Me2B Pty Ltd (Australian company number: 681 803 216) and its subsidiaries (“we”, “us” or “our”) operate a personal information monetisation platform, through our website me2b.ai and our Valuoo iOS and Android mobile applications (collectively, our “Platform”), which empowers consumers to securely share and monetise their personal information in exchange for bonus mobile internet, prepaid utilities, branded rewards and personalised offers (collectively, the “Rewards”).

We bridge the gap between consumers’ growing need for affordable mobile data and their desire for enhanced value from their personal information. Acting as a “trusted” broker, we leverage “consent and preferences” to secure the best Rewards, ensuring consumers benefit directly from their personal information.

This Privacy Policy sets out how we collect, use, disclose, transfer, store, retain and otherwise process your personal information when you visit our website, download or use our mobile applications, sign up for or use your Valuoo account, or otherwise interact or engage with us in connection with any of our products or services (collectively, our “Services”) or any of the Rewards.

Our Platform and our Services are not intended to be used by anyone under the age of 18 (a “Child”). If you are a parent or guardian and you are aware that your Child has provided us with personal information, please contact us using the details in the “Contact Us” section below. If we become aware that we have collected personal information from any Child, we take steps to remove such information from our servers.

As we operate in different countries across the world, some aspects of this Privacy Policy address certain country-specific requirements under applicable privacy and data protection laws. It is important that you read this Privacy Policy in full to ensure you understand all aspects that apply to you.

By clicking the checkbox next to “I agree to the Privacy Policy” when you sign up for your Valuoo account, you agree that: (a) you have read this Privacy Policy in full; (b) you understand this Privacy Policy; and (c) your personal information may be collected, used, disclosed, transferred, stored, retained and/or otherwise processed in accordance with this Privacy Policy.

Our Platform can contain links to and from the websites of, amongst others, our business partners, telecommunication service providers, utilities service providers, retailers, brands and advertisers (collectively, our “Partners”). If you follow a link to any of these websites, please note that this Privacy Policy does not apply to any of our Partners. We are not responsible or liable for the privacy policies or practices of these websites, so please check their policies before you submit any personal data to these websites.

When you visit our website, download or use our mobile applications, sign up for or use your Valuoo account, or otherwise interact or engage with us in connection with any of our Services or any of the Rewards, we may collect the following information about you:

• Information you give us:

You may give us information about yourself if you sign up for or use a Valuoo account, complete any online forms (such as registration forms, preference forms or surveys), opt-in to receive any communications or Rewards, place an order for any pre-paid mobile internet services, mobile internet data top-ups or other products, redeem any Rewards, enter into any promotions, participate in any social media functions, or correspond with us (by email, telephone, chat, instant messaging apps, social media or otherwise).

Depending on what you provide, this information can include your name, phone number, email address, address or location, date of birth, gender, order information, hobbies, interests, shopping preferences, brand preferences, communication preferences, reviews, images and financial information (including your credit or debit card details).

You need to have an account with us in order to place any order on our Platform or to redeem any Reward. When you first place an order on our Platform or redeem any Reward, and if you haven’t yet registered an account with us, an account will be created for you. You can delete your account anytime by going into the account details section.

• Information we receive from other accounts or sources:

We can receive information about you from other sources, such as your other accounts (for example, when you use your Apple ID or Google Sign In to sign in on our Platform), and other platforms and websites (including data brokers, our Partners, social media providers such as Facebook, Instagram, YouTube, TikTok and X, advertising networks, analytics partners, and payment service providers).

By logging into our Platform via Apple, Google, Facebook, Instagram, YouTube, TikTok or X, or by linking your Valuoo account to your Apple, Google, Facebook, Instagram, YouTube, TikTok or X account, you are giving us permission to obtain certain information and content from these accounts. The specific types of information that we may obtain depends on your settings for such accounts or websites, and will be subject to their privacy policies.

