PDPA Notice

Version 1.0 - 01 September 2023

The Personal Data Protection Act 2010 (“the Act”), which regulates the processing of personal data in co mmercial transactions, applies to us.

We, MaiMai, take the privacy and protection of your personal data seriously.

So, we have set out the below information about our processing of your personal data by us or on our behalf, what rights youhave, and how you can get in touch if you want to know more.

When we say, “personal data”, we mean information about you, such as your name, date of birth and contact details. We collect personal data from you that is necessary for us to either provide you with the product or service you’ve requested or to comply with statutory or contractual requirements. In order to enable us to deal with your inquiries, open and operate anaccount/investment for you and/or to generally provide you with our products and services, we may need to and/or may berequired to collect, record, hold, use, disclose and store (i.e. “process”) personal information and financial information aboutyou.

For the purpose of this written notice (“Notice”), the terms “personal data” and “processing” shall have the same meaning as prescribed in the Act.

Part A - Personal data we process

Personal and contact details, such as title, full name, contact details and contact details history;
Your date of birth, gender and/or age;
Your nationality, NRIC or other identity copies and details (if relevant to the product or service);
Records of your contact with us such as via the phone number of our customer service centre and, if you get in touch with us online using our online services or via our smartphone app, details such as your mobile phone location data, IP address and MAC address;
Products and services, you hold with us, as well as those you have been interested in and have held and the associated payment methods used;
Analysis of data relating to marketing made to you, including history of communications and whether you open them or click on links;
Information we obtained from third parties, including information about instances of suspect fraud;
Personal data which we obtain from Credit Reference Agencies and Fraud Prevention Agencies, including public and shared credit history, financial situation and financial history;
Fraud, debt and theft information, including details of money you owe, suspected instances of fraud or theft, and details of any devices used for fraud;
Criminal records information, including alleged offences;
Financial details about you, such as your salary and details of other income, details of your savings, details of your expenditure, and payment method(s);
Information about your employment status (if relevant to the product or service);
Your residency and/or citizenship status;
Your marital status, family, lifestyle or social circumstances (if relevant to the product or service). For example, thenumber of dependents you have or if you are a widow or widower;
Information we buy or rent from third parties, including demographic information, details of outstanding finance,marketing lists, publicly available information, and information to help improve the relevance of our products andservices;
Insights about you and our customers gained from analysis or profiling of customers;
Tax information (if relevant to the product or service). For example, for investment accounts.

Part B - Where we get your personal data

We'll collect personal data from the following general sources:

From you directly, through all application/registration forms, and any information from family members, associates or beneficiaries of products and services;
Information generated about you when you use our products and services;
From a broker or other intermediary (for example, our authorized distributors/agents, business partners) who we work with to provide products or services or quote to you, subject to your prior consent;
Cookies, location services, IP addresses when you visit our website or mobile app or when you fill up contact us forms within our website or app;
Third parties connected with you, such as employers, joint account holders, security providers, guarantors and indemnitors, subject to your prior consent;
Third parties such as insurance companies, agents, vendors, financial nstitutions, courts or public records;
Questionnaire and contact details when you attend surveys, investor conferences, roadshows, competitions, promotions or when you update contact us form on our website;
From other sources such as Fraud Prevention Agencies, Credit Reference Agencies, other lenders, publicly available directories, and information (for example, telephone directory, social media, internet, news articles), debt recovery and/or tracing agents, other organisations to assist in prevention and detection of crime, police and law enforcement agencies; and
We buy or rent information about you or customers generally from third parties including demographic information, vehicle details, claims history, fraud information, marketing lists, publicly available information, and other informationto help improve our products and services or our business; and
From such other sources in respect of which you have given your consent to disclose information relating to you and/or where not otherwise restricted.

Part C - How we use personal data and why

We, MaiMai will use the personal data you provide to us, together with other information, for the following purposes (“Purposes”):

Purposes

Legal basis for processing

The administration of our products and services, including to enable us to perform our obligations to you and to provide any relevant services as discussed with you prior to any purchase of a product or service.

Carrying out checks using agencies such as credit reference agencies, tracing companies, or publicly available information (see Part D for more).

To assess your application(s)/request(s) for our products and services.

Necessary for the performance of our contract with you or in order to take steps prior to entering into a contract with you.

To communicate with you, including the but not limited to notify you about benefits and changes to the features of our products and services and to administer offers and competitions.

Provision of customer services – like to reply to a question, complain, tell you that something is changing or to generally resolve disputes.

To better manage our business and your relationship with us, including to understand your current and future investment needs and your financial situation.

Automated decision-making or profiling (see Part E for more).

Keeping your information on record and carrying out other internal business administration.

To conduct market surveys and trend analysis.

To update, consolidate and improve the accuracy of our records.

Transfer or assign our rights, interests, and obligations under any of your agreements with us.

To conduct internal activities including audit, compliance, and risk management purposes.

Necessary for the performance of our contract with you. After our contract is complete, our legitimate interests in maintaining and developing our relationship with you.

Complying with any regulatory or other legal requirements.

