FIDERE

Privacy Policy

Last Updated: November 1, 2024

This Privacy Policy Statement (the 'Privacy Policy') is formulated by FIDERE and its affiliated companies (collectively 'we') in accordance with the Personal Data (Privacy) Ordinance (Cap. 486) of the Laws of Hong Kong (the 'Privacy Ordinance'), to inform you of our policies and practices regarding the collection, use, retention, disclosure, transfer, protection and access of personal data.

1. Our Commitment to Privacy

We are committed to complying with the requirements of the Privacy Ordinance regarding the management of personal data to protect the privacy, confidentiality and security of the personal data we hold. We are equally committed to ensuring that all our staff and agents fulfill these obligations. If we ask you to provide certain information to identify you when using our services, you can rest assured that we will only use it in accordance with this Privacy Policy. Our commitment to comply with the Privacy Ordinance is based on the following principles: • We only collect personal data that we believe is relevant and necessary for providing our services and products • Personal data will only be used for specified purposes and will not be used for other purposes without your consent • We will not disclose personal data to any third party unless we (i) obtain your consent or (ii) are required by law, and we will only disclose under appropriate authorization • We will take all practicable steps to ensure your personal data is secure, confidential and accurate. This data will not be retained longer than necessary • Only authorized persons may access or process your personal data • You have the right to access or correct your personal data

2. Collection of Personal Data

We will collect your personal data through various means, including but not limited to when you use our website and applications, contact us and apply for our services. Where appropriate, you may be asked to provide your name, address, phone number and email address. Providing us with your personal data is optional, but without your personal data, we may not be able to process your request or provide the services you request. When you browse our website and applications, certain data may be automatically collected. For example, your web browser will automatically send data to each website you visit, including our website, which is a standard feature. This data includes your Internet Protocol (IP) address, domain name, browser type and configuration, language settings, geographic location, operating system, time/duration and previously visited websites (visitor data). We may also collect data about your usage and activities on the website and applications. We use this data, which does not identify individual users, to analyze trends, administer the website and applications, track user activities around the website and applications, and collect demographic information about our entire user base.

3. Use of Personal Data

We use your personal data to provide you with our services, operate and improve the website and applications, send you information, and for other purposes described in this Privacy Policy or disclosed to you on the website or in connection with our services. You agree and understand that any and all data provided to and collected by us may be used for the following purposes: • To provide and improve our services • To personalize and improve your experience on the website and applications • To process your applications or requests • To register an account with us to create applications • To apply to become a partner • To respond to and follow up on your inquiries and provide customer service • To provide service information and other services and content you request, and to send account and service-related information, including confirmations, invoices, technical notices, updates, security alerts, and support and administrative information • To conduct statistical analysis, research, surveys, quality assurance and reviews • To notify you of changes that may affect your services • To send you information about new promotions, products and services offered by FIDERE and our selected partners • To conduct comprehensive analysis of promotional performance • To maintain internal records • To fulfill regulatory and/or compliance obligations • For other purposes directly related to any of the above

4. Transfer of Personal Data

When you register to use our services, we may share the personal data you provide with the following third parties only when necessary for the third party to provide the service: • Credit card processing companies and payment providers to charge you for services • Email service providers to send emails on our behalf • Employment resource companies to process your job applications • Business partners, joint venture partners, service providers, suppliers, agents, consultants and independent contractors who provide administrative or other services to us in the normal course and scope of our business • To comply with any applicable laws, regulations, government orders or court orders, or respond to any lawful requests and legal proceedings • To protect the rights and property of FIDERE, our agents, members and others, including enforcing our agreements, policies and terms of use • Based on our good faith belief that disclosure is necessary to respond to emergencies or protect the personal safety of any person • In connection with any merger, sale of company assets, financing or acquisition of all or part of our business We also reserve the right to disclose your personal data to our related companies, including FIDERE Group affiliates and associated companies in Hong Kong and outside Hong Kong. In any such case, if your data is transferred and subject to a different privacy policy, we will provide notice.

