3. What information do we collect about you?

It may be necessary for you to provide us with certain personal data in order for you to receive the information and services of muruguru. We will let you know when such data is essential for Membership. All other personal data is up to you to provide or not, as you prefer.

(a) Your Membership

If you are a muruguru member ("Member"), some of the personal data we may collect from you includes:

• your email address, telephone number, gender, date of birth, district of residence, username and password;

• your membership account, account status, or any activities related to your account.

• your transaction history or payment details when you purchase anything our platform (including the product or service purchased, the date of purchase, where you made your purchase, the cardholder's name, credit card number, expiry date and billing information);

(b) When you visit our website

We may use online tracking technology such as cookies, pixel tags, web beacons and other similar technologies (for example, we may use Google Analytics – to learn how Google Analytics collects and processes information, please visit: “How Google uses information from sites or apps that use our services”) to automatically collect information about:

• your visits to our website, such as your browsing history, how long you stay on our website or app, and how often you visit;

• your location information as provided by your mobile or other device when you interact with our website, including your IP address and general geographic location; and the device that you use to browse our website (e.g. your device ID, operating system, type of device, browser type and version, mobile application crashes and other system activity, and third party sites you were using before interacting with our services).

You have the right to disable any of these online tracking technologies. To learn more about how we use the above data, please see the section below on online tracking technology.

(c) Social Media

When you have any social media accounts associated with our website, we may collect detailed information from the accounts (e.g., your gender, date of birth, occupation, and/or location).

(d) Other information

We also collect some of your personal data whenever we communicate with you (e.g. email content, WhatsApp contact and information, etc.), or when you complete any voluntary surveys and questionnaires we may send you from time to time (e.g. your demographic information and feedback).

Furthermore, if you provide us with information about other individuals, it signifies that you confirm your ability to:

- Represent their consent to the collection and/or processing of their personal data.

- Represent their acceptance of any notifications.

- Ensure that you have obtained the consent or have the authority to allow us to collect, store, and/or otherwise use their personal data.

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4. How do we use your information?

muruguru will only use your personal data for the purposes set out below.

(a) Account administration

To help administer and manage and maintain your Account, including:

• creating and updating your Account;

• verifying your identity;

• creating a single profile about you, including combining your information with any other personal data already held by us or our partners;

• processing services and/or activities;

• completing transactions, including processing or facilitating payments; and

• sending you updates about new features and benefits relating to muruguru

(b) Customer support

To assist you when you contact us, such as responding to and investigating any of your questions or concerns, and monitoring and improving our customer support services.

(c) Marketing

To provide you with marketing and promotional materials, if you choose to receive them. Please see the section on Direct Marketing below for more information.

(d) Personalisation

We aim to create personalized marketing communications that align with your interests and preferences, providing you with the best possible customer experience related to our website and your membership account. We may also utilize data analytics tools to assess the effectiveness of our advertisements and promotions, as well as determine your interest in new products or services. Additionally, we strive to tailor the content and type of offers, products, services, and rewards to best suit your needs and preferences.

(e) Optimisation and improvements

We may utilize your personal data through various means, (e.g., using analytical tools, conducting research, surveys, and feedback forms) in order to understand and improve our website or operations, as well as the operations of our partners. This helps us, along with our partners, to enhance the quality of services or products, as well as develop new features and advantages.

(f) Legal and administration purposes

We may use your personal data to investigate or handle any incidents, claims or disputes, or as otherwise required by law or requested by any law enforcement or regulatory authorities, courts or other governmental agencies. We may also use your personal data in relation to any legal proceedings related to you.

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5. Who do we share your information with?

If you use our website or register as a member, it signifies your agreement and consent for us to share your personal data with third parties. We are committed to protecting your information and personal data, and will take reasonable measures to safeguard them in accordance with this Privacy Policy and all applicable laws.

(a) Partners

If you are a member, your personal data may be shared with our partners for the purpose of processing services/products and related transactions, as well as for data analysis to improve their operations, services, or products.

Please note that if you provide your personal data to our partners when purchasing any services or products from them, or if you have registered as their customer, our partners may directly collect personal data from you. Personal data collected by our partners will be governed by their respective privacy policies (rather than this Privacy Policy), and we will not be involved in or responsible for the collection and processing of such data.

(b) Service providers

Your personal data may be shared with us or our service providers (including agents and contractors) who process personal data on our behalf to help us administer and operate muruguru, our website, to conduct data analytics, to help aggregate and anonymise personal data, or to carry out any of the purposes set out above. Such service providers may include information technology suppliers, back-end and front-line or support service providers, service centre operators, marketing agencies, data management and analysis service providers, and customer contact services. Our service providers may contact you on our behalf for the aforementioned purposes.

We only use trusted service providers who are obligated to use your personal data solely in accordance with this Privacy Policy.

(c) Professional advisors and assignees

When necessary, we may share your personal data with our professional advisors, including lawyers, accountants, financial advisors and insurers. Your personal data may also be shared with third parties in connection with any merger, acquisition, consolidation, restructuring, sale of assets, financing or any other similar scenarios involving the transfer of some or all of our business assets.

(d) Government and regulatory authorities

This Privacy Policy is governed by the laws of the Hong Kong Special Administrative Region of the People's Republic of China ("Hong Kong"). We strive to handle your personal data in accordance with any data privacy laws that we believe apply to us. Your personal data may be shared with regulatory authorities, courts and other governmental agencies to comply with any legal or regulatory requirements, orders or requests. Any dispute concerning the terms and conditions of this Privacy Policy, shall be subject to the exclusive jurisdiction of the courts of Hong Kong.