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PRIVACY POLICY

Updated: 11 August 2025

ETHOZ Group Ltd (hereinafter referred to as “ETHOZ”, “we”, “us”, or “our” which terms shall include any subsidiary or affiliated entity of ETHOZ Group Ltd) operate the website https://www.ethozgroup.com (the “Website”), and provides certain services (including information and content) through our web and/or mobile application (“Platform”) including but not limited to allowing registered members of ETHOZ to check the status of any credit facility taken out with ETHOZ or the application of a loan. We are committed to respecting and protecting your privacy in respect of personal data collected through or in connection with our Website.

1. INTRODUCTION

1.1. We take our responsibilities under the Singapore Personal Data Protection Act 2012 (the “PDPA”) seriously. We also recognise the importance of the personal data you have entrusted to us and believe that it is our responsibility to properly manage, protect and process personal data provided to us by you. “Personal data” shall have the meaning given to it in the PDPA.

1.2. This Privacy Policy is designed to assist you in understanding how we collect, use, disclose and/or process the personal data you have provided to us, to help you to make an informed decision before providing us with your personal data.

1.3. If you, at any time, have any queries on this policy or any other queries in relation to how we may manage, protect and/or process personal data, or if you wish to withdraw your consent for us to collect, use and/or disclose your personal data please do not hesitate to contact our Data Protection Officer at the contact details below.

1.4. This Privacy Policy (together with our Website Terms of Use) and our Platform Terms and Conditions sets out the basis on which we use, disclose and process any personal data we collect from you.

1.5. By accessing or using any part of our Website or Platform, or applying for and using our services, you consent to your personal data being collected, used and disclosed by us in accordance with the terms of this Privacy Policy. If you do not agree with any term of this Privacy Policy, you should immediately cease the use of our Website, Platform and services.

2. COLLECTION OF PERSONAL DATA AND OTHER INFORMATION

2.1. We may collect and process personal data that you provide to us (which may include your name, identification and passport numbers, registered address, email address, mobile number, financial such as billing address, banking details and other payment information, employment history, and photographs and other personal description):

(a) when providing feedback or contacting us for any reason, such as your name, email address and contact details;

(b) when submitting an enquiry form relating to our services or products;

(c) when registering an account with us;

(d) when you apply or make an application for any service or product that we provide or offer;

(e) when we seek information, whether from third parties or you, about you in connection with the products and services you have applied for;

(f) when you enter into any agreement or provide other documentation or information in respect of your interactions with us, or when you use our services;

(g) when orders are to be fulfilled such as delivery details and addresses;

(h) if you contact us for any reason, which we may keep a record of that correspondence;

(i) when you interact with our employees via online enquiries, social media platforms, emails and other digital communications such as WhatsApp or Telegram;

(j) when you request that we contact you or request that you be included in an email or other mailing list;

(k) when you respond to our promotions, initiatives or to any request for additional personal data;

(l) when you submit an employment application and your resume and/or Curriculum Vitae;

(m) when you are contacted by, and respond to, our marketing representatives and officers;

(n) when we receive references from business partners and third parties, for example, where you have been referred by them;

(o) when you fill up surveys administered by us or our third-party surveying service providers;

(p) personal data that may be captured via any error logging and reporting tool that captures error report data and, at your option and with your consent, send this data to us in order for us to be informed of any software errors or problems that may occur during the use of the Website or Platform;

(q) details of visits to the Website or Platform, the activities you engage in when using the Website or Platform Services and the resources that you access on or via the Website or Platform;

(r) for any other incidental purposes related to or in connection with the aforementioned.

2.2. We only retain personal data for so long as it is necessary. Your personal data may be archived as long as the purpose for which the personal data was used still exists and if there are any legal or business reasons.

2.3. Aggregate Data

(a) We collect certain non-personal data when you visit and use our Website or Platform. Such data is entirely anonymous and is aggregated for statistical analysis (“Aggregate Information”). The information we obtain in this manner enables us to customise and personalise the services we offer, as well as measure the overall effectiveness of our online content, advertising campaigns, and the goods and services we offer.

(b) When you access our Website or Platform, we store Aggregate Information about your visit in a small text file called a “Cookie” on your hard disk by a web server. Cookies collect information about the pages you view, the links you click and other actions that you take on our websites. You can block cookies by modifying your browser settings to disable cookies. However, if you choose to do so, some of the functionality of our Website may be impaired. We use persistent cookies and session cookies. A persistent cookie stays in your browser and will be read by us when you return to our Website or Platform or a partner site that uses our services. Session cookies only last for as long as the session (usually the current visit to a website or a browser session). We use the following cookies:

(i) Strictly necessary cookies – These are cookies that are required for the operation of our Website or Platform. They include, for example, cookies that enable you to log into secure areas of our Website or Platform, use a shopping cart or make use of e-billing services.