With your consent, we may supplement the information you provide to us with additional information (such as demographic data, household size, income range, occupation and other details) obtained from reputable third-party data providers and data appending service providers. Such third-party providers collect and aggregate information from public sources (such as public databases and records, government databases, and openly accessible social media profiles). We use such additional information, and combine such additional information with the information you provide to us, to: (a) provide you with more personalised Rewards, tailored recommendations, relevant offers, targeted promotions, and advertisements specifically aligned with your interests and preferences; and (b) enhance the security, authentication, and identity verification processes on our Platform. We use consent as the legal basis to collect such additional information and to combine such additional information with the information you provide to us. You have the right to withdraw your consent at any time by changing your preferences in your Valuoo account or by completing the Unsubscribe Form.

• Information our IT systems collect about you:

Each time you visit our website, download or use our mobile applications, sign up for or use your Valuoo account, or otherwise interact or engage with us in connection with any of our Services or any of the Rewards, certain information will be created and automatically recorded by our IT systems. That information includes:

• Cookies

You can see more details about cookies in section 8, but these small text files can help improve your experience with our Platform and make it easier to interact with us. This may include storing your location or language preferences to save you having to re-enter information when returning to our Platform, or ensuring that items you wish to order don’t disappear as you navigate between pages on our Platform. We also use cookies to provide you with tailored advertising, promotions and rewards.

• Device information

The information provided by your device will differ depending on your operating system and device settings (e.g. PC, Mac, iPhone, Android, or otherwise), but includes the type of device you have (e.g. iPhone 17 Pro or Samsung Galaxy S25+), the device’s IP address and location, the browser you’re using, your mobile network provider (for mobile devices), the pages you have visited, your time zone and country location, and crash or download error reports.

To provide you with our Services, including to allow you to redeem and receive the Rewards on our Platform, administer your Valuoo account and optimise your experience, we need to use your information in a number of different ways.

With your consent, we will use your information for marketing and advertising purposes via our Platform. Where you have told us you would like to receive marketing communications and offers from our Partners, we will use your personal information to send you such communications and offers via our Platform. We may use your information (including supplemental information received from partners that we append to our existing customer information as described below) to tailor such communications and offers to you.

You may unsubscribe from such communications and offers by modifying your preferences in your Valuoo account’s profile management section, by following the opt-out instructions in the promotional emails that are sent to you, or by completing this Unsubscribe Form.

We use third-party service providers to serve advertisements most relevant to you across your different devices and on our own and others’ websites and mobile applications. In addition to the information about your visits to our Platform or usage of our mobile application, our service providers may also use the information about your interactions with other websites or applications to target advertisements for products available from our Platform or from our Partners. For information about opting out of targeted advertising and controlling the use of cookies, please see the cookies section of this Privacy Policy.

We also carry out research, analysis and surveys on your use of our Platform (including which offers you engage with and which Rewards you redeem). We also use your information to confirm your identity and perform credit checks or anti-fraud checks, in order to ensure your, and our, financial security. Please see below to find out the detailed purposes for which we collect your information, what specific information is collected and the legal basis for which we use such information.

• To register and manage your Valuoo account on our Platform,we collect your name, date of birth, phone number, email and any other additional details you may wish to provide (such as your hobbies, interests, shopping preferences, brand preferences, communication preferences and gender). The legal basis is the performance of a contract with you.

• To fulfil the orders you make through our Platform,we collect your name, phone number, email and order details such as the products you are buying and price. The legal basis is the performance of a contract with you.

• To collect and process payment from you,we collect your payment information. Depending on your selected payment method, such information may include:

• Credit or debit card: card number, cardholder’s name, expiration date and CVV/CVC security code;

• Direct carrier billing: your mobile phone number and mobile carrier account information;

• Digital wallet or e-wallet: your digital wallet or e-wallet account information (such as your account identifier, registered phone number or email address associated with your digital wallet or e-wallet);

• Loyalty points: details of your loyalty account, including your loyalty account identifier, membership number, or points balance; and

• Direct bank transfer: your bank account details, including account holder’s name, account number, bank name, IBAN, SWIFT/BIC code, or other necessary banking details required for transaction processing.

