POCKETYOU ASIA PRIVACY POLICY

PT. Dowlat Alib Indonesia (Pocketyou) highly respects the privacy and confidentiality of the personal data of our clients, customers, visitors and all other persons we interact with in the course of providing our services. While we are driven by the goal of providing customers with a better shopping experience, we also understand that a major concern that customers may have is the security of their personal information, and are committed to ensuring that all personal data provided to us is kept secure and only used for purposes that have been approved by our customers.

For starters, we only collect personal information that is necessary to provide the services you request, understand your needs, and better serve you overall. We collect as little information as possible. We provide our PocketYou Seller partners with only the information necessary to allow us to verify and track your rewards.

For example, we use cookies to track your transactions with our PocketYou Seller partners because such information is necessary to allow us to validate and credit cashback/rewards to your PocketYou account. Otherwise, we limit any data provided to an aggregate level. We do not under any circumstances sell your information. We are committed to implementing policies, practices and processes to protect the collection, use and disclosure of personal data that you provide to us, in accordance with applicable personal data protection laws. By using the Pocketyou App, you acknowledge that you have read, understood and agreed to all provisions contained in this Privacy Policy, which is an integral part of the Pocketyou Terms and Conditions. Capitalized terms used have the same meaning as those contained in the Pocketyou Terms and Conditions.

Described below are the details of our personal data protection policy. You can rest assured that PocketYou takes privacy and security seriously and welcomes any feedback on these matters. If you have any questions, comments or concerns, or require any assistance, please feel free to contact us at info@pocketyouasia.com or at support@pocketyouasia.com.

The purpose of this document is to inform you about how PocketYou manages, collects, uses and discloses Personal Data relating to you and other users of our websites, extensions for desktop web browsers (“web extensions”), software applications, mobile applications and other platforms. We conduct our business in accordance with relevant data protection laws, and have implemented additional measures to protect your personal information.

Your continued provision of our services to you and your continued use of such services shall be deemed to be our mutual agreement to comply with this Personal Data Protection Policy as updated from time to time on our website.

Personal data

In this Personal Data Protection Policy, “Personal Data” refers to any data, whether true or not, about an individual who can be identified from such data, or from such data and other information we have or are likely to have access to, including data in our records which may be updated from time to time.

Collection of Personal Data

The Personal Data that PocketYou may collect from you will depend on the products, services and promotions that you use or subscribe to. PocketYou collects this data to enable our services and our platform to function properly and to help us better understand how they work on different devices and browsers.

Typically, PocketYou will collect Personal Data relating to you when you:

1. Leave your contact details with us after attending our events e.g. marketing or community events and seminars.
2. Leave your contact details with us after visiting, using or installing (as the case may be) our websites, portals, mobile applications, social media platforms and browser extensions, or making an inquiry through other portals
3. Register for our services and/or submit any forms relating to our products and services.
4. Sign up for alerts or newsletters or respond to our marketing collateral, e.g. advertisements, brochures or flyers.
5. Contact us with questions or requests for assistance or otherwise interact or communicate with us or our employees, e.g. through our online interface, email, phone calls, faxes, text messages or face-to-face meetings.
6. Participate in competitions, prize draws, surveys or other similar events.
7. Submit your CV and job application form to us or Submit your CV to a recruitment company or job portal, which in turn forwards the same to us.
8. Referred to us by a business partner or third party.

The Personal Data collected may include information relating to:

1. Identity: This includes your full name, email address, date of birth, phone number, photo, device ID, IP address and payment-related information (e.g. your bank account details or account details with a payment service provider such as PayPal).
2. Interactions with us: This includes recordings of your phone calls with us, emails you send, and other records of any contact you have with us.
3. Accounts: Details relating to your PocketYou account.
4. Use of our services: This includes using cookies, our web extensions, or other browser-related methods to track information relating to your interaction with our website and our PocketYou Sellers (e.g. pages within our website that you visit, time spent on those pages, items and information searched for on our site, access times and dates, web pages you visited prior to our site, and information relating to clicks and redirects).
5. Preferences: This includes details you have shared with us about how you would like to be contacted, as well as your preferred products and brands.
6. Location: Some of the services we provide depend on your location. In order to function, those services need to know your location. Whenever you open and use or interact with our platforms (including our apps) on your mobile device or otherwise, we use location information to customize our services to your location. The services use the ‘background location’ of your various devices, including to send you notifications about offers/packs/interesting things near you. If you enable ‘background location’, our platform will from time to time inform us about the location of your device even if you do not directly interact with our platform.
7. In addition to collecting the above Personal Data directly from you or your authorized representative, PocketYou may also collect Personal Data from third parties (such as our business partners, Google, social media providers, or fraud prevention agencies), or from publicly available sources.
8. In addition, PocketYou uses “cookies”, which are small data files sent to your browser to store and track information about you when you enter our website. Cookies are used to track some of the above-mentioned information related to the use of our services.
9. Most internet browsers give you the option to turn off the processing of cookies but this may result in a loss of functionality, restrict the use of the website, and/or delay or affect the way it operates. In particular, it will not allow us to track your transactions with our PocketYou Seller partners and this means that we will not be able to credit you with cashback/gifts or provide you with your requested products and services. Therefore, you must configure our web extension and its usage.