For meeting the requirements to make disclosure under the requirements of any laws binding on and for the purposes of any guidelines issued by regulatory or other authorities with which MaiMai or any of its branches and any of MaiMai holding companies, subsidiaries, affiliates, representatives are expected to comply.

To conduct anti-money laundering checks; for crime detection, prevention, and prosecution; to comply with any sanction requirements.

For the purpose of enforcing our legal rights and/or obtaining legal advice.

Compliance with our legal obligations.

Design and provide you with information on our and third-party products, services and offers which may be of interest to you.

Conduct research and statistical analysis (including use of new technologies).

For other legitimate business activities.

For such other purposes directly related to the foregoing.

Our legitimate interests in designing and improving our products, provide value added services, developing our business and gaining insight into how our products are used.

In addition, we, MaiMai will use the personal data you provide to us, together with other information, to sendyou direct marketing offers and promotions by electronic and non-electronic means including by post, as well as sending youintroductions to products and services from carefully selected third parties also by post. Please see part I for further details. Ourlegal basis for this processing is based on your consent.

Who we share your personal data with and why We will share your personal data to the following parties:

Companies and/or organizations that act as our agents, affiliates, business partners, subsidiary(ies), shareholders and its related companies, and/or professional advisers;
Companies and/or organisations (including but not limited to custodians, trustees, distributors, brokers) that assist us in processing and/or otherwise fulfilling transactions that you have requested;
Companies and/or organisations that assist us in providing value dded services that you have requested;
Your advisers and/or agents (including but not limited to brokers, auditors, lawyers, accountants, financial institutions,financial advisers, or other professional advisers), where authorised by you;
Any other person notified by you as authorised to give instructions or to use the account(s), investment(s) or productsand services on your behalf;
Any other agents and/or counterparties that we are required to provide such information to by any laws (includingany regulations, guidelines and/or organisations) and/or court orders;
And other third-party service providers who provide administrative, telecommunications, computer, payment, printing, redemption, or other services to us to enable us to operate our business), industry associations and federations, your jointpolicy or investment holder, professional advisors, researchers, credit reference agencies, debt collection agencies,financial and partnerships for any of the purposes set out in this Part C; and/orƒ
Any other person connected to the enforcement or preservation of any of our rights under your agreement(s) with us.

We keep your personal data for a set amount of time

Your personal data will be stored either for as long as you (or your joint policyholder) are our customer and for a period of sevenyears after the end of the customer relationship, or longer if required by law. There may be specific circumstances where it is necessary for us to retain your personal data for longer (such as when a dispute arises).ƒ

Part D - Reference checks

For certain products, we may use approved credit reference agencies, tracing companies, financial crime preventionagencies, or publicly available information, to help us to check your identity, as well as to prevent fraud and money laundering;this may include checks on your current or previous addresses. Results of these may be recorded for future reference.

These checks may also be carried out for a fund investor, joint account holder or person(s) that you provide personal data on.Should we ever lose contact with you, we may use these agencies to verify your address to help us get back in touch.

Any transfer of your personal data will always be done securely.

Part E - We may use your personal data to make automated decisions or profile you

We, MaiMai may use your personal data to make automated decisions affecting you or to conduct other profiling (for example, marketing profiling).

Part F - Use of your sensitive personal data

For certain products or services, we will need to process your sensitive personal data, such as information relating to ethnicity and sexual orientation. To the extent that we need your explicit consent to process this kind of personal data in the mannerdescribed in Parts C, D, and E, we will provide details of this at the point of collection and seek your consent.

Part G - You're in control

When it comes to how we use your personal data, you have the right to:

Request a copy of your personal data (we have the right to charge a reasonable fee to complete this request) (“data access”);
Request that we correct anything that’s wrong, or complete any incomplete personal data (“data correction”);

If you currently reside in an EU jurisdiction, additional rights under General Data Protection Regulation (GDPR) may apply. As such, you may:

Ask us to delete your personal data if it is no longer needed for the purposes set out in Part A or if there is no other legal basis for the processing;
Object to us using your personal data for direct marketing (including related profiling) or other processing based on legitimate interests;
Request that provides a copy of your personal data in a structured and commonly used format in certain circumstances1; and
Limit how we use your personal data or withdraw your consents (including automated decision making) you havegiven for the processing of your personal data.

You are responsible for ensuring that the information you provide us is accurate, complete, not misleading and is kept up to date.

If you want to exercise your rights, or would like an explanation about these rights, we have explained how you can get in touchin the Contact Us section. The above rights are subject to the provisions of the Act. We may refuse to comply with a data accessrequest or a data correction request and shall, by notice in writing, inform you of our refusal and the reasons of our refusal.

If you do need to speak to us, it will be useful to have to hand that the data controllerof your personal data is MaiMai. We may monitor or record calls or any other communication we have with you. This might be for training, for security,or to help us check for quality.

Part H – Acting on someone else’s behalf?

When you give us personal data about another person (or persons), you should have been appointed and authorized by suchperson to act on their behalf. This includes providing consent to:

Our processing of their personal data and sensitive personal data (as we’ve explained in Parts A - G above); and
You are getting any information protection notices on their behalf.

If for any reason you are concerned as to whether you are permitted to provide us with the other person’s information, pleasecontact us at the email address below before sending us anything.