the EEA or the United Kingdom, you may also have the right to (a) request restriction of processing of your personal information; (b) object to processing based on our legitimate interests, including profiling based on those interests; and (c) lodge a complaint with a supervisory authority in your country of residence, place of work, or where an alleged infringement has occurred.

Where we rely on legitimate interests as a legal basis, you may object to such processing on grounds relating to your particular situation. We will consider your request in accordance with applicable law.

12. U.S. State Privacy Disclosures

Residents of certain U.S. states, including California and other states with comprehensive privacy laws, may have additional rights or disclosures available to them under applicable law.

1. General State Law Disclosures

In the preceding 12 months, we may have collected and disclosed for business purposes the categories of personal information described in this Privacy Policy, including:

• identifiers and contact information;

• professional, employment-related, or investor-related information;

• account, registration, verification, and authentication information;

• internet or electronic network activity information;

• communications and submission information; and

• security and risk management information.

We collect, use, and disclose these categories for the purposes described in the sections above, including Site operation, account administration, investor-access management, authentication, security, communications, analytics, legal compliance, and business operations.

2. Sales and Sharing

We do not sell personal information collected through the Site. We also do not share personal information collected through the Site with advertising or marketing partners for cross-context behavioral advertising purposes.

3. Sensitive Personal Information

To the extent we collect personal information that may be deemed sensitive under applicable state law, we use and disclose it only for permitted business purposes, such as authentication, verification, Site security, legal compliance, and account administration, and not to infer characteristics for unrelated purposes.

4. Non-Discrimination

We will not unlawfully discriminate against you for exercising any privacy rights available under applicable law.

5. California “Shine the Light”

If applicable, California residents may request information regarding certain disclosures of personal information to third parties for their own direct marketing purposes. Because we do not disclose personal information collected through the Site to third parties for their own direct marketing purposes in the manner contemplated by that law, we will inform requesters of this fact in response to any such request.

13. Cross-Border Processing

We are based in the United States and may process or store personal information in the United States or other jurisdictions where we, our affiliates, service providers, or advisors operate. As a result, personal information may be transferred to and processed in jurisdictions that may not provide the same level of data protection as your home jurisdiction.

Where applicable, we will take steps reasonably designed to ensure that cross-border transfers are subject to appropriate safeguards as required by law.

If you are located in the EEA, the United Kingdom, or another jurisdiction with restrictions on cross-border data transfers, we will take appropriate measures to ensure that transfers of personal information are conducted in accordance with applicable data protection laws.

Such measures may include, where appropriate: (a) entering into standard contractual clauses approved by the European Commission or UK authorities; (b) relying on adequacy decisions issued by relevant authorities; or (c) implementing other lawful transfer mechanisms recognized under applicable law.

You may request additional information about these safeguards by contacting us using the details provided below.

14. Children’s Privacy

The Site is intended for individuals who are at least the age of majority in their jurisdiction of residence and capable of forming legally binding agreements. The Site is not directed to persons under the age of majority in their jurisdiction of residence and who are not capable of forming legally binding contracts under applicable law, and we do not knowingly collect personal information from such individuals through the Site. Additionally, we do not sell or share personal information of consumers we know to be between the ages of 13 and 16 without their affirmative authorization, as required by applicable state law. If we learn that we have collected personal information from any such person in a manner not permitted by law, we will take reasonable steps to delete that information.

If you believe a child has provided personal information to us through the Site, please contact us at contact@vyometx.com.

15. Third-Party Links and Services

The Site may contain links to third-party websites, platforms, services, filings repositories, publications, or other resources. This Privacy Policy does not apply to third-party websites or services, and we are not responsible for their privacy practices, content, or policies.

If you choose to access a third-party website or service, you should review that third party’s privacy notice and terms before providing any information or using the service.

16. Changes to This Privacy Policy

We may revise this Privacy Policy from time to time in our discretion. When we do, we will post the updated version on the Site and update the Effective Date above. If changes are material, we may provide additional notice by means appropriate to the nature of the change and applicable law.

Your continued use of the Site after any updated Privacy Policy becomes effective constitutes your acknowledgment and agreement to the revised Privacy Policy to the extent permitted by law.

17. Governing Law

THIS PRIVACY POLICY AND ANY DISPUTE, CLAIM, OR CONTROVERSY ARISING OUT OF OR RELATING TO THE SITE OR THIS PRIVACY POLICY (INCLUDING NON-CONTRACTUAL DISPUTES OR CLAIMS) SHALL BE GOVERNED BY AND CONSTRUED IN ACCORDANCE WITH THE LAWS OF THE STATE OF DELAWARE, WITHOUT REGARD TO ITS CONFLICTS OF LAW PRINCIPLES.

SUBJECT TO ANY APPLICABLE ARBITRATION PROVISION, YOU AGREE THAT ANY LEGAL ACTION OR PROCEEDING ARISING OUT OF OR RELATING TO THIS PRIVACY POLICY SHALL BE BROUGHT EXCLUSIVELY IN THE STATE OR FEDERAL COURTS LOCATED WITHIN THE STATE OF DELAWARE, AND YOU HEREBY IRREVOCABLY SUBMIT TO THE PERSONAL JURISDICTION AND VENUE OF SUCH COURTS AND WAIVE ANY OBJECTION BASED ON INCONVENIENT FORUM OR ANY OTHER BASIS.

TO THE FULLEST EXTENT PERMITTED BY APPLICABLE LAW, YOU AND COMPANY EACH HEREBY IRREVOCABLY WAIVE ANY RIGHT TO A TRIAL BY JURY IN ANY LEGAL PROCEEDING ARISING OUT OF OR RELATING TO THIS PRIVACY POLICY.

18. Contact Information

If you have questions about this Privacy Policy or our privacy practices, or if you would like to submit a privacy request, please contact us at contact@vyometx.com