European Data Protection Notice

Frontal Labs, Inc. ("Frontal," "we," "us," or "our") is a company incorporated under the laws of the State of Delaware, United States of America. Its registered address for legal service is 131 Continental Drive, STE 305, Newark, DE 19713, United States of America. Frontal is a fully remote company with team members located primarily in Portugal. This presence constitutes an establishment in the European Union for purposes of Article 3(1) of the GDPR.

1. EU ESTABLISHMENT AND LEAD SUPERVISORY AUTHORITY

Frontal has an establishment in Portugal by virtue of its operational team located there. Under Article 3(1) of the GDPR, the GDPR applies directly to Frontal's processing of personal data in the context of the activities of that establishment.

The lead supervisory authority for Frontal's cross-border processing is:

Comissao Nacional de Proteccao de Dados (CNPD) Av. Dom Carlos I, 134 1200-651 Lisboa Portugal Website: https://www.cnpd.pt/

EU data subjects may lodge complaints with the CNPD or with the supervisory authority in their Member State of residence.

2. UK AND SWISS DATA PROTECTION

Frontal does not currently maintain an establishment in the United Kingdom or Switzerland. Frontal relies on the UK International Data Transfer Agreement (UK IDTA) and the Standard Contractual Clauses (SCCs) for lawful transfers of personal data to the United States from the UK and Switzerland, respectively. Frontal will appoint Article 27 representatives in these jurisdictions as required and as its presence in those markets grows.

3. CONTACTING FRONTAL

Data subjects and supervisory authorities may contact Frontal directly:

Data Protection Officer: Email: dpo@frontal.dev

Privacy Inquiries: Email: privacy@frontal.dev

Registered Address: Frontal Labs, Inc. Attn: Data Protection Officer 131 Continental Drive, STE 305 Newark, DE 19713 United States of America

4. DATA PRIVACY FRAMEWORK

Frontal is pursuing certification under the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. Until certification is confirmed, Frontal relies on the Standard Contractual Clauses (SCCs) incorporated into its Data Processing Agreement as the primary transfer mechanism for personal data transferred from the EEA, UK, and Switzerland to the United States.

Frontal commits to resolve complaints about privacy and the collection or use of personal information. Individuals with inquiries or complaints should contact Frontal at privacy@frontal.dev. Frontal has committed to refer unresolved complaints to JAMS, an independent dispute resolution provider, at https://www.jamsadr.com/dpf-dispute-resolution. This service is provided free of charge.

Frontal's commitments are subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC). If Frontal transfers personal data to a third party acting as an agent, Frontal remains liable if the third party processes such personal data in a manner inconsistent with Frontal's obligations, unless Frontal proves it is not responsible for the event giving rise to the damage.

5. CONTACT

Frontal Labs, Inc. 131 Continental Drive, STE 305 Newark, DE 19713 United States of America Email: dpo@frontal.dev