Privacy Policy

We may collect information about you when you visit our Sites or use our Services, including the following: (a) Registration and use information – When you register to use our Services by establishing an Account, we will collect Personal Data as necessary to offer and fulfil the Services you request. Depending on the Services you choose, we may require you to provide us with your name, postal address, telephone number, email address and identification information to establish an Account. We may require you to provide us with additional Personal Data as you use our Services. (b) Transaction and experience information – When you use our Services, for example, to make purchases from merchants, to process payments, we collect information about the transaction, as well as other information associated with the transaction such as amount sent or requested, amount paid for products or services, merchant information, including information about any funding instruments used to complete the transaction, Technical Usage Data, and Geolocation Information. (c) Participant information – When you use our Services, we collect Personal Data you provide us with the other participants associated with the transaction.

(d) Information that you choose to provide us to obtain additional Services or specific online Services – If you request or participate in an optional Site feature, or request enhanced Services or other elective functionality, we may collect additional information from you. We will provide you with a separate notice at the time of collection if the use of that information differs from the uses disclosed in this Privacy Policy. (e) Information about you from third-party sources – We obtain information from third- party sources such as merchants, data providers, and credit bureaus, where permitted by law. (f) Other information we collect related to your use of our Sites or Services – We may collect additional information from or about you when you communicate with us, contact our customer support teams or respond to a survey.

We retain Personal Data to fulfil our legal or regulatory obligations and for our business purposes. We may retain Personal Data for longer periods than required by law if it is in our legitimate business interests and not prohibited by law. If your Account is closed, we may take steps to mask Personal Data and other information, but we reserve our ability to retain and access the data for so long as required to comply with applicable laws. We will continue to use and disclose such Personal Data in accordance with this Privacy Policy.

We may share your Personal Data or other information about you with others in a variety of ways as described in this section of the Privacy Policy.

We may share your Personal Data or other information for the following reasons: (a) With other members of the BetterPay corporate family: We may share your Personal Data with members of the BetterPay family of entities, among other things, provide the Services you have requested or authorized; to manage risk; to help detect and prevent potentially illegal and fraudulent acts and other violations of our policies and agreements; and to help us manage the availability and connectivity of BetterPay products, Services, and communications. (b) With other companies that provide services to us: We may share Personal Data with third-party service providers that perform services and functions at our

direction and on our behalf. These third-party service providers may, for example, provide you with Services, verify your identity, assist in processing transactions or provide customer support. (c) With the other parties to transactions when you use the Services, such as other Users, merchants, and their service providers: We may share information about you and your account with the other parties involved in processing your transactions. This includes other Users you are sending or receiving funds from merchants and their service providers when you use the Services to pay for goods or services. The information includes: a. Personal Data and Account information necessary to facilitate the transaction; b. information to help other participants (s) resolve disputes and detect and prevent fraud; and c. aggregated data and performance analytics to help merchants better understand Users and to help merchants enhance Users’ experiences. (d) With other third parties for our business purposes or as permitted or required by law: We may share information about you with other parties for BetterPay business purposes or as permitted or required by law, including: a. if we need to do so to comply with a law, legal process or regulations; law enforcement, regulators, government officials, or other third parties in relation to a subpoena, court order, or other legal process or requirement under Malaysian law or regulation, or the laws and regulations of other jurisdictions that are applicable to BetterPay or one of its affiliates; when we need to do so to comply with such law or credit card rules; or when we believe, in our sole discretion, that the disclosure of Personal Data is necessary or appropriate to prevent physical harm or financial loss; or to report suspected illegal activity or to in BetterPay violations of a user agreement; to protect the vital interests of a person; b. to protect our property, Services and legal rights; c. to help assess and manage risk and prevent fraud against us, our Users and fraud involving our Sites or use of our Services, including fraud that

occurs at or involve BetterPay our business partners and strategic ventures, other individuals and merchants; d. to companies that we plan to merge with or be acquired by; and e. to support our audit, compliance, and corporate governance functions. (e) With your consent: We also will share your Personal Data and other information with your consent or direction, including if you authorize an account connected with a third-party account or platform. (f) With law enforcement agencies, for the purpose of preventing and/or detecting crime, investigations and/or the apprehension or prosecution of offenders and/or protection of national security and/or any purpose that is required or authorised by or under any law, order or judgment of a court.