(ii) Analytical/performance cookies – They allow us to recognise and count the number of visitors and to see how visitors move around our Website or Platform when they are using it. This helps us to improve the way our Website or Platform works, for example, by ensuring that users are finding what they are looking for easily.

(iii) Functionality cookies – These are used to recognise you when you return to our Website or Platform. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).

(iv) Targeting cookies – These cookies record your visit to our Website or Platform, the pages you have visited and the links you have followed. We will use this information to make our Website or Platform and the information displayed on it more relevant to your interests.

(c) We may also use electronic images known as Web Beacons to deliver or communicate with cookies, in order to better understand how you interact with the content on our Website. We also may include Web Beacons from third parties, in e-mail messages to determine whether messages have been opened and acted upon.

(d) We may also use website analytic tools on our websites to retrieve information from your browser, including the site you came from, the search engine(s) and the keywords you may have used to find our Website, the pages you viewed within our Website, your browser add-ons and your browser’s dimensions.

(e) We may use third-party web services on our Website or in our Platform. The service providers that administer these services use technologies such as cookies (which are likely to be analytical/performance cookies or targeting cookies), web server logs and web beacons to help us analyse how visitors use our Website or Platform and make the information displayed on it more relevant to your interests. The information collected through these means (including IP addresses) is disclosed to these service providers. These analytics services may use the data collected to contextualise and personalise the marketing materials of their own advertising network.

3. PURPOSE OF COLLECTION OF PERSONAL DATA

3.1. We may collect, use and process your personal data for any or all for one or more of the following purposes:

(a) facilitating your use of our Website and Platform and to operate our Website or and Platform;

(b) performing obligations in the course of connection with our provision of the goods and / or services requested by you;

(c) verifying your identity for the purposes of processing and administering to any enquiry, credit facility application, contractual agreement, account application, registration or other services;

(d) responding to, handling, and processing queries, request, applications, complaints, and feedback from you;

(e) execution and documentation on motor insurance claims and other services;

(f) processing payment and credit transactions;

(g) fraud management, crime prevention and / or investigation; complying with any applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and / or regulatory authority;

(h) sending marketing information about our goods or services including notification of our marketing events, initiatives and promotions, membership and rewards schemes and other promotions;

(i) notification and / or update on business entities and relevant information;

(j) contacting you through the contact information provided by you in order to provide you with the information that you request from us;

(k) storing, hosting and/or backing up (whether for disaster recovery or otherwise), whether within or outside Singapore;

(l) for record-keeping purposes;

(m) conducting research, analysis and developmental activities (including but not limited to data analytics, surveys and/or profiling) to improve the Website, Platform and our services;

(n) notifying you of any administrative updates that are not marketing or advertising in nature;

(o) responding to any legal processes and pursuing legal rights and remedies;

(p) managing claims or complaints;

(q) responding to requests for information from public and governmental / regulatory authorities, statutory boards, related companies, whether in Singapore or abroad, for audit, compliance, investigation and inspection purposes;

(r) informing you of updates on and/or changes to our services, programmes, policies, terms and conditions, and other administrative information;

(s) complying with any applicable law, regulation, legal process or government request;

(t) any other purposes for which you have provided the information; and

(u) any other incidental business purposes related to or in connection with the above.

4. PERSONAL DATA YOU DISCLOSE TO US

4.1. You represent, undertake and warrant that:

(a) for any personal data of individuals that you will be or may be disclosing or disclose to us, that you would have prior to disclosing such personal data to us obtained consent from the individuals whose personal data are being disclosed, to:

(i) permit you to disclose the individuals’ personal data to us for the purposes set out in this Privacy Policy; and

(ii) permit us (whether in Singapore or overseas) to collect, use, disclose and/or process the individuals’ personal data for the purposes set out in this Privacy Policy;

(b) you shall notify the individuals whose personal data are disclosed to us of the relevant purposes for such disclosure; and

(c) any personal data of individuals that you disclose or will be disclosing to us is accurate. Further, you shall give us notice in writing as soon as reasonably practicable should you be aware that any such personal data has been updated and/or changed after such disclosure.