We securely transfer your payment details directly to our authorised third-party payment providers and financial service partners (including providers of credit/debit card processing, direct carrier billing, digital wallets, loyalty payment systems, and banking institutions). We do not store your full payment details or sensitive financial information ourselves once the transaction is processed.

The legal basis is the performance of a contract with you.

• To provide you with our Services(including helping you to resolve any issue you have with our Services, updating you about any changes to this Privacy Policy, or contacting you to know how your experience with us was), we collect your name, phone number, email and your contact history with us. The legal basis is the performance of a contract with you and our legitimate interests in retaining you as a customer and providing you with first-class customer support services.

• To monitor the quality of our Platform and our Services,we collect your name, phone number, email, your response to our SMS inquiries about the quality of the service and your contact history with us (including phone records of our conversations and conversations through email or other instant messaging apps). The legal basis is our legitimate interests in running our business and improving our Platform and our Services.

• To administer, maintain and optimise our Platform and our services, we collect your device information (such as your device IP address and device type), cookie identifiers and browsing information. The legal basis is our legitimate interests in running our business and improving our Platform and our Services.

• To perform fraud and credit checks and if we can do business with you,we collect your name, phone number, email, credit/debit card details, browsing history, order history, date of birth, gender, specific behavioural cookies, device information (such as IP address and device type), any national identifiers (like driving licence or ID cards) and any publicly available information (like social media profiles or news). The legal basis is the legitimate interests to protect us and our customers from fraudulent activities and compliance with a legal obligation.

• To send you marketing communications and personalised offers,we collect your name, date of birth, phone number, email, hobbies, interests, shopping preferences, brand preferences, communication preferences, date of birth, gender, order history, browsing history and behaviour, device information, cookie identifiers, internal identifiers and country. We use consent as the legal basis to collect and process such information.

• To manage our loyalty programmes, we collect your name, date of birth, phone number, email, hobbies, interests, shopping preferences, brand preferences, communication preferences, date of birth, gender, order history, browsing history and behaviour, device information, cookie identifiers, internal identifiers, country, spent tier level and wealth. We use consent as the legal basis to collect and process such information.

• To provide you with personalised recommendations and enhance your experience,we collect your name, date of birth, phone number, email, hobbies, interests, shopping preferences, brand preferences, communication preferences, date of birth, gender, order history, browsing history and behaviour, device information, cookie identifiers, internal identifiers, country, spent tier level and wealth. We use consent as the legal basis to collect and process such information.

• To carry out research, analysis, enquiries and surveys on your use of our Platform,we collect your name, date of birth, phone number, email, hobbies, interests, shopping preferences, brand preferences, communication preferences, date of birth, gender, order history, browsing history and behaviour, device information, cookie identifiers, internal identifiers, country, spent tier level and wealth. We use consent as the legal basis to collect and process such information.

• To advertise and retarget advertising of our and our Partners’ products and services,we collect your name, date of birth, phone number, email, hobbies, interests, shopping preferences, brand preferences, communication preferences, date of birth, gender, order history, browsing history and behaviour, device information, cookie identifiers, internal identifiers, country, spent tier level and wealth. We use consent as the legal basis to collect and process such information.

To produce aggregated statistical reports, we use your hobbies, interests, shopping preferences, brand preferences, communication preferences, date of birth, gender, order history, browsing history and behaviour, device information, cookie identifiers, internal identifiers, country, spent tier level and wealth, provided that the result of such reports do not identify you. The legal basis is our legitimate interests in running our business and improving our Platform and our Services.

To provide our Services and our Platform, we work with a number of carefully selected third parties. To do this, we may share your information with these third parties in the following limited circumstances:

• Group companies for business purposes:Me2B Pty Ltd is part of a larger family of companies in different parts of the world (collectively, the “Me2B Group”). The Me2B Group comprises Me2B Holdings Pty Ltd, Me2B Pty Ltd and all their respective subsidiaries. Your personal information may be shared between members of the Me2B Group in order to operate our business and provide our Platform and our Services. Rest assured, their use of information is consistent with this Privacy Policy.