5. Direct Marketing

We may from time to time use data collected or held by us, including your name, address, phone number and email address, for direct marketing purposes. We will not transfer or disclose your personal data to any third party for direct marketing purposes unless we obtain your consent or indication of no objection. However, we may transfer and disclose your name, address, phone number and email address to companies in our group in Hong Kong or overseas for direct marketing of products related to payment services. To conduct the above direct marketing, we may engage third-party data processors or service providers to complete tasks. When you give us consent or indicate no objection for the above purposes, it means you have agreed to our use of your personal data for the above purposes. You have the right to withdraw consent for such use. You can also contact us at info@fidere.com to change your preferences for using your data in direct marketing at any time.

6. Security

The security of your personal data is very important to us. We take reasonable security measures to protect your personal data from loss, misuse, unauthorized access, disclosure, modification and destruction. When you enter sensitive data (such as credit card numbers) on our online registration or order forms, we will encrypt that data using Secure Socket Layer (SSL) technology. If you use a password on our website or applications, you are responsible for keeping it confidential and should not share it with others. If you believe your password has been misused, please notify us immediately. We have also established appropriate procedures to maintain and protect data we collect offline. However, please note that despite our efforts, no security measures are impenetrable.

7. Cookies

We may automatically collect certain data through the use of 'cookies'. Cookies are small data files that can track and collect your browsing data from your web browser. Among other things, the use of cookies helps us improve the website, applications and your experience. We use cookies to see the most popular areas and features, count the number of computers visiting our website and applications, personalize your experience and remember your preferences. Cookies will also use this data during your future visits to the website and applications so that the server can immediately recognize that you have previously visited the website and applications. We will also link data stored in cookies to any personally identifiable data you submit on the website and applications. Cookies never allow us to access your computer or any data about you other than the data you choose to share with us. You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually change your browser settings to decline cookies if you prefer. However, if your browser is set to not accept cookies or you decline cookies, you may not be able to access certain features or services of the website or applications. Our Privacy Policy does not cover the use of cookies by our service providers, and we cannot access or control these cookies.

8. Hyperlinks

The website and applications may contain links to other websites. If you provide any data while browsing those websites, we cannot be responsible for the protection and privacy of that data, and those websites are not governed by this Privacy Policy. We encourage you to carefully read the privacy policies applicable to those websites.

9. Retention of Personal Data

We will retain all personal data in accordance with the guidelines set out in the Privacy Ordinance. We will only retain and use your personal data for as long as your account is active or as needed to provide you with services, and for as long as necessary to achieve the purposes for which such data is used (including any directly related purposes), fulfill our legal obligations, resolve disputes and enforce our agreements.

10. Monitoring Your Personal Data

You have the following rights regarding your personal data: • To know and access personal data held by us • To supplement, change or delete your personal data • To restrict or object to the processing of personal data • Data portability, i.e., to receive your personal data in a structured, commonly used and machine-readable format and transmit that personal data directly to another data user • To lodge a complaint with the relevant data protection authority You may choose to restrict the collection or use of your personal data in the following ways: • Whenever you are asked to fill out a form on the website or applications, look for a box you can click to indicate that you do not want the data to be used for direct marketing purposes • If you have previously agreed to our use of your personal data for direct marketing purposes, you can change your mind at any time and notify us by sending an email to info@fidere.com If you wish to exercise any of the above rights, please contact our Data Protection Officer by sending an email to info@fidere.com. To protect your privacy and identity, we will take reasonable steps to verify your identity before allowing you to access or correct your personal data. Please note that we have the right to charge a reasonable fee for processing any data access request in accordance with the Privacy Ordinance.

11. Amendments to Privacy Policy

We will revise the terms of this Privacy Policy from time to time, and we encourage you to review this Privacy Policy from time to time to ensure you are aware of the latest version.

12. English Version Prevails

In case of any conflict or ambiguity between the Chinese and English versions of this Privacy Policy, the English version shall prevail.

13. Inquiries

If you have any questions about this Privacy Policy, please contact us by sending an email to info@fidere.com.