SmartAlex Children's Privacy Notice

Version 1.0 · Effective July 8, 2026 · THERCSGROUP PTE. LTD. (trading as SmartAlex, Singapore Reg. No. 202543608D)

1. Purpose and scope

This Children's Privacy Notice (this "Notice") is issued by THERCSGROUP PTE. LTD., trading as SmartAlex ("SmartAlex", "we", "us", "our"). It explains our position on the personal data of children in connection with the SmartAlex platform, websites, applications, and APIs (the "Services").

The Services are a business-to-business tool. They are designed and sold for use by organisations to build and operate AI voice agents and related workflows. The Services are not a consumer product, are not marketed to families or minors, and are not intended to be used by children.

This Notice should be read together with our Privacy Policy, which describes in full how we handle personal data across the Services. Where this Notice and the Privacy Policy address the same subject, this Notice governs on the specific question of children's data.

2. Our position

Our position on children and the Services is as follows:

• The Services are not directed to, and are not intended for use by, children under the age of 18 (a "Child", and "children" accordingly).
• We do not knowingly collect, use, sell, or otherwise process the personal data of a Child through the Services in our capacity as the operator of the platform.
• Account holders must be adults who are at least 18 years of age and who register and use the Services on behalf of a business or other organisation, in a professional capacity.
• We do not design, promote, or hold out the Services as a product or service for children, and we do not create features intended to appeal to children.

If you are under 18, please do not create an account, submit personal data to us, or otherwise use the Services.

3. If we learn we have a Child's data

If we become aware that we have collected personal data from a Child under the age of 18 without appropriate authorization, we will take reasonable steps to delete that data from our systems, or to otherwise bring the processing into compliance with applicable law, as soon as is reasonably practicable.

If you believe that a Child has provided personal data to us, or that personal data relating to a Child has been made available to us through the Services, please alert us at privacy@getsmartalex.com. When you contact us, please provide enough detail for us to locate the relevant data (for example, the account, workspace, or context involved) so that we can act on your request. We will review the report and, where appropriate, remove the data.

4. Customer responsibility

The organisation that subscribes to and configures the Services (the "customer") decides how its AI agents are used, including who those agents contact and what data is processed. SmartAlex does not choose the audiences, contacts, or recipients for a customer's campaigns or agents.

Accordingly, the customer is responsible for the lawfulness of its own use case. In particular, the customer:

1. must not use the Services to intentionally target, market to, or collect personal data from children, except where the customer has a valid lawful basis and all required consents to do so;
2. must comply with all children's privacy laws that apply to it and to its use of the Services, which may include, by way of example, the United States Children's Online Privacy Protection Act (COPPA) in relation to children under the age of 13 in the United States, and the rules on children's consent under the EU General Data Protection Regulation (GDPR), such as the age thresholds for information society services set out in Article 8 of the GDPR;
3. is responsible for any age assurance, age-gating, parental notice, and parental or guardian consent required for its own use case; and
4. must not represent to any person that SmartAlex has assumed responsibility for age verification or children's consent on the customer's behalf.

Use of the Services is also subject to our Acceptable Use Policy, which prohibits unlawful and abusive use of the Services.

5. End users who are children

Some customers may, in their own use case, interact with end users who could include children. Where that happens, the customer is the controller (or the equivalent "responsible party" or business) for that processing, and SmartAlex acts as the operator, processor, or service provider that processes personal data on the customer's documented instructions.

In that situation, the customer is responsible for:

• establishing a valid lawful basis for processing the personal data of any Child;
• obtaining and recording any parental or guardian consent that applies to that Child under the laws relevant to the customer; and
• providing any notices to Children or their parents or guardians that those laws require.

Our processing of personal data on behalf of a customer, including any personal data relating to a Child, is governed by our Data Processing Addendum. Nothing in this Notice makes SmartAlex the controller of personal data that a customer processes through the Services for the customer's own purposes.

6. Age assurance and verification

We may take reasonable steps to detect and remove accounts that appear to belong to a Child, or that appear to be used in a manner inconsistent with the business-only nature of the Services. Those steps may include reviewing account information, suspending or terminating access, and deleting associated data.

We do not, however, operate the Services as a service for children, and we do not carry out age verification of a customer's own end users. Age assurance and verification within a customer's use case are the responsibility of that customer, as described in sections 4 and 5.

7. Relationship to other documents

This Notice supplements, and does not replace, our other legal terms. It should be read together with:

• the Privacy Policy, which describes how we handle personal data generally;
• the Acceptable Use Policy, which sets out prohibited uses of the Services; and
• the Data Processing Addendum, which governs our processing of personal data on behalf of a customer.

If there is any conflict between this Notice and one of those documents on the specific subject of children's personal data, this Notice governs.

8. Updates and contact

We may update this Notice from time to time to reflect changes in the Services, in applicable law, or in our practices. When we make a material change, we will update the version and effective date below.

If you have questions about this Notice, or you wish to report that a Child's personal data may have been provided to us, please contact:

• Privacy matters and Child data reports: privacy@getsmartalex.com
• Legal notices: legal@getsmartalex.com

This Notice is issued by THERCSGROUP PTE. LTD. (UEN 202543608D), 160 Robinson Road, #14-04 Singapore Business Federation Center, Singapore 068914, and is governed by the laws of the Republic of Singapore.

9. Version and effective date

This Children's Privacy Notice is version 1.0 and is effective from 8 July 2026.