• Our Partner from whom you purchase products or receive or redeem Rewards:Our Platform empowers you to securely share and monetise your personal information in exchange for Rewards. Acting as your “trusted” broker, we leverage your “consent and preferences” to secure the best Rewards for you, ensuring you benefit directly from your personal information. We do not share any of your personal identifiers (such as your name and contact details) directly with our Partners from whom you purchase products or receive or redeem Rewards (such as telecommunication providers, retailers, e-commerce platforms and consumer brands). Instead, we share only aggregated and anonymised data with such Partners. This means that such Partners will receive insights about groups or categories of users (for example, the total number of users interested in certain brands or products) but cannot identify you individually from the information we share with them.

• Third party service providers for business purposes:To function properly, we rely on a number of carefully selected third parties to provide us with services and products. We permit these companies to use your personal information only to the extent necessary to provide us with their services and products. Below you can find the types of third parties we use:
  
  
• Artificial intelligence data processors that we use to anonymise, enrich, match or aggregate information.

• Marketing tools and performance marketing and recommendations providers (including Magnite, Emarsys and Syniverse) that help us enable our marketing and deliver advertising and recommendations of products tailored to your interests and needs.

• Telecommunication digital products and rewards providers (including DT One) that we use to facilitate the provision and delivery of prepaid telecommunication products (such as airtime and data top-ups) and branded non-cash digital rewards.

• Loyalty programs and rewards integration providers (including Currency Alliance) that we use to manage multi-brand loyalty programs, points exchanges and partnerships.

• Payment solution providers (including Xendit, Thunes and Boku) that we use to process your payment information (including your credit or debit card details) so that we can process payment for you.

• IT/technology providers (including Salesforce and Heroku) that we use to support, maintain and provide our technology and IT infrastructure that supports our Platform and the storage of your information.

• Anti-fraud and credit check providers to keep us and you secure. They have access to and process your information and associated orders to check for any fraudulent behaviour.

• Analytics and search engine providers, like Google, that we use to assist us in the improvement and optimisation of our Platform.

• Customer service management providers, that allow us to provide our customer services and improve and manage your customer experience.

• Research companies that we can engage to help us carry out surveys regarding your use of our Platform and our Services.

• Third parties where we are considering a corporate transaction:The Me2B Group is always looking for new opportunities and directions in which to grow. This means sometimes we may consider corporate transactions such as merger, acquisitions, reorganisations, asset sale, or similar. In these instances, we may transfer your information to enable the assessment and undertaking of that transaction. If we buy or sell any business or assets, your personal information may be one of the assets that are transferred.

• To comply with legal requests:On occasion we may be required to liaise with various regulators and law enforcement agencies in a number of different countries, whether as a result of law, a court order, or another legal process. Although we dispute requests wherever suitable, in some cases we may have to share your information with the regulators or law enforcement agencies. Where we consider it appropriate, and provided we are not prohibited from doing so by law or court order, we will attempt to notify you of these legal demands.

Aggregated information with third parties: We may aggregate your information with the information of other customers, creating a dataset of information about the usage of our Platform, purchase of products, and other general, grouped information about our customers. The legal basis is our legitimate interest in understanding the usage of our Services and demand for our Services. Although this dataset is aggregated and anonymised, meaning it cannot identify you as an individual, it provides a valuable insight into the use of our Platform and we may therefore share it with select third parties. These parties may include providers of plugins or similar technologies (to help measure traffic), our Partners and other providers and our investors.

