DOMAIN REGISTRATION SERVICES PRIVACY NOTICE ADDENDUM

as of September 22, 2025

Please review the below privacy notice addendum in addition to Sollutium EU Sp z o.o. (“we,” “us” or “Sollutium”) Privacy Policy if you purchased domain registration services from Sollutium.

INFORMATION COLLECTION

When you purchase Domain Registration services for top level domains (“TLDs”), as the domain Registrar, we are required to collect the following personal information from you (collectively, “Personal Information”):

• Registrant Name
• Registrant Organization (where applicable)
• Registrant Address
• Registrant Email
• Registrant Fax (where applicable)
• Registrant Phone number
• Administrative Contact
• Administrative Contact Organization (where applicable)
• Administrative Contact Address
• Administrative Contact Email
• Administrative Contact Fax (where applicable)
• Administrative Contact Telephone Number
• Technical Contact
• Technical Contact Organization (where applicable)
• Technical Contact Address
• Technical Contact Email
• Technical Contact Fax (where applicable)
• Technical Contact Telephone Number
• Billing Contact
• Billing Contact Organization (where applicable)
• Billing Contact Address
• Billing Contact Email
• Billing Contact Fax (where applicable)
• Billing Contact Telephone Number

We retain this Personal Information for the duration of the domain registration and, in accordance with ICANN’s Registrar Accreditation Agreement, for up to two (2) years following the end of the domain registration period.

Our collection of Personal Information is necessary to comply with contractual obligations we have with the Internet Corporation for Assigned Names and Numbers (“ICANN”) and with certain TLD registries operators (“Registries Operators” “Registry Operator”) so that you can validly register your domain name. In addition to Personal Information, our contracts with some Registries Operators may require us to collect other personal information for the registration of a TLD such as certain professional affiliations, identification or other qualifiers (“Additional Personal Information”).

UP-TO-DATE INFORMATION; USE OF INFORMATION AND EXPIRATION

You agree to notify Sollutium within five (5) business days when any of the information you provided as part of the registration process changes. It is your responsibility to keep this information current and accurate. Failure by you, for whatever reason, to provide Sollutium with accurate and reliable information on an initial and continual basis shall be considered a material breach of the Domain Registration Agreement and a basis for suspension and/or cancellation of the domain name. We may periodically send you requests regarding the accuracy of your information. Failure by you, for whatever reason, to respond within five (5) business days to any inquiries made by us to determine the validity of the information provided by you shall also be considered a material breach of the Domain Registration Agreement and a basis for suspension and/or cancellation of the domain name. You agree to retain a copy for your records of the receipt for the purchase of your domain name.

DISClOSURE OF INFORMATION

• Public Whois. Our contracts with ICANN and other Registry Operators require us to make certain domain name information (“WHOIS Information”) available and accessible to the public through a WHOIS search, as required by ICANN/Registry Policy (the “WHOIS Directory”). The WHOIS Directory is a publicly accessible database that lists WHOIS Information, including a particular domain name, the name server(s) to which the domain name points, and the domain name’s creation and expiration dates. Except for natural persons in the EU/EEA (as described below) and/or in cases where Domain Privacy Service has been purchased, your Personal Information could be displayed in the WHOIS Directory.
• EU/EEA natural persons. Notwithstanding the foregoing, pursuant to the European Union’s General Data Protection Regulation 2016/679, or GDPR, if you are a EU/EEA natural person (as defined by the GDPR), other than as specified in this addendum, our publication of WHOIS Information will not contain any Personal Information. Accordingly, we will not display Personal Information of a EU/EEA natural person in the WHOIS Directory.
• Transfer Out. If you initiate a transfer out of a domain name away from us as the registrar of record, pursuant to our contract with ICANN, we may need to publish your registrant email address obtained from your Personal Information in the WHOIS Directory for a period of approximately five (5) calendar days. After this period and assuming a valid transfer has occurred, you would cease to be our customer for that domain name and your WHOIS Information would be managed by the gaining registrar.
• Certain Registries. Registries Operators are third party providers of TLDs that are independent of domain registrars. If required by contract with a particular Registry Operator, we may be obligated, as a domain registrar of domains provided by the Registry Operator, to provide Personal Information and Additional Personal Information to such Registry Operator to successfully complete your domain name registration. If we provide your Personal Information and Additional Personal Information to a Registry Operator, the Registry Operator has its own obligation to comply with applicable data privacy laws. Some Registry Operators are located outside the European Economic Area (EEA) and act as independent data controllers. We ensure that any such transfers are done in compliance with applicable data protection laws, including GDPR mechanisms such as Standard Contractual Clauses (SCCs), where required.
• Data Escrow. Our contract with ICANN requires us to deposit the Personal Information collected with a secure third-party escrow provider who acts solely as a holder of the data. The escrow provider stores this information solely for purposes of data recovery in case of registrar failure and is contractually prohibited from using it for any other purpose.
• Permitted Disclosures. We may also disclose your Personal Information when required by the rules, regulations and policies of ICANN, including but not limited to the Uniform Domain-Name Dispute-Resolution Policy (UDRP) and any applicable law, regulation, legal process or government request, court orders or responses to the owner of the information. This also includes the exchanging of information with other companies and services with fraud protection purposes.

Domain Privacy Service

If you purchased domain privacy services ("Domain Privacy"), you agree that your Registration Information, as defined in the Domain Registration Agreement will be replaced in any public WHOIS search with information provided by Sollutium as determined in its sole discretion (the "Private WHOIS Contact Information").

