Applications Privacy Policy — Visto Group

Visto Group SA and its affiliated companies (“We”) takes your privacy seriously. We are committed to process any personal information we collect (hereafter generally referred to as information) in full transparency, in accordance with applicable laws and regulations, and to ensure the accuracy, confidentiality and security of your information.

This privacy notice applies to the information We collect from you as an individual through our mobile applications (“Apps”) published on the Apple App Store.

By using our Apps you agree with this Privacy Policy and the processing of personal information described herein. If you do not agree please refrain from using our Apps.

This privacy notice is dated March 2026. It may be updated from time to time, in which case any such modification shall be mentioned within the Apps or on our website at visto.group.

1. What is personal information?

Personal information is any information that can enable the identification of an individual or a legal entity or that relates to an identified or identifiable individual or legal entity. Information may, as such, enable your identification (like your first and last names, email address or social security number), or may enable such identification and provide information when combined with one another (such as medical records, salary grade, role and function). In so far as any such information enables to identify you as a person or can be related to you, whether taken separately or combined with one another, it shall be considered as personal information.

2. What information do We collect from you?

Our Apps are designed to minimize data collection. We do not require account creation and do not collect personal information such as your name, email address or payment details. Payments for in-app purchases are handled entirely by Apple and are subject to Apple’s own privacy policy.

Information that We may collect through your use of our Apps may typically consist of the following:

• Location data: If you grant permission, our Apps may access your device’s location. This data is used exclusively to perform calculations within the App (such as determining location-dependent results). Your location is processed locally on your device, is not transmitted to our servers, and is not stored.

• Microphone access: If you grant permission, our Apps may access your device’s microphone. Audio data is used exclusively to perform real-time analysis within the App (such as music chord detection). Audio is processed locally on your device, is not recorded, is not transmitted to our servers, and is not stored. You may revoke microphone access at any time through your device settings

• Device and diagnostic information: Our Apps may automatically collect basic diagnostic data, such as crash reports, device model and operating system version. This information does not identify you personally and is used solely to improve the stability and performance of the Apps.

We do neither collect nor process any sensitive data (such as, for instance, your religion, sexual orientation or health related data).

3. Why do We collect such information?

The limited information described above is collected for the following purposes:

• Location data: To perform location-dependent calculations within the App. This processing is based on your explicit consent, which you may withdraw at any time by revoking location permissions in your device settings.

• Microphone access: To perform real-time audio analysis within the App, such as identifying musical chords. This processing is based on
  your explicit consent, which you may withdraw at any time by revoking microphone permissions in your device settings.

• Diagnostic information: To improve the stability, performance and features of our Apps. This processing is based on our legitimate interest in providing reliable applications.

We do not use your information for advertising, profiling, or marketing purposes. We do not build user profiles. We do not track you across apps or websites.

4. Who might We share your information with?

We do not sell, rent or trade your personal information to third parties.

We may share limited diagnostic information with:

• Apple: Crash reports and diagnostic data may be shared with Apple as part of the standard App Store distribution process, subject to your device settings.

• Any third party to which We are ordered or obliged to disclose such information as a result of a Court order, governmental authority and/or by law.

• Any relevant entity for emergency purposes that compel such disclosure.

We do not use third-party analytics services, advertising networks or social media tracking tools within our Apps.

5. Where will your information be stored?

Location data is processed locally on your device and is not transferred to any server.

Should any diagnostic information be collected, it will be stored and normally processed either in Switzerland or in the European Economic Area (EEA) where our servers are based.

When We transfer information from Switzerland to other countries outside the European Economic Area, We shall only do so in accordance with the law, notably by entering into data transfer agreements and Standard Contractual Clauses with the relevant entities.

6. How do We protect your information?

We are committed to protecting the security of your personal information.

Location data never leaves your device. It is processed in memory only and is not written to disk or transmitted over the network.

We use a variety of security technologies and procedures to help protect any diagnostic information from unauthorized access, use, modification or disclosure to an appropriate level depending upon the sensitivity of the information.

7. How long do We retain your information?

• Location data: Not retained. It is used in real time for calculations and immediately discarded. It is never stored on your device or on our servers.

• Diagnostic information: Crash reports and performance data, if collected, may be retained for up to twelve months for the purpose of improving application stability, after which they are deleted.

We do not maintain user accounts and therefore do not retain any account-related information.

8. Children’s privacy

Our Apps do not knowingly collect personal information from children under the age of 13 (or the applicable age in your jurisdiction). If you believe that a child has provided us with personal information, please contact us at the address below and we will take steps to delete such information.

9. What rights do you have in respect of your information?

You have the right (i) to submit an information request in order to learn what categories of information we are processing about you, for what purposes, how we share your information with others and how long we store your information, (ii) to request that we rectify incorrect information about you, (iii) to request that we stop or limit processing your data and (iv) to request that we provide you with your information in a format suitable for migration.

Given that our Apps collect virtually no personal information and do not require user accounts, in most cases no personal information will be held by us.

You may at any time revoke location permissions through your device’s settings (Settings > Privacy & Security > Location Services).

If you would like to submit such request or should you have any question related to such processing or to this privacy notice, you may contact us by sending an email to: info@visto.group.

In rare cases we may — to the extent permitted by applicable law — have to partially or entirely refuse to comply with such requests. In such case we shall inform you about the reasons of such refusal.

You are entitled to lodge a complaint in respect of our processing of your information with the supervisory authority. If you are a resident of Switzerland the complaint can be lodged at the following address:

Swiss Federal Data Protection and Information Commissioner Feldeggweg 1 3003 Berne Switzerland

For more information please see www.edoeb.admin.ch. If you are a resident of a country of the European Economic Area, the complaint can be lodged with the data protection authority of your country.

10. Controller and Representative

The controller of information collected through the Apps is:

Visto Group SA Avenue Louis-Casai 81 1216 Cointrin +41 22 732 53 72 info@visto.group

11. Governing Law and Jurisdiction

This Policy is subject to Swiss law, at the exclusion of its Private International Law Statute. Any dispute arising out of or related to this Policy shall be submitted to the exclusive jurisdiction of the Court of Chambre patrimoniale of the Geneva State, seated in Geneva, Switzerland.