We primarily host your personal information in the United States of America and Singapore. As a global business, we may also transfer your personal information to, and process your personal information in, countries outside your country of residence and where members of the Me2B Group and our third party service providers are located. These countries may have data protection rules that are different from your country of residence. In certain situations, we may be required to disclose your personal information pursuant to lawful requests from local law enforcement or government authorities. We implement appropriate measures and safeguards to protect your personal information to meet the standards described in this Privacy Policy (including the use of the European Union Standard Contractual Clauses, the United Kingdom International Data Transfer Agreement or any equivalent standard contracts issued by the relevant authorities, where applicable and required) and/or adopting alternative measures required for the lawful transfer of personal information in accordance with applicable privacy and data protection laws.

We may engage in automated decision-making processes (including profiling) which involve the use of technology to evaluate certain personal aspects relating to you, based on your stated preferences, your usage patterns, and your Rewards redemption history.

Specifically, we analyse and categorise your preferences, interactions, and redemption behaviours to assign you to particular user segments. Such segmentation allows us to determine the type, relevance, and value of the Rewards, offers, promotions, and advertising you receive. Our aim is to ensure that our content and offers are as personalised and beneficial to you as possible, aligning closely with your interests and preferences.

The logic used involves automated analysis of data points you provide (such as your stated preferences and demographic details), combined with behavioural data collected from your interactions on our Platform (such as frequency of use, types of Rewards redeemed, responses to previous promotions, and overall engagement). Based on these factors, our automated systems categorise you into segments that inform our decisions regarding the relevance, type, and monetary value of Rewards and promotions tailored specifically for you.

The primary consequence of such processing is to influence the personalised content, offers, promotions, and Rewards you see. For example, if our analysis indicates you frequently redeem Rewards related to certain brands or products, you may receive similar offers or more attractive incentives related to those preferences. Conversely, segments reflecting different behaviours or preferences might receive different types of Rewards and offers. These decisions do not significantly or legally affect your rights but rather enhance your user experience by offering tailored Rewards and marketing communication.

You have the right not to be subject to a decision based solely on automated processing, including profiling, which has legal effects for you or affects you in any other significant way. While our automated processes generally do not produce such effects, if you have concerns, or wish to request human intervention, express your point of view, contest a decision, or seek further clarification about these automated processes, please contact us directly using the contact details provided in the “Contact Us” section below.

We use technology such as “cookies” to collect information and store your online preferences. Cookies are small pieces of information sent by a web server to a web browser, which allows the server to uniquely identify the browser on each page.

We use the following categories of cookies on our Platform:

• Strictly necessary cookies: These cookies are essential in order to enable you to move around our Platform and use its features. Without these cookies, services you have asked for such as remembering your login details or shopping basket items cannot be provided. These cookies will also inform us about whether we can do business with you and protect us and our customers from fraudulent activities.

• Performance cookies: These cookies collect anonymous information on how you use our Platform (e.g. we use Google Analytics cookies to help us understand how customers arrive at our Platform, browse or use our Platform) and highlight areas we can improve such as navigation, shopping experience and marketing campaigns. The data stored by these cookies does not show personal details from which your individual identity can be established. They are also used to help measure the effectiveness of an advertising campaign.

• Functionality cookies: These cookies remember choices you make such as the country you visit our Platform from, language and search parameters such as size, colour or product line. These can then be used to provide you with an experience more appropriate to your selections and to make the visits more tailored and pleasant. The information these cookies collect may be anonymised and they cannot track your browsing activity on other websites.

• Targeting cookies or advertising cookies: These cookies collect information about your browsing habits and limited aggregated demographic information in order to make advertising more relevant to you and your interests. They are also used to limit the number of times you see an advert. The cookies are usually placed by third party advertising networks. They remember the websites you visit and that information is shared with other parties such as advertisers. For example, we use third party companies to provide you with more personalised adverts when visiting other websites.

You can withdraw your consent to these cookies at any time through the following options:

• For Google Analytics cookies across all websites, please visit Google Analytics Opt-out Browser Add-on; and
• For any other type of cookies, you can clean the cookies through your browser settings.