Although the Private WHOIS Contact Information will appear in any public WHOIS search result, you are solely responsible for resolving any and all monetary, creditor, or other claims that arise in connection with a legal or other dispute involving your domain name registration. Use of the Domain Privacy service in no way alleviates your obligation to provide valid and accurate Registration Information and to update and correct such information pursuant to the terms of the Domain Registration Agreement.

Please note, use of Domain Privacy does not shield you from liability arising from your use of the domain name. You remain the Registered Name Holder and are responsible for any harm caused by the domain’s use, including by third parties.

The Domain Privacy service is NOT a general mail forwarding service. You agree that you will not provide any third party with the Private WHOIS Contact Information for the purpose of having such third party transmit communications to you. Sollutium may immediately terminate the Domain Privacy service and, at its sole option, disclose the Registration Information in the event that you breach the Agreement.

Notwithstanding anything to the contrary, you agree that Sollutium may, but is not obligated to, review and forward communications in connection with your domain name that it receives. You hereby authorize Sollutium to receive, sort, open, forward, and destroy any and all mail sent to our address at our sole discretion. You specifically acknowledge that Sollutium is not obligated but may forward to you certified or traceable courier mail, legal notices, or postal mail; however, Sollutium will NOT forward "junk" mail or other unsolicited communications (whether delivered through fax, postal mail, or telephone), and you further authorize Sollutium to either discard all such communications or return all such communications to the sender. You agree that: (i) postal mail may be forwarded via regular mail forwarding or scanned and emailed electronically to the email address listed by you in the Registration Information; (ii) emails will be forwarded to the email address listed by you in the Registration Information; and (iii) callers will be directed to use the mailing or email address listed on the Private WHOIS Contact Information and we will forward such mail or email pursuant to the terms of this section; we will not relay phone messages to you. You agree to waive any and all claims arising from your failure to receive communications directed to your domain name but not forwarded or referred to you by Sollutium.

If any domain name for which you are using the Domain Privacy service is transferred to another registrar, Domain Privacy will automatically cease and no refund will be given for any unused portion of the service.

Failure to renew the Domain Privacy service while your domain name registration is still valid will result in the Domain Privacy being suspended, terminated, or canceled, and your Registration Information will be displayed in any public WHOIS search. Domain Privacy Service is provided for free, and the ability to purchase the Domain Privacy Service will be described on the Domain Purchase page on our website (https://vsys.name) or in your Account. In the event you are provided with free Domain Privacy Service with the registration of a domain name, you acknowledge and agree that such free Domain Privacy Service will only be available with a valid purchase and may be terminated if the domain name is deleted or canceled.

Sollutium expressly reserves the right, in its sole discretion and without any liability to you whatsoever, to suspend or cancel your use of the Service and/or reveal the Registration Information in any public WHOIS search or to any third party at any time without notice to you:

• To comply with any applicable laws, rules, regulations or requirements, or with any subpoenas, court orders, official government inquiries or requests of law enforcement;
• To comply with ICANN's Uniform Domain Name Dispute Resolution Policy;
• To resolve any and all third-party claims, whether threatened or made, arising out of your use of the Domain Privacy service, including without limitation, to avoid a dispute of any claim that the registered domain name violates or infringes a third party's trademark, trade name, or other legal rights;
• In the event you breach any provision of Domain Registration Agreement or any other agreement you've entered into with Sollutium, including, but not limited to, the Terms of Service;
• To comply with the rules, procedures, or practices of the registry that governs the domain name extension receiving the Domain Privacy service and to protect the integrity and stability of the applicable domain name registry;
• To avoid any financial loss or legal liability (civil or criminal) on the part of Sollutium, its parent companies, subsidiaries, affiliates, shareholders, agents, officers, directors, or employees;
• To prevent inappropriate activity that comes to Sollutium attention, including without limitation if you are using Domain Privacy to hide your involvement in illegal or morally objectionable activities, including without limitation, activities that are intended to or otherwise: (i) appeal purely to the prurient interests of third parties; (ii) defame, embarrass, harm, abuse, threaten, or harass third parties; (iii) violate Polish laws and/or other foreign/international laws; (iv) involve hate crimes, terrorism, or child pornography; (v) are tortious, vulgar, obscene, invasive of a third party's privacy, racially, ethnically, or otherwise objectionable; (vi) impersonate the identity of a third party; (vii) harm minors in any way; or (viii) relate to or transmit viruses, Trojan Horses, access codes, backdoors, worms, time bombs, or any other code, routine, mechanism, device or item that corrupts, damages, impairs, interferes with, intercepts or misappropriates any software, hardware, firmware, network, system, data, or personally identifiable information.

Pursuant to paragraph 3.7.7.3 of ICANN's Registrar Accreditation Agreement ("RAA"), you agree that if you license use of a Registered Name (as that term is defined in the RAA) to a third party, you are nonetheless the Registered Name Holder of record (as that term is defined in the RAA) and are responsible for providing the full contact information and for providing and updating accurate technical and administrative contact information adequate to facilitate timely resolution of any problems that arise in connection with the Registered Name. A Registered Name Holder licensing use of a Registered Name according to this provision shall accept liability for any harm caused by wrongful use of the Registered Name, unless the Registered Name Holder discloses the current contact information provided by the licensee and the identity of the licensee within seven (7) days to a party that provides the Registered Name Holder reasonable evidence of actionable harm.