Accuracy of Information and Third Party Consent

You must ensure that all Personal Data submitted to us is complete, accurate and correct. Your failure to do so may result in our inability to provide the products and services you have requested. Further, when you provide us with any Personal Data relating to a third party (including your spouse, child, parent and/or employee), you represent to us that you have obtained consent from the third party to provide their Personal Data to us.

Security of Personal Data

1. PocketYou ensures that all Personal Data collected will be stored safely and securely and has implemented strict measures to secure and protect your information. This includes:
2. Using secure 128-bit encrypted SSL connections on all our web pages where you submit Personal Data. 128-bit SSL encryption is the industry standard and is estimated to take at least a trillion years to crack.
3. Ensuring that Personal Data relating to you is only stored on appropriately secured servers to prevent security breaches.
4. Restricting access to information in our systems.
5. Implementing strict verification processes to prevent unauthorized access to Personal Data.
6. Securely destroying your personal information when it is no longer required for our business or legal processes.

Use of Personal Data

PocketYou does not sell or trade Personal Data collected online with third parties. We may use Personal Data relating to you to:

1. Manage the services we provide to you;

Primarily, we use your Personal Data to fulfill and process your orders and cashback. This includes using Personal Data relating to you to track your transactions with our PocketYou Seller partners, credit cashback rewards to your PocketYou account, and process the necessary payments related to those transactions. It also includes using Personal Data relating to you to enable or disable services, provide you with additional products, services, and benefits (such as promotions, loyalty programs, or rewards programs), and administer (sometimes in conjunction with our preferred partners) promotional events, contests, competitions, and corporate social responsibility projects.

2. Improve the services we provide for you;

We use your Personal Data to investigate complaints, claims and disputes. We also use your Personal Data to improve the performance of our sites and services and service delivery, such as when you make inquiries and provide feedback on the quality of our services. We may also use Personal Data relating to you to understand your preferences, develop new products and services, or personalize or improve the products and services we offer to you. That also includes using Personal Data relating to you to deliver relevant advertisements (such as those involving details of our or our selected partners’ products, services, special offers and awards), either to our customers in general, or which we have identified may be of interest to you in particular, to send you periodic newsletters with your prior consent or where permitted under local laws and regulations, or to promote benefits and offer rewards and promotions for which you are eligible.

Customer Service

This includes using Personal Data relating to you to respond to requests and inquiries made by you (or persons authorized by you), provide you with directory assistance, and provide you with updates regarding our products, services or policies.

Security and Compliance

This includes using Personal Data relating to you to detect and prevent fraud and other crimes (for example by conducting checks for money laundering, terrorism financing, and related risks), conduct internal audits, or fulfill legal, regulatory, and other requirements (including providing assistance to law enforcement, judicial, and other government agencies, responding to regulatory complaints, making relevant disclosures to regulatory agencies, conducting audit checks, due diligence and investigations, and taking steps deemed necessary by PocketYou in the event of lawsuits or potential lawsuits). That also includes using Personal Data relating to you for security and risk management purposes and to ensure the safety and security of our property and systems.

Job Application

This will include processing job applications, recruitment and selection as well as processing and

administration of employment records. We will not use Personal Data relating to you for purposes other than what we have informed you of, or which are permitted or required by local laws and regulations. We will only retain Personal Data relating to you only for as long as there is a business or legal need.

Sharing Personal Data

We may share personal data relating to you with:

A company within the Pocketyou group

PocketYou's business partners, vendors, agents, and service providers that we work with to deliver your subscription services. This would include PocketYou Seller partners, payment service providers, third party service providers engaged in connection with marketing promotions and services offered by PocketYou or its selected partners, and third party service providers who provide operational services to PocketYou (such as telecommunications, information technology, payment,

printing, billing, payroll, processing, technical services, training, market research, call center or other services to PocketYou). This also includes our professional advisors such as auditors and lawyers.

In the event of an actual or prospective business asset transaction (such as a merger, acquisition or asset sale), any business partner, investor, transferee or transferee for the purpose of facilitating such transaction.

Relevant regulators, statutory boards or authorities, or law enforcement agencies as required by any laws, rules, guidelines and regulations or schemes.

Personal Data disclosed above is only for relevant purposes (see those mentioned in this Policy) or to protect the interests of our customers.

In exceptional circumstances, PocketYou may also be required to disclose Personal Data relating to you, where there is reason to believe that disclosure is necessary to prevent a threat to life or health, or for law enforcement purposes.

