I. Introduction

1.1 Welcome to the FRUUGO platform operated by FRUUGO Southeast Asia Limited and its affiliates (individually and collectively, “FRUUGO,” “we,” “us,” or “our”). FRUUGO takes its responsibilities under applicable privacy laws and regulations (“Privacy Law”) seriously and is committed to respecting the privacy rights and concerns of all users of our FRUUGO website and mobile application (“Platform”) (“We” refers to the Platform and the services we provide on our Platform, collectively, the “Services”). Users are those who register an account with us to use the Services, including buyers and sellers (individually and collectively, “Users,” “you,” or “your”). We recognize the importance of the personal data you entrust to us and believe it is our responsibility to properly manage, protect, and process your personal data. This Privacy Policy (“Privacy Policy” or “Policy”) is designed to help you understand how we collect, use, disclose, and/or process the personal data you provide to us and/or that we possess about you, both now and in the future, and to help you make informed decisions before providing us with any of your personal data. 1.2 “Personal Data” or “personal information” means data of an individual that can be identified from that data or from other information that an organization has the right or may have the right to access, whether or not it is true. Common examples of personal data may include name, ID number, and contact information. 1.3 By using the Services, registering an account with us, accessing our platform, or accessing the Services, you acknowledge and agree to your acceptance of the practices, requirements, and/or policies outlined in this Privacy Policy, and you hereby consent to our collection, use, disclosure, and/or processing of your personal data as described herein. If you do not agree to the processing of your personal data as described in this Privacy Policy, please do not use our Services or access our platform. If we change our Privacy Policy, we will notify you, including by posting such changed or revised Privacy Policy on our platform. We reserve the right to modify this Privacy Policy at any time. Your continued use of the Services or Platform, including placing any order, to the maximum extent permitted by applicable law, constitutes your acknowledgment and acceptance of the changes made to this Privacy Policy. 1.4 This Policy applies together with other notices, contractual terms, and consent terms applicable to our collection, storage, use, disclosure, and/or processing of your personal data, and is not intended to overridden such notices or terms unless we expressly state otherwise. 1.5 This policy applies to both the buyer and seller of the services, unless otherwise expressly stated. Our disclosure and/or processing of your personal data is not intended to overwrite these notices or terms unless we expressly state otherwise.

2. When does FRUUGO collect personal data?

2.1 We will/may collect personal data about you:

When you register and/or use our services or platform, or when you open an account with us;

When you submit any form, including but not limited to application forms or other forms related to any of our products and services, whether online or in physical form;

When you enter into any agreement with us or provide other documents or information regarding your interaction with us, or when you use our products and services;

When you interact with us, such as by phone (which may be recorded), letter, fax, face-to-face meeting, social media platform and email, including when you interact with our customer service agents;

When you use our electronic services, or interact with us through our applications or use services on our platform. This includes, but is not limited to, cookies that we may deploy when you interact with our applications or websites;

When you grant permission on your device to share information with our applications or platform;

When you link your Lazada account to your social media or other external accounts or use other social media features in accordance with the provider's policies;

When you transact through our services;

When you provide us with feedback or complaints;

When you register for the competition; or

When you submit your personal data to us for any reason

The above is not exhaustive, but rather lists some common situations in which your personal data may be collected.

3. What personal data will Lazada collect?

3.1 The personal data that Lazada may collect includes, but is not limited to:

Name;

email address;

Date of birth;

Invoice and/or delivery address;

Bank account and payment information;

telephone number;

gender;

Information sent or related to the device used to access our services or platform;

Information about your network and the people and accounts you interact with;

Photo, audio, or video recordings;

Government-issued identification or other information required for our due diligence, Know Your Customer, identity verification, or fraud prevention;

Marketing and communication data, such as your preferences for receiving marketing from us and third parties, your communication preferences, and your communication history with us, our service providers, and other third parties;

Usage and transaction data, including details about your searches, orders, ads and content you interact with on the platform, and other products and services related to you;

Location data;

This includes any other information about a user when they register to use our services or platform, and information relating to how a user uses our services or platform; and

Summary data on user-engaged content.

3.2 You agree not to submit any inaccurate or misleading information to us, and you agree to notify us of any inaccuracies or changes to such information. We reserve the right, at our sole discretion, to request further documentation to verify the information you provide.

3.3 If you register as a user of our platform using your social media account (“Social Media Account”), link your FRUUGO account to your social media account, or use any Lazada social media features, we may access information that you have voluntarily provided to your social media account provider in accordance with that provider’s policy, and we will always manage and use any such personal data in accordance with this policy.

3.4 If you do not wish us to collect the above information/personal data, you may opt out at any time by giving written notice to our Data Protection Officer. For more information on opting out, please see the section below titled “How can you withdraw your consent, request access, or correct the information you have provided to us?” However, please note that opting out or withdrawing your consent to our collection, use, or processing of your personal data may affect your use of the Services and Platform. For example, opting out of location information collection will result in the disabling of its location-based features.

