We at FOMO Pay Pte Ltd (“FOMO Pay” “we,” “us,” “our”) know that our users and customers (“you,” “your”) care about how your personal information is collected, used and shared, and we take your privacy seriously. Please read this Security & Privacy Policy (“Policy”) to understand how FOMO Pay may collect, use and disclose your personal data, whether through the FOMO Pay website at http://www.fomopay.com (“Site”), the FOMO Pay mobile application (“App”), or otherwise in the course of our normal business operations.

Consent

By accessing the Site, App and/or providing personal data to FOMO Pay, you hereby acknowledge that you have read this Policy and that you consent to the collection, use and disclosure of your personal data by FOMO Pay in accordance with this Policy. If you do not consent to the terms of this Policy, please do not access the Site, App or provide your personal data to FOMO Pay.

FOMO Pay does not knowingly collect or solicit personal data from those below the age of 18, or knowingly allow such persons to register an account with FOMO Pay (“Account”). If you are under 18, please do not use the Site or App, or attempt to register an Account or send any personal data about yourself to us.

What is Personal Data?

“Personal data” means data about a person who can be identified (i) from that data, or (ii) from that data and other information to which FOMO Pay has or is likely to have access.

What personal data does FOMO Pay collect?

We may gather various types of personal data of our users and customers, as explained more fully below.

Data that is voluntarily provided. FOMO Pay collects personal data that you voluntarily provide to us, whether through the Site, App or other platforms or channels (such as through email, telephone and other forms of communication). At various places on the Site or App, or in the course of obtaining the services provided by FOMO Pay, you may be required to provide certain personal data such as your full name, email address, address, country of residence, telephone number and other personal information, in order to access or use certain features or services of the Site or App, or to otherwise obtain our services. For example, personal data may be collected when you register an Account, make a purchase, enter a contest, promotion or survey, fill up a form, provide comments, suggestions or feedback, or when you contact our customer service or helpdesk via email, phone or other channels. You can always choose not to provide your personal data, but you may not be able to access or use certain features or services of the Site or App, or to obtain certain services from us.

Data that is sent automatically. In addition, FOMO Pay collects data that is sent automatically by your web browser, computer, mobile or tablet device. This may include your IP address, the address of the web page you were visiting when you accessed our Site, date and time of your visit, information about the device you are using and other information. Please check the settings of your browser and/or device if you want to know what data is automatically sent or if you wish to change your settings.

How do we use your data?

Generally, we collect personal data in order to provide our products and services to you, and to personalize and improve our services and your user and customer experience with FOMO Pay. Personal data collected may be used:

• a) to process, record, monitor and fulfil your orders and deliveries;
• b) to verify and process your personal particulars and payment;
• c) to communicate with you, including to confirm and update you on the status of your orders and deliveries, and respond to your queries and requests;
• d) to improve our products or services;
• e) to inform you of promotions, offers, surveys, events, products and services, which may be of interest to you;
• f) to conduct marketing research, user profile and statistical analysis;
• g) to customize your online experience according to your chosen interests and preferences and enhance your current and future visits to the Site, use of the App and customer experience with us;
• h) to update and back-up our records;
• i) to reduce credit risk, detect and protect us against error, fraud and other criminal activity;
• j) to comply with law, the requests of law enforcement and regulatory officials, or orders of court;
• k) to enforce our legal rights and remedies; or
• l) for such other purposes notified to you on or before collection or use of the data.

Who do we disclose your data to?

We do not rent, trade or sell your personal data. Your personal data will not be disclosed by FOMO Pay to any third party, except to:

• a) any affiliate, subsidiary or partner of FOMO Pay;
• b) our technology, marketing and logistics service providers;
• c) credit card and payment processing companies;
• d) lawyers, auditors, professional advisors and investors of FOMO Pay; or
• e) any other agents, service providers or subcontractors acting for or on behalf of FOMO Pay,

to the extent required to carry out the purposes set out in Section D, or to do anything at your request; or where you expressly consent to such disclosure; or where such disclosure is required or permitted by applicable law, statute, stock exchange regulation or by-law, regulatory or governmental order or court order.

From time to time, we may collaborate with other third parties to organize joint marketing and promotional campaigns, offers or contests, and may require disclosure of your information to such third parties. For example, where a promotion or Voucher Code is specially offered to customers of our third party partner, we may share your information with that partner to the extent relevant to such promotional campaign. In some cases, you may not be able to enjoy the promotion, offer or participate in the contest, unless you consent to disclosure to our partner of your information.

Recipients of your personal data may be located outside Singapore. You agree that we may transfer your personal data to our affiliates, subsidiaries and/or other third parties located outside of Singapore, as long as the personal data is handled in accordance with this Policy and all applicable laws. FOMO Pay will ensure recipients of your personal data are legally bound to provide a standard of protection for your personal data comparable to the protection afforded under the Personal Data Protection Act 2012 (No. 26 of 2012).

How long do we retain your data?

Personal data provided by you will be retained as long as the purpose for which the data was collected continues. Thereafter, FOMO Pay will destroy or delete the information, or remove the means by which the data can be associated with you, unless its retention is required to satisfy legal, regulatory, accounting or other business requirements or to protect FOMO Pay’s interests.

Is your data secure?

As your Account is protected by a password for your privacy and security, we ask that you take steps to protect against unauthorized access or use of your Account. Please select and protect your password appropriately and limit access to your device and browser by signing off after you have finished accessing your Account. You are responsible for any loss, theft and compromise of your password and Account Information, and any activity on your Account that takes place through unauthorized password use.

We understand the importance of keeping your personal data private and secure. We therefore put in place security arrangements to protect your privacy and personal data, in a manner that we believe is reasonably appropriate to prevent unauthorized access, collection, use, disclosure, copying, modification, disposal or similar risks. Please be informed that despite our best efforts, no security measures are impenetrable. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of your personal data. FOMO Pay does not warrant or guarantee in any way that your personal information or private communications will always remain private and/or safe. FOMO Pay hereby disclaims any responsibility or liability directly or indirectly arising out of or in connection with, any loss, theft, or unauthorized access, collection, use, disclosure, copying, modification, disposal or similar actions with regard to any personal data held or maintained by us, except to the extent caused by our fault or negligence

Online Policy & Terms and Conditions (Version: December 2016)