In some cases, we encrypt, anonymize, and aggregate information before sharing it. Anonymizing means removing information from personally identifiable features. Aggregation means presenting information in groups or segments eg. age groups.

We will also ensure that the overseas organizations we work with adhere to strict

confidentiality and data protection obligations.

Bulletin

When you register as a user on PocketYou, we will also use the Personal Data you have provided to send you promotional emails from time to time to inform you of the latest offers, gifts, deals, products or services from PocketYou or our selected partners. You may unsubscribe from our promotional emails at any time via the unsubscribe function within the promotional email.

INTELLECTUAL PROPERTY RIGHTS

1. The entire Pocketyou Application and its supporting system including but not limited to: (a) the layout, design and appearance of the Pocketyou Application contained in or displayed on the Pocketyou Application media; (b) logos, photos, images, names, brands, words, letters, numbers, writings, and color arrangements contained in the Pocketyou Application; and (c) the combination of the elements as referred to in letters (a) and (b), are entirely Our Intellectual Property Rights and no other party co-owns the rights to the Application or to the layout, design and appearance of the Application.

2. You shall not from time to time (i) copy, modify, adapt, translate, create derivative works from, distribute, sell, transfer, publicly display, recreate, transmit, move, broadcast, decipher, or disassemble any part of or otherwise exploit the Pocketyou Application (including the support system and services therein) licensed to You, except as permitted in these Terms and Conditions, (ii) license, sublicense, sell, resell, transfer, assign, distribute or commercially exploit or make available to third parties and or software in any way; (iii) publish, distribute or reproduce in any way material protected by copyright, trademark, or other proprietary information without obtaining prior approval from us or the owner of the rights that license their rights to us, (iv) delete any copyright, trademark or other proprietary rights notices contained in the Pocketyou Application, (v) reverse engineer or access the Pocketyou Application and/or its supporting systems to (a) build a counter product or service, (b) build a product using similar ideas, features, functions or graphics, or (c) copy ideas, features, functions or graphics, (vi) launch automated programs or scripts, including, but not limited to, web crawlers, web robots, web indexers, bots, viruses, worms, or other similar applications and any programs that may make multiple server requests per second, create a heavy load or hinder the operation and/or performance of the Pocketyou Application, (vii) use robots, spiders, site search/retrieval applications, or any other manual or automated devices or processes to retrieve, index, "data mine", or in any way reproduce or circumvent the navigational structure or presentation of the Pocketyou Application and the contents contained therein

Updating Personal Data

You can update your personal information at any time by accessing your account on the PocketYou website. If there is any Personal Data relating to you that you are unable to update via the PocketYou website and that you would like to correct, you may contact us at support@pocketyouasia.com and we will be happy to assist you in any way possible.

Honoring Your Consent and Access to Personal Data

If you wish to access the Personal Data we hold relating to you, enquire about how Personal Data relating to you has been or may have been used or disclosed by PocketYou in the past year, or wish to withdraw your consent to such use of Personal Data, you may contact us (and our Data Protection Officer) at support@PocketYou.com or info@PocketYou.com. We will endeavor to comply with your request to the best of our ability. However, please note that we may have to charge you a reasonable administrative fee for retrieving the Personal Data relating to you.

Please note that you may withdraw your consent to our collection, use and disclosure of your information at any time. This includes uninstalling the web extension. However, please also note that if you withdraw your consent to our use and/or disclosure of Personal Data relating to you, depending on the nature of your objection, we may not be able to continue to provide our products or services to you or perform any contract we have with you. Our legal rights and remedies

are expressly reserved in such instances.

Changes to the Personal Data Protection Policy

PocketYou reserves the right to modify and update its Personal Data Protection Policy at any time to ensure that it is consistent with industry trends and/or any changes in legal or regulatory requirements. Subject to your rights at law, you agree to be bound by the terms of the applicable Personal Data Protection Policy as updated from time to time on our website. Any changes to this policy will be published on our website.

APPLICABLE LAW

This Privacy Policy shall be governed and construed in accordance with the laws of the Republic of Indonesia.

CHANGES TO PRIVACY POLICY

We may at any time change, update, and/or add some or all of the provisions in this Privacy Policy, in accordance with our business going forward, and/or changes in laws and regulations. If this Privacy Policy is changed/updated/added, we will notify you through a notification delivered through the Pocketyou Application and/or website www.pocketyouasia.com and/or to your email address. By continuing to communicate with us, using the Pocketyou Application and our services, or using the features in the Pocketyou Application means signifying your acceptance of the changes, updates, and/or additions that we make to this Privacy Policy. If You continue to use the Pocketyou Application after reading this Privacy Policy (including its changes), You are deemed to have agreed to this privacy Policy (including its changes) and may continue to use the Pocketyou Application.

EFFECTIVE DATE

This Privacy Policy in effective as of November 1, 2023.