4. Collection of other data

4.1 As with most websites and mobile applications, the information your device sends may include data about you recorded by our web servers while you browse our platform. This typically includes, but is not limited to, your device's Internet Protocol (IP) address, computer/mobile device operating system and browser type, mobile device type, mobile device characteristics, unique device identifier (UDID) or mobile device identifier (MEID) for your mobile device, the address of the referencing website (if any), the pages you visited on our website and mobile applications, and the time of your visit. Sometimes there is also a "cookie" (which can be disabled using your browser preferences) to help the website remember your last visit. If you are logged in, this information will be associated with your personal account.

4.2 Our mobile applications may use technologies such as GPS and Wi-Fi to collect precise information about the location of your mobile device. We collect, use, disclose, and/or process this information for one or more purposes, including but not limited to the service of location—which you request or which provides you with relevant content based on your location or allows you to share your location with other users—as part of the services under our mobile applications. For most mobile devices, you can revoke your permission for us to collect your location information through your device settings. If you have any questions about how to disable location services on your mobile device, please contact your mobile device service provider or device manufacturer.

4.3 When you view pages on our website or mobile applications, when you watch content and ads on our platform or through the service, and when you access other software, most of the same information is sent to us (including but not limited to IP address, operating system, etc.); however, your device does not send us information about the content installed on the service and platform, ad views and/or software, and the time, rather than page views.

5. Cookies

5.1 We, our authorized service providers, and advertising partners may use cookies or other features from time to time to allow us or third parties to collect or share information about your use of our services or platform. These features help us improve our platform and the services we offer, help us provide new services and features, and/or enable us and our advertising partners to provide you with more relevant content, including through remarketing. A cookie is an identifier stored on your computer or mobile device that records data about your computer or mobile device, how and when you use or access the service or platform, how many people use it, and other activities within our platform. We may associate cookie information with personal data. Cookies are also linked to information about the items you choose to purchase and the web pages you view. This information is used to track your shopping cart, provide content specific to your interests, enable our third-party advertising partners to place advertisements on our websites on the Internet, conduct data analysis, and monitor service usage.

5.2 You can refuse the use of cookies by selecting the appropriate settings on your browser or device. However, please note that if you do so, you may not be able to use the full functionality of our platform or services.

6. How will we use the information you provide us?

6.1 We may collect, use, disclose and/or process your personal data for one or more of the following purposes:

We will consider and/or process your application/transaction with us or your transactions or communications with third parties through the Service;

To manage, operate, provide and/or control your use and/or access to our services and our platform (including but not limited to remembering your preferences), as well as your relationship with us and your user account;

Respond to, process, handle or complete transactions and/or meet your requirements for certain products and services, and notify you of service issues and unusual account behavior;

We will enforce our Terms of Service or any applicable End User License Agreement;

To protect personal safety and the rights, property, or safety of others;

For the purpose of identifying, verifying, conducting due diligence, or knowing your customers;

Assess and make decisions related to your credit and risk profile and eligibility for credit products;

To maintain and manage any software updates and/or other updates and support that may be required from time to time to ensure the smooth operation of our services;

To handle or facilitate customer service, execute your instructions, and process or respond to any inquiries made by or on your behalf (or allegedly made by) you;

In order to manage and/or administer your relationship with us or your use of our services, we may contact or communicate with you by voice call, text message and/or fax message, email and/or postal mail or other means, such as, but not limited to, conveying administrative information relating to our services. You acknowledge and agree that we may communicate such information to you by mailing you letters, documents or notices, which may involve disclosing certain personal data about you to achieve the same delivery and on the outer cover of envelopes/mail parcels;

Allow other users to interact with you, contact you, or view some of your activities on the platform, including notifying you on the platform when other users send you private messages, post comments about you on the platform, or contact you using social features;

To conduct research, analysis, and development activities (including but not limited to data analysis, surveys, product and service development and/or analysis) to analyze how you use our services, recommend products and/or services relevant to your interests, and improve our services or products and/or enhance your customer experience;

Audits and investigations are permitted to verify the size and composition of the target audience and to understand their experience with Lazada services.

For marketing and advertising purposes, and in this regard, we may send you marketing and promotional information and materials related to products and/or services (including, but not limited to, products and/or services that Lazada may have third-party products and/or services) through various media and communications in cooperation with or in partnership with products or services that Lazada (and/or its affiliates or related companies) may be selling, marketing or promoting, whether such products or services exist now or will be created in the future. You can unsubscribe from receiving marketing messages at any time using the unsubscribe function in the electronic marketing materials. We may use your contact information to send newsletters or marketing materials from ourselves and our related companies;

In response to legal proceedings or to comply with any applicable laws, governmental or regulatory requirements of any applicable jurisdiction, or if we have a strong reason to believe that such disclosure is necessary, including but not limited to fulfilling disclosure requirements under any law binding on Lazada or its related companies or affiliates (including, where applicable, displaying your name, contact details and company details).

