Introduction
WOW Fintech Sdn Bhd (hereinafter, “WOW Fintech ”,” we”,”us”,”our”) (Company No.1207364-D) respects and values the right to the privacy of our users (“yours”, “you”) and are committed in protecting all Personal Information collected and stored by us. Our privacy policy ensures that we protect the trust you place in us when users provide us with your personal information. It is important for users to read the Privacy Policy together with others applicable notices we may provide on specific occasions when we are collecting, using, disclosing and/or processing personal information about you, so that you are fully aware of how and why we are using your personal information.

This Privacy Policy page serve to describes our practices regarding the Personal Information we collect through the download and usage of WOW Fintech application (“App”) in smartphones and mobile devices, and your use of or access to the WOW Fintech Website (the “Site”) (collectively, together with the App, the “Platform”) and all content, products, services and functionality available at or through the App and the Site (collectively, together with the Platform, the “Services”). This Privacy Policy will explain in:

• The type of Personal Information we collect and how we collect it:.
• Information from third party service providers, with your consent, which may include your profile content or other types of personally identifiable information.
• How Personal Information is used:
• The parties that we disclose the Personal Information to; and
• The choices we offer, including how to access and update your personal information.

By using our Services, you are agreed to the terms of this Privacy Policy and you will be deemed to have consented to the collection, use and disclosure of your Personal Information in accordance to the Privacy Policy.

Collection Of Personal Information
“Personal Information” is any type of data which can be used to identify you or from which you are identifiable which some may/will include sensitive personal information that is sensitive in nature. This includes but is not limited to your name, nationality, race, gender, date of birth, marital status, religion, personal interests, health information, employment information, contact number, bank and credit cards credentials, email address, your image, government-issued identification number (Identification Card No.), biometric data and financial information which in relation with Services such as WOW Fintech points system, account points balance, redemption history and account activities as well as other non-public information about you that is associated with or linked to any of the foregoing data.

In order to enable us to provide you with the Service, we may need to/required to collect, record, hold, use, disclose and store Personal Information for a better experience in using our Service. Some Personal Information is required by us to fulfill partly or all of the services requested by you. However, if you are unable to provide us with the required information, we will be unable to fulfill your request and as a result, you may encounter some inconveniences while using our services.

We collect your Personal Information you provide to us through your relationship with us which includes but not limited to information provided by you when using the Services, interacting with Merchants and more. Following are the examples:

• When you complete a user profile/account (which includes Personal Information such as first and last name, contact number, avatar picture and other identification information when needed.)
• Interacting with Services such as engaging with Merchants and products and services you have purchased.
• Necessary information for completing/making a transaction during purchase or checkout of a Services or product.
• Information discloses through your interaction with the Merchants.
• Information such as messages and coupon that is stored under your account.
• Information from written communications when you provide us a feedback (s) or contact us (e.g. email address and your name as well as other content included in the written communication to us) and we may use it for the purpose of communicating with you and to efficiently be available to support you in resolving any other issues you may face or manage your request.
• We may also collect information that pertain to you directly through other source (if any). When we do so, we require the third party to confirm that the information was legally acquired by them and that they have obtained your consent beforehand. Information collected directly or indirectly may be combined to help us improve overall accuracy and completeness to aid us to better tailor our interactions with you.

Information that is collected by technology:

• Information of you including the web browser type, Internet Protocol (IP) address (a unique number that is assigned to all electronic devices that is used to specifically identify a device in a massive network), domain name, user profiles and date/time stamp of your visit.
• Information from third party service providers, with your consent, which may include your profile content or other types of personally identifiable information.
• Cookies and URL information to gather information regarding the date and time of your visit and the information for which you searched and viewed on the Site. “Cookies” are small pieces of information that a website sends to your computer’s hard drive while you are viewing a website. We may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience on the Platform. Persistent Cookies can be removed by following web browser’s directions.
• Information on how you use and interact with the Site and App via third party analytics services such as  Google Analytics or Google AdSense. Such third-party analytics services may use Cookies to gather information such as the pages you visited, your IP address, a date/time stamp of your visit and the sites that redirected you to the Platform

Information from third parties or other sources which you have given permission/consent to disclose information relating to you and/or where not otherwise restricted (e.g. payment providers, business partners and related partners). Information collected from you about others in situation/event where you decide to invite a third party to create an account on the App. Hence, we will collect your and the third’s party names and e-mail addresses in order to send an e-mail and follow up with the third party. If you are below the age of eighteen (18), you are responsible to obtain consent from your parent, guardian or person who has parental responsibility, prior to disclosing your personal details to us. We ARE NOT TO BE HELD LIABLE for any loss or inconvenient to you for failing to obtain consent.

Use Of Personal Information
For general use or collected by technology. In addition to the purposes stated above, we may use your Personal Information for processing request that you make, or to aid us in providing a better experience in serving you, whether or not through technological means which includes to personalize, maintain and improve our App and Site services. This includes using the Personal Information for the following purposes:

• To facilitate the creation, administration and update on your account.
• To send you a welcome email or text message (TAC) and to verify ownership of the e-mail address or mobile number provided during the creation of account.
• To send you administrative email/ text message notification such as security or support and maintenance advisories.
• To send you update or reminder on account status via email or text messages notification regarding.
• To provide you with Services across various business verticals that collaborate with us.
• To engage you to provide Services.
• To conduct due diligence checks.
• To identify and verify your identity as a user in our system.
• To verify your age (when/where necessary).
• To resolve/investigate/address/provide support on reported issues.
• To send you notifications, alerts, updates, newsletter, mailers, promotional materials, special privileges, festive season greetings.
• To update/alert/notify you on ongoing promotions/events/activities.
• To use your information (with consent) such as resume for job application services.
• To offer, obtain, provide, facilitate or maintain insurance or financing solutions.
• To perform internal operations necessary for our Platform, which includes troubleshooting software bugs and operational problems, conducting data analysis, testing and research, monitoring and analyzing usage and activity trends.
• To protect the security and integrity of the Services and any facilities or equipment used to make the Services available.
• To enable communication between Merchant and users.
• To process, manage or verify your rewards and points.
• To track user-specific information on what pages users’ access or visit.
• Fulfill the services to you as a data processor, where you have provided consent to the data controller (e.g. the business/organization you had previously purchased goods or services from, and for whom WOW Fintech is providing services on behalf of) for such services to be rendered.
• For our day-to-day operations and administrative purposes including account management, billing and collection, audits, reporting and investigations.
• For the purpose of defending or enforcing our legal rights and/or obtain legal advice.
• To assist in the prevention, detection or investigation of crime or possible criminal activities or for the administration of justice.

Disclosure of Your Personal Information

Third Party Service Providers
We may share your Personal Information with our third-party services. This includes:

1. Payment processors and facilitators.
2. Credit bureaus and other credit reporting agencies.
3. Background check and anti