We may process your information for the following reasons: (a) To operate the Sites and provide the Services, including to: a. initiate a payment; b. authenticate your access to an Account; c. communicate with you about your Account, the Sites, the Services, or BetterPay; d. create an account connection between your Account and a third-party account or platform; and e. perform credit worthiness and other financial standing checks, evaluate applications, and compare information for accuracy and verification purposes. (b) To keep your Account and financial information up to date. (c) To manage our business needs, such as monitoring, analyzing, and improving the Services and the Sites’ performance and functionality. For example, we analyze User behaviour and perform research about the way you use our Services. (d) To manage risk and protect the Sites, the Services and you from fraud by verifying your identity. BetterPay’s risk and fraud tools use Personal Data, Device

Information, Technical Usage Data and Geolocation Information from our Sites and websites that offer BetterPay Services to help detect and prevent fraud and abuse of the Services. (e) To provide personalized Services offered by BetterPay on third-party websites and online services. We may use your Personal Data and other information collected in accordance with this Privacy Policy to provide a targeted display, feature, Services or offer to you on third-party websites. (f) We may use cookies and other tracking technologies to provide these online services and/or work with other third-parties such as merchant’s, advertising or analytics companies to provide these online services. (g) To comply with our obligations and to enforce the terms of our Sites and Services, including to comply with all applicable laws and regulations. (h) To respond to your requests, for example, to contact you about a question you submitted to our customer service team. (i) For purposes related to or in connection with the agreements, terms of services and/or our rules and policies with respect to our products or service (including, but not limited to, monitoring compliance and enforcement of rights). (j) To conduct research for analytical purposes including, without limitation, knowledge discovery in data and analysis of transactions with us. (k) For such other purposes that is incidental or ancillary or in furtherance to the above purposes.

When you visit our Sites, use our Services, or visit a third-party website for which we provide online Services, we and our business partners and vendors may use cookies and other tracking technologies (collectively, “Cookies”) to recognize you as a User and to customize your online experiences, the Services you use, and other online content and advertising; measure the effectiveness of promotions and perform analytics; and to mitigate risk, prevent potential fraud, and promote trust and safety across our Sites and Services. Certain aspects and features of our Services and Sites are only available through the use of Cookies, so if you choose to disable or decline Cookies, your use of the Sites and Services may be limited or not possible.

You have choices when it comes to the privacy practices and communications described in this Privacy Policy. Many of your choices may be explained at the time you sign up for or use a Service or in the context of your use of a Site. You may be provided with instructions and prompts within the experiences as you navigate the Services.

Choices Relating to the Personal Data We Collect (i) Personal Data. You may decline to provide Personal Data when it is requested by BetterPay, but certain Services or all of the Services may be unavailable to you. (ii) Location and other device-level information. The device you use to access the Sites or Services may collect information about you, including Geolocation Information and User usage data that BetterPay may then collect and use.

Choices Relating to Cookies You may have options available to manage your cookies preferences. For example, your browser or internet device may allow you to delete, disable, or block certain cookies and other tracking technologies. You may choose to enable these options but doing so may prevent you from using many of the core features and functions available on a Service or Site.

You may have an option regarding the use of cookies and other tracking technologies when you use a Service or visit parts of a Site. For example, you may be asked if you want the Service or Site to “remember” certain things about you, and we will use cookies and other tracking technologies to the extent that you permit them.

Where indicated (in the Sites or any agreement), it is obligatory to provide your Personal Data to us to enable us to process your application for our products and/or services.

Should you decline to provide such Personal Data, we may not be able to process such applications, or provide and/or continue to provide our products and/or services.

We may transfer your Personal Data to places outside Malaysia (including, without limitation, where: (i) any of our service providers or partners who are involved in providing part of our product and/or service; or (ii) outsourced data storage or data processing

services for and on behalf of us is located outside Malaysia or has servers and/or related equipment outside Malaysia). You consent to us transferring your Personal Data to places outside Malaysia in these instances. We may also transfer your Personal Data to places outside Malaysia where permitted by law.

We maintain technical, physical, and administrative security measures designed to provide reasonable protection for your Personal Data against loss, misuse, unauthorized access, disclosure, and alteration. The security measures include firewalls, data encryption, physical access controls to our data and information access authorization controls. While we are dedicated to securing our systems and Services, you are responsible for securing and maintaining the privacy of your password(s) and Account/profile registration information and verifying that the Personal Data we maintain about you is accurate and current. We are not responsible for protecting any Personal Data that we share with a third-party based on an account connection that you have authorized.

You may request access to and correction of your Personal Data and/or limit the processing of your Personal Data (including personal data relating to other persons who may be identified from that personal data), or make any enquiries or complaints in respect of your Personal Data, by contacting us at the email address or contact number available at the Sites. In relation to either a data access request or a data correction request, you should quote your name, address and phone or account number and provide brief details of the information you want a copy of or, as the case may be, you want to have corrected, in any such request. Please note that we may decline to comply with your data access request in accordance with the PDPA. We shall be entitled to charge a fee (where permitted under the applicable law) for any data access request.

We reserve the right to modify, update or amend this Privacy Policy at any time and the updated version shall apply and supersede any and all previous versions. You are encouraged to check our website and re-visit this Privacy Policy periodically for our most up-to-date Privacy Policy.