Generate statistical data and research to meet internal and statutory reporting and/or record-keeping requirements;

Due diligence or other screening activities (including, but not limited to, background checks) may be conducted in accordance with legal or regulatory obligations or as required by law or as risk management procedures that we may have implemented.

Review our services or FRUUGO's business;

To prevent or investigate any actual or suspected breach of our Terms of Service, fraud, illegal activity, omissions or misconduct, whether or not related to your use of our Services or any other matter arising out of your relationship with us;

Respond to any threats or actual claims against Lazada, or other claims that any content infringes on the rights of third parties;

Store, host, or back up your personal data (whether for disaster recovery or other purposes), whether within or outside your jurisdiction;

Processing and/or facilitating commercial asset transactions or potential commercial asset transactions, wherein such transactions involve FRUUGO as a participant, or only involve affiliates or related companies of Lazada as participants, or involve affiliates or related companies of Lazada and/or any one or more Lazada entities as participants, and there may be other third-party organizations involved in the transaction. “Commercial asset transaction” means the purchase, sale, lease, merger, consolidation, or any other acquisition, disposal, or financing of an organization or a part of an organization or any of its business or assets; and/or

We may notify you of any other purposes with your consent.

(Collectively referred to as "purpose").

6.2 You acknowledge, agree, and consent that Lazada may access, retain, and disclose your account information and content if required by law, pursuant to a court order, or by any government or regulatory body with jurisdiction over Lazada, or in good faith. Lazada believes such access, protection, or disclosure is reasonably necessary to: (a) comply with legal process; (b) comply with any government or regulatory body with jurisdiction over FRUUGO; (c) enforce the FRUUGO Terms of Service or this Privacy Policy; (d) respond to any threats or actual claims against FRUUGO or other claims that any content infringes on the rights of third parties; (e) respond to your customer service requests; and (f) protect the rights, property, or personal safety of FRUUGO's users and/or the public.

6.3 Because the purposes for which we/may collect, use, disclose, or process your personal data are subject to change, the aforementioned purposes may not occur. However, we will notify you of such other purposes when we obtain your consent, unless privacy laws permit the processing of applicable data without your consent.

7. How does FRUUGO protect and retain customer information?

7.1 We have implemented various security measures and strive to ensure the security of your personal data on our systems. User personal data is contained behind a secure network and can only be accessed by a select few employees with special access rights to such systems. However, absolute security cannot be guaranteed.

7.2 We will retain personal data in accordance with privacy laws and/or other applicable laws. That is, we will destroy or anonymize your personal data when we reasonably determine that (i) retaining such personal data is no longer necessary for the purpose for which it was collected; (ii) retention is no longer required for any legal or commercial purpose; or (iii) there is no other legitimate interest requiring further retention of such personal data. If you cease using the platform, or your license to use the platform and/or services is terminated or revoked, we may continue to store, use, and/or disclose your personal data in accordance with this Privacy Policy and our obligations under privacy laws. We may also securely process your personal data without prior notice under applicable law.

8. Will FRUUGO disclose the information it collects from visitors to external parties?

8.1 In conducting business, we may/may need to use, process, disclose, and/or transfer your personal data to our third-party service providers, agents, and/or our affiliates or related companies and/or other third parties, which may be located in or outside Malaysia for one or more of the purposes described above. Such third-party service providers, agents, and/or affiliates or related companies and/or other third parties will process your personal data on our behalf or otherwise for one or more of the purposes described above. We strive to ensure that third parties and our affiliates protect your personal data from unauthorized access, collection, use, disclosure, processing, or similar risks, and retain your personal data only for the purposes described above.

Our subsidiaries, affiliates and related companies;

Buyers or sellers with whom you transact or interact on the platform, or buyers or sellers related to your use of the service for the purposes described above;

Other users who use our platform for one or more of the aforementioned purposes;

We utilize contractors, agents, service providers, and other third parties to support our business. These include, but are not limited to, parties that provide us with administrative or other services, such as post offices, logistics service providers, financial service providers, advertising and marketing partners, telecommunications companies, information technology companies, and data centers;

Governments or regulatory bodies with jurisdiction over FRUUGO or permitted by Article 6.2;

In the event of a merger, divestiture, reorganization, restructuring, dissolution, or otherwise sale or transfer of all or part of FRUUGO's assets (whether as a going concern or as part of bankruptcy, liquidation, or similar proceedings), the buyer or other successor, where personal data held by FRUUGO concerning users of our services constitutes the transferred assets; or a counterparty to a business asset transaction involving Lazada or any of its affiliates or related companies; and

We disclose to third parties for one or more purposes, and these third parties in turn collect and process your personal data for one or more purposes.

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