This document given is the use of any personal information collected by ABCOMO ECOMMERCE PTE. LTD. or its affiliates (the “Company”) during the course of it providing any services to you in accordance with any client agreement that you have entered into with the Company.

1. Interpretation: In this document, the following terms have the meanings given to them below:

(a) AML/CFT Laws means the laws and regulations regarding anti-money laundering and countering financing of terrorism in Singapore.

(b) Authority means any government body established under any jurisdiction that, within that jurisdiction, administers any enactment relating to privacy or the holding of information.

(c) Client Agreement means any agreement entered into between you and the Company.

(d) Client Information means any information given to the Company by you for the purposes of, or ancillary to, any of the Services and includes at least the following:

(i) Your full name;

(ii) Your date of birth;

(iii) Your email address;

(iv) Your phone number;

(v) Your street and postal address;

(vi) Any photographic identification provided by you to the Company, including your driver’s license and/or passport;

(vii) The bank account from which you may deposit funds into any account operated by the Company, and into which the Company may deposit from time to time any funds due to you in accordance with the terms of the Client Agreement; and

(viii) Any information collected as part of your incidental use of the Services.

(e) Cookie means any alphanumeric identifier which the Company transfers to your computer through your web browser when you visit the Company’s website or any other platform.

(f) Data Storage Policy means the policy set out in the Schedule.

(g) Law means any common or customary law and any constitution, decree, judgment, legislation, order, ordinance, regulation, statute, treaty or other legislative measure, in each case of any jurisdiction.

(h) The Company means ABCOMO ECOMMERCE PTE. LTD., a company duly incorporated under the law of Singapore.

(i) Policy means the privacy policy set out in this document.

(j) Portal Account means the account available for use by you under the Client Agreement.

(k) PDPA means the Personal Data Protection Act 2012 of Singapore, as amended and supplemented from time to time.

(l) Services means any services provided by the Company to you under the Client Agreement.

2. General Intent: Any Client Information given by you to the Company during the course of, or as a consequence of, using the Services or as otherwise requested by us as a precondition to using the Services is governed by this Policy.

3. Holding of Confidential Information: Any Client Information will be:

(a) collected and held both physically and electronically by the Company’s registered physical address; and

(b) stored, as far as practicable, in accordance with the Data Storage Policy.

4. Authorisation: By entering into the Client Agreement, you agree and authorise the collection, use, disclosure, storage and retention of Client Information by the Company in accordance with this Policy.

5. Collection of Client Information: When you use the Services, the Company will collect information about you, through Cookies, which may be stored by the Company and you acknowledge that:

6. Cookies: Cookies may be used by the Company to:

(a) Track visitor use of the Company’s website and to compile statistical reports on that website’s activity;

(b) Compile aggregate information about areas of the Company’s websites that are visited most frequently;

but will not be used for collecting any information that can or may be used to identify you.

7. Use of Client Information: As part of the Company providing the Services and providing the Portal Account to you, the Company will or may use Client Information for the following purposes:

(a) As permitted by the Client Agreement;

(b) In undertaking any of the Services

(c) To any third parties for the purposes of obtaining any credit check, or for the purposes of completing any identity verification, including under the AML/CFT Laws or any other law.

(d) To detect, prevent, protect against fraud and financial crimes;

(e) To comply with any Law.

(f) For the purposes of communicating with you for the purpose of improving any of the Services;

(g) For the purposes of sending any targeted emails or text messages about any content the Company believes you may be interested in, or services which are provided by any of our business partners; to the exchange upon which any securities you wish to buy or sell using our services are traded;

(h) Any third parties who themselves provide services necessary or desirable for the Company to provide the Services to you;

(i) Any government authority where required by Law, including any Law relating to taxation in any jurisdiction such as the Foreign Account Tax Compliance Act (United States);

(j) To the Company’s own professional advisers;

(k) To any third-party where that third-party is, in the opinion of the Company, acting in good faith, potentially acquiring either all or any part of the Company’s business, or any shares the Company has issued.

8. Overseas Entities: By entering into the Client Agreement, the Client authorises the Company to disclose Client Information in accordance with this Policy to third-parties outside the jurisdiction of Singapore, and in such case:

(a) You acknowledge that such third parties may not be subject to the same or equivalent Law that applies to privacy in Singapore; and

(b) The Company will nonetheless take reasonable steps to ensure that any Client Information so supplied will not, so far as is practicable, be used by such third-party in any way materially different to how Client Information may be used either by the Company itself under this Policy or under Singapore Law generally.

9. Third Party and Unauthorised Use: Although the Company will encourage any person or parties to whom the Company has disclosed Client Information in accordance with this Policy to comply with privacy obligations equivalent to those imposed under the PDPA and/or this Policy:

(a) The Company cannot and does guarantee that in all circumstances any such third-party will so comply; and

(b) The Company accepts no liability and is not liable to the Client in any way whatsoever for the use or mis-use of Client Information:

(i) By any third-party to whom the Company has disclosed Confidential Information in accordance with this Policy;

(ii) By any third-party who has illegally accessed or obtained Client Information due to, for example, fraud or hacking

10. Retention of Information: The Company will retain any Client Information for:

(a) So long as the Client Agreement remains in place;

(b) For at least seven years after the Client Agreement has been terminated, or such longer time as the Company deems necessary or desirable:

(i) To fulfill the purposes set out in this Policy;

(ii) For the purposes of fraud prevention, safety, and security;

(iii) To comply with any Law;

(iv) To comply with any guidelines issued by any Authority; or

(v) To comply with best industry practice as determined by the Company.

11. Review of and Access to Client Information: If at any time you wish to access any Client Information that the Company is holding, you may contact the Company’s privacy officer by email at contact@abcomo.com, and in such case, the Company shall be entitled to charge a reasonable administration fee for making that information available.

12. Correction of Client Information: You may require that the Company correct any Client Information that is inaccurate or out of date, but the Company will only delete Client Information in accordance with the retention of information rules set out at clause 8 of this Policy.

13. Amendment of Policy: The Company may review or review this Policy from time to time, and such reviewed or amended Policy will become effective one calendar month after the date it is published on the Company’s website at 1^st Mar 2021.

SCHEDULE

DATA STORAGE POLICY

1. Security is the Company’s top priority. The Company and/or its group companies will strive at all times to ensure that Client Information will be protected against unauthorized or accidental access, processing or erasure.

2. The Company maintains this commitment to data security by implementing appropriate physical, electronic and managerial measures to safeguard and secure Client Information.

14. The secure area of the Company’s website, portal or App supports the use of Secure Socket Layer (SSL) protocol and 128-bit encryption technology – an industry standard for encryption over the Internet to protect data. When you provide the Client Information, it will be automatically converted into codes before being securely dispatched over the Internet.

15. The Company’s servers are protected behind “firewalls” and the Company’s systems are monitored to prevent any unauthorized access. Only your valid User ID and Password, which identify you uniquely, will allow you to log in to the Company’s secure website(s) and/or the Company’s applications or apps. This ensures that messages from authorized users only are admitted into the Company’s secure site(s).