Privacy Policy

NEKSAI Inc.

Last Updated: February 10, 2026

This Privacy Policy (this “Policy”) describes the manner in which Neksai Inc., a company with headquarter address at the offices of Conyers Trust Company (Cayman) Limited, Cricket Square, Hutchins Drive, PO Box 2681, Grand Cayman, KY1-1111 and is represented by CEO Tran Anh Tuan (“Neksai,” “we,” “us,” or “our”), collects, uses, processes, discloses, and safeguards personal information in connection with the operation of NEM:Recall and related applications, websites, software, and services (collectively, the “Service”).

By accessing or using the Service, you acknowledge that you have read and understood this Policy and agree to the collection, use, and disclosure of personal information as described herein.

1. Scope of This Policy

This Policy applies to personal information collected by Neksai through the Service. It does not apply to information collected offline or by third parties not controlled by Neksai.

2. Categories of Information Collected

Neksai may collect the following categories of personal information:

(a) Information Provided by Users

• Account registration information (such as name, username, and email address)

• Communications submitted to Neksai (including support requests and feedback)

• Content voluntarily submitted through the Service

(b) Information Collected Automatically

• Device and technical information (including IP address, browser type, operating system)

• Usage and log data (including access times, pages viewed, gameplay activity)

• Identifiers collected through cookies or similar technologies

• Information received from platform providers, service providers, or business partners, to the extent permitted by applicable law

3. Data Controller; Data Processor; Publishing Entity

For purposes of applicable data protection laws:

• Neksai Inc. is the data controller and the sole owner of all personal information collected, processed, or otherwise handled in connection with the Service.

• Neksai Inc. retains all authority and responsibility with respect to the purposes and means of processing personal information.

The Service may, from time to time, be published, distributed, hosted, or operationally supported by one or more affiliated or third-party entities, including, on a temporary basis, AI AVATAR VIETNAM COMPANY LIMITED (“AIA VN”) and Neksai Corporation(Neksai Cor.). AIA VN and Neksai Cor. act solely as a data processor and service provider on behalf of Neksai and processes personal information only in accordance with Neksai’s documented instructions, applicable data processing agreements, and applicable law. For the avoidance of doubt: AIA VN and Neksai Cor. do not own, control, or determine the use of any personal information collected through the Service; AIA VN and Neksai Cor. do not develop, own, or hold any intellectual property rights in the Service; all data ownership, control, and responsibility remain exclusively with Neksai. Neksai may, at its discretion, change the publishing entity, hosting provider, or service providers supporting the Service from time to time. Any such change shall not affect data ownership, user rights under this Policy, or Neksai’s role as data controller.

4. Purposes of Processing

Neksai processes personal information for the following purposes:

• To provide, operate, maintain, and improve the Service

• To administer user accounts and authenticate users

• To monitor, prevent, and address fraud, abuse, security incidents, or technical issues

• To communicate with users regarding the Service

• To enforce the Terms of Use and other applicable agreements

• To comply with legal, regulatory, and contractual obligations

Neksai does not sell personal information.

5. Legal Bases for Processing (Where Applicable)

Where required by applicable data protection laws, Neksai relies on one or more of the following legal bases:

• Performance of a contract

• Legitimate business interests (including security, fraud prevention, and service improvement)

• Compliance with legal obligations

• User consent, where required

6. Disclosure of Personal Information

Neksai may disclose personal information:

• To service providers and contractors acting on Neksai’s behalf and subject to confidentiality, data-processing, and security obligations consistent with this Policy

• To affiliates or successors in interest, where permitted by law

• In response to lawful requests by public authorities, courts, or regulators

• To protect the rights, property, or safety of Neksai, its users, or others

• In connection with a merger, acquisition, reorganization, or sale of assets

Neksai does not authorize third parties to use personal information for their own independent purposes.

7. Cookies and Similar Technologies

The Service may use cookies and similar technologies to facilitate operation, enhance security, analyze usage, and improve performance. Users may control cookies through browser settings; however, disabling cookies may limit certain features of the Service.

8. Data Retention

Personal information is retained only for so long as reasonably necessary to:

• Fulfill the purposes described in this Policy

• Comply with applicable legal and regulatory requirements

• Resolve disputes and enforce agreements

9. Data Security

Neksai implements reasonable administrative, technical, and organizational safeguards designed to protect personal information against unauthorized access, disclosure, alteration, or destruction. Notwithstanding the foregoing, no method of transmission or storage is completely secure, and Neksai cannot guarantee absolute security.

10. User Rights

Subject to applicable law, users may have the right to:

• Request access to personal information

• Request correction or deletion of personal information

• Object to or restrict certain processing activities

• Withdraw consent where processing is based on consent

Requests may be submitted using the contact information below. Neksai may require verification of identity before responding.

11. International Data Transfers

Personal information may be transferred to, processed in, and stored in jurisdictions other than the user’s country of residence. Neksai takes reasonable measures to ensure that such transfers comply with applicable data protection laws.

12. Children’s Privacy

The Service is intended solely for individuals eighteen (18) years of age or older. Neksai does not knowingly collect personal information from minors.

13. Amendments to This Policy

Neksai reserves the right to amend or update this Policy at any time. Continued use of the Service following the effective date of any amendment constitutes acceptance of the revised Policy.

14. Contact Information

Neksai Inc.

Email: legal@neksai.com