Please note that refusing cookies does not mean you will no longer receive online advertising. It does mean that the company or companies from which you opted out will no longer deliver adverts tailored to your web preferences and usage patterns, so you may see a greater number of adverts that are irrelevant to you and your preferences.

We do not respond to web browser “do not track” signals or other mechanisms that provide a method to opt out of the collection of information across the networks of websites and online services in which we participate. At this stage, no uniform technology standard for recognising and implementing DNT signals has been finalised. If a standard for online tracking is adopted that we must follow in the future, we will describe how we do so in this Privacy Policy.

Keeping you and your personal information secure is very important to us. We implement several security measures designed to protect your personal information, including:

• Transport Layer Security (“TLS”) encryption: Using TLS to encrypt personal data transmitted during interactions with our Platform, including your financial or payment information, ensuring that data sent to us is secure and protected from interception;

• One-Time Password (“OTP”) Authentication: Requiring verification through a OTP, sent securely to your registered email or mobile device, when you first create your Valuoo account, periodically during your use of our Platform, or when you log in from a new or unfamiliar device;

• Secure Handling of Payment Details by Authorised Partners: We do not directly store sensitive payment information such as full credit/debit card numbers or CVV security codes. Instead, your payment details are securely processed and saved by our authorised payment service providers and financial partners, who maintain industry-standard safeguards for protecting your data. These authorised providers securely save your payment credentials to facilitate a seamless checkout experience, so you don’t need to re-enter payment details each time. You can view, manage, or delete your saved payment information directly through your Valuoo account settings or at the checkout page on our Platform;

• Regular Security Monitoring: Regularly monitoring our servers, systems, and networks for potential vulnerabilities, threats, and attacks. However, despite our best efforts, the transmission of information over the Internet can never be entirely secure. We cannot fully guarantee the security of personal data transmitted to or through our Platform, and you acknowledge that any such transmission is at your own risk.

Please remember that if you voluntarily disclose personal information through communication methods outside of our Platform (such as email, SMS, or other messaging services), that information may be collected, accessed, or used by others outside of our or your control.

We retain the data you provide to us for as long as you have your Valuoo account with us and thereafter for such period as you may have questions or a claim in relation to our Services, notwithstanding any superior retention period that we may be obliged to observe in accordance with legal requirements applicable to us.

In some circumstances, you can ask us to delete your data as set out below.

After you have terminated your use of our Services, we may store your information in an aggregated and anonymised format.

You have certain rights in relation to the personal data we hold about you, which we detail below. Some of these only apply in certain circumstances as set out in more detail below. We also set out how to exercise those rights. Please note that we will require you to verify your identity before responding to any requests to exercise your rights and that can include asking a set of security questions to ensure it is you. When you have appointed someone else to do the request on your behalf, that person and/or organisation needs to show a valid power of attorney issued by you. We must respond to a request by you to exercise those rights without undue delay and at least within one month (although this may be extended by a further two months in certain circumstances).

To exercise any of your rights, please complete this Data Subject Request Form.

• Be Informed and Access

You have the right to know whether we process personal data about you, and if we do, to access the data we hold about you and certain information about how we use it and who we share it with (including the categories of personal data we share with businesses for their direct marketing uses and the names and addresses of those businesses). Please note that: (i) in your Valuoo account dashboard, you can see information about you, namely your account details (such as name, email, phone number and your order history); and (ii) in the “My Account” settings, you can see most of the information we collect and hold about you.

You can also request a copy of your information. If you require more than one copy of the data we hold about you, we may charge a reasonable administration fee.

We may not provide you with certain personal data if providing it would interfere with another’s rights (e.g. if providing the personal data we hold about you would reveal information about another person) or where another exemption applies.

• Portability

You have the right to receive a subset of the personal data we collect from you in a structured, commonly used and machine-readable format and you have the right to request that we transfer such personal data to another party. The relevant subset of personal data is data that you provide us with your consent or for the purposes of performing our contract with you. If you wish for us to transfer the personal data to another party, please ensure that you detail that party and note that we can only do so where it is technically feasible. We are not responsible for the security of the personal data or its processing once it is received by the third party. We also may not provide you with certain data if providing it would interfere with another’s rights (e.g. if providing the personal data we hold about you would reveal information about another person or our trade secrets or intellectual property).