5. THIRD PARTY SITES

The Website and Platform may from time to time, contain links to and from the websites of our partner networks, advertisers, affiliates or other third parties. If you follow a link to any of these websites, please note that these websites have their own privacy policies. As these websites are not owned or operated by us, we do not accept any responsibility or liability for the contents of these websites and their privacy policies, and you access and provide personal data to these third-party websites at your own risk. Please check these policies before you submit any personal data to any such websites.

6. DISCLOSURE OF PERSONAL DATA

6.1. Personal data provided to us by you may be used, disclosed, maintained, accessed, processed and/or transferred to the following third parties, whether sited in Singapore or outside of Singapore, for the purposes set out below:

(a) our affiliates, subsidiaries and group companies;

(b) third party service providers which require the processing of personal data, for example, third party service providers which have been engaged by us to

(i) to provide and maintain any IT equipment used to store and access personal data;

(ii) to host and maintain the Website and Platform;

(c) our auditors and legal advisors;

(d) public and governmental / regulatory authorities, statutory boards, industry associations, whether in Singapore or abroad; and/or

(e) courts and other alternative dispute forums.

6.2. In certain circumstances we may provide third parties (whether or not located in Singapore) with aggregate information about our Website and Platform’s users. This may include information about your computer, including where available your IP address, operating system and browser type, for system administration and to report aggregate information to our advertisers. This is anonymised statistical data about our users’ browsing actions and patterns, and does not identify any individual.

6.3. We may also disclose personal data in order to comply with any legal obligation, or in order to enforce or apply any terms and conditions between you and us; or to protect the rights, property, or safety of any person (including for example for the purposes of fraud detection and prevention).

7. DATA SECURITY

7.1. The security of your personal information is important to us. ETHOZ protects Personal Data in our possession or our control by making reasonable security arrangements to prevent unauthorised access, collection and disclosure.

7.2. While we strive to protect your Personal Data, no data transmission over the Internet can be guaranteed to be completely secure. We cannot guarantee the security of any information you transmit to us, and you transmit such information at your own risk. It is important that you do your part to ensure that any personal data provided to us via our Website or Platform or email or any other channels of communication are done in a safe and secure manner. We will not be liable for the security, authenticity, integrity or confidentiality of any transaction and other communications made through unsecure channels to us, whether through our Website or our Platform. We are not liable for any damages resulting from any security breaches, unauthorised and/or fraudulent use of your personal data.

8. TRANSFER OF PERSONAL DATA OUTSIDE OF SINGAPORE

8.1. The personal data that we collect from you may be transferred to, used, processed and stored outside of Singapore for one or more of the purposes set out above. By submitting personal data and/or using the Website, Platform and our services, you agree and consent to such transfer, storing or processing.

8.2. We will take reasonable steps to maintain appropriate physical, technical and administrative security to help prevent the loss, misuse, unauthorized access, disclosure or modification of personal data.

9. UPDATING YOUR INFORMATION

9.1. Where you submit personal data to us, you should ensure such personal data is accurate, and let us know if such personal data changes so that we are not holding any inaccurate personal data about you.

9.2. You may request to update or amend your personal data by notifying us through e-mail to our Data Protection Officer.

9.3. If you have registered an account with us, you may change the details through your account.

10. RETENTION OF PERSONAL DATA

10.1. We may retain your personal data for as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws.

10.2. We will cease to retain your personal data, or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purpose for which the personal data was collected, and is no longer necessary for legal or business purposes.

11. CONTACTING US

11.1. If you have any questions or feedback regarding this Privacy Policy, you may submit your request via email to our Data Protection Officer at DataProtectionOfficer@ethozgroup.com.

11.2. Please indicate in the subject header the nature of your correspondence. We will strive to revert to you speedily.

12. WITHDRAWAL OF CONSENT

12.1. You may withdraw your consent for us to collect, use, disclose and/or process your personal data for some or all of the purposes listed in this Privacy Policy.

12.2. You may request to access and/or correct the personal data currently in our possession by writing to the Data Protection Officer using the contact details provided below. Please note that we may charge you a reasonable fee for the handling and processing of your requests to access your personal data.

12.3. Please note that if you withdraw your consent to collect, use, disclose and/or process any or all of your personal data, Ethoz may be unable to properly provide any service or administer any contractual relationship in place.

13. UPDATES TO THIS POLICY

This policy will be reviewed from time to time to take into account future developments, industry trends and / or any changes in legal or regulatory requirements. We reserve the right to amend the terms of this Privacy Policy at our absolute discretion.