• Correction

You have the right to correct any personal data held about you that is inaccurate or incomplete. You can edit your personal information in the “My Account” settings. You can also request the correction by emailing us. Please note that in some cases we can ask you to explain in detail why you believe the personal data we hold about you to be inaccurate or incomplete so that we can assess whether a correction is required. Please note that whilst we assess whether the personal data we hold about you is inaccurate or incomplete, you may exercise your right to restrict our processing of the applicable data as described below.

• Erasure

You may request that we erase the personal data we hold about you in certain circumstances. Please see below to learn what those are:

• You believe that it is no longer necessary for us to hold the personal data we hold about you.

• We are processing the personal data we hold about you on the basis of your consent, and you wish to withdraw your consent and there is no other ground under which we can process the personal data.

• We are processing the personal data we hold about you on the basis of our legitimate interest and you object to such processing. Please provide us with detail as to your reasoning so that we can assess whether there is an overriding interest for us to retain such personal data.

• You no longer wish us to use the personal data we hold about you in order to send you promotions and special offers.

• You believe the personal data we hold about you is being unlawfully processed by us.

Also note that you may exercise your right to restrict our processing of the data while we consider your request as described below.

Please provide as much detail as possible on your reasons for the request to assist us in determining whether you have a valid basis for erasure. Please note that we may retain the personal data if there are valid grounds under law for us to do so (e.g. for the defence of legal claims or freedom of expression) but we will let you know if that is the case.

Where you have requested that we erase data that we have made public and there are grounds for erasure, we will use reasonable steps to try to tell others that are displaying the data or providing links to the data to erase the data too.

• Restriction of Processing to Storage Only

You have a right to require us to stop processing the personal data we hold about you other than for storage purposes in certain circumstances. Please note that if we stop processing the personal data, we may use it again if there are valid grounds under data protection law for us to do so (e.g. for the defence of legal claims or for another’s protection).

Listed below are the cases where you may request we stop processing and only store the personal data we hold about you:

• You believe the personal data is not accurate for the period it takes for us to verify your claim.

• You wish to erase the personal data as the processing we are doing is unlawful but you want us to retain the personal data for storage only and stop processing it.

• We wish to erase the personal data as it is no longer necessary for our purposes but you require it to be stored for the establishment, exercise or defence of legal claims.

• You have objected to us processing personal data we hold about you on the basis of our legitimate interest and you wish us to stop processing the personal data while we determine whether there is an overriding interest in us retaining such personal data.

• Objection

At any time you have the right to object to our processing of data about you in order to send you promotions and special offers, including where we build profiles for such purposes and we will stop processing the data for that purpose. You can do this by changing your marketing preferences in your Valuoo account, selecting ‘unsubscribe’ at the bottom of our marketing emails or by completing the Unsubscribe Form. Please note that you will still receive emails related to the orders you make through our Platform or updates to our Privacy Policy.

You also have the right to object to our processing of data about you and we will consider your request in other circumstances as detailed below:

We are processing the data we hold about you (including where the processing is profiling) on the basis of our or a third party’s legitimate interest and you object to such processing. Please provide us with detail as to your reasoning so that we can assess whether there is a compelling overriding interest in us continuing to process such data or if we need to process it in relation to legal claims. Also note that you may exercise your right to request that we stop processing the data whilst we make the assessment on an overriding interest.

• Withdrawal of Consent:

You have the right to withdraw your consent to your data being processed where we use consent as the legal basis. You can withdraw your consent (either generally or in relation to specific hobbies, interests, shopping preferences, brand preferences and/or communication preferences) at any time by changing your preferences in your Valuoo account or by completing the Unsubscribe Form.

• Damages

You have the right to be compensated for any damages sustained due to any inaccurate, incomplete, outdated, false, unlawfully obtained or unauthorised use of personal information, taking into account any violation of your rights and freedoms as data subject.

• Complaints

If you believe that the processing of your data violates any applicable data protection law or that your data protection rights have been violated in any other way, you have the right to complain to the relevant data protection authority.  Notwithstanding that, we encourage you to first contact us to resolve any issues or concerns.

[If you are in Malaysia, the website for the Department of Personal Data Protection is here: https://daftar.pdp.gov.my/p_aduan.]

[If you are in Indonesia, the website for the Ministry of Communication and Digital is here: https://www.komdigi.go.id/.]

[If you are in Philippines, the website for the National Privacy Commission is here: https://privacy.gov.ph/right-to-file-a-complaint/.]

[If you are in Vietnam, the website for the Department of Cybersecurity and High-tech Crime Prevention is here: https://en.bocongan.gov.vn/.]

[If you are in Singapore, the website for the Personal Data Protection Commission is here: https://www.pdpc.gov.sg/complaints-and-reviews.]

[If you are in Cambodia, the website for the [Ministry of Post and Telecommunications] is here: [https://mptc.gov.kh/].]

[If you are in Thailand, the website for the Personal Data Protection Committee is here: https://www.pdpc.or.th/.]

If you are in the European Union, you can find contact details for your “Supervisory Authority” here: https://edpb.europa.eu/about-edpb/board/members_en

If you are in the United Kingdom, you can find contact details for the Information Commissioner’s Office here https://ico.org.uk/make-a-complaint/.

If you are in Australia, the website for the Office Australian Information Commissioner is here: https://www.oaic.gov.au/privacy/privacy-complaints/.

Despite our robust security measures, in the unlikely event of a data breach, we have procedures in place to manage and respond to such incidents.

A data breach refers to a breach of security leading to the accidental or unlawful destruction, loss or alteration of, or unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise processed.

In the event of a data breach that is likely to result in a high risk to your rights and freedoms, we will notify you without undue delay. This notification will describe in clear and plain language the nature of the data breach, the likely consequences, the measures taken or proposed to be taken to address the breach, and recommendations for you to mitigate potential adverse effects.

We will communicate this information to you through appropriate channels, such as your email address or via a notification within your Valuoo account or our mobile application, unless direct communication is not feasible, in which case a public communication may be made.

Where required by applicable data protection laws, including but not limited to the General Data Protection Regulation (the “GDPR”), we will notify the relevant supervisory authorities without undue delay, and where feasible, not later than 72 hours after having become aware of it.

If you have any questions or complaints regarding this Privacy Policy or if you wish to contact us regarding our use or handling of your personal information, you can do so by contacting us via the channels set out below. You can also contact us and request a copy of this Privacy Policy in hard copy or in another format that suits your particular needs.

Any changes we may make to this Privacy Policy in the future will be posted on this page and, where appropriate, notified to you by email. Please check back regularly to stay informed of updates or changes to this Privacy Policy.

If you are a citizen or resident of any country set out below, the relevant country-specific terms set out below will supplement (and should be read together with) this Privacy Policy.  In the event of any inconsistency between such country-specific terms and this Privacy Policy, such country-specific terms will prevail to the extent of such inconsistency.

• Malaysia

Right to limit processing of your personal information

[You may request to limit the processing of your personal information by using the contact details provided under the “Contact Us” section above. However, this may affect our provision of our Services to you.]

• Indonesia

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• Philippines

[For users based in the Philippines, you can click the following link to view the National Privacy Commissioner Seal of Registration of [Me2B Philippines].]

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[If you are based in the Philippines, subject to the limitations and conditions of the Data Privacy Act of 2012 (the “DPA”) and any regulations, rules, guidelines, notifications and orders issued by virtue of the DPA, as may be amended from time to time, you are entitled to the rights set out in this Privacy Policy.]

• Vietnam

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• Singapore

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• Cambodia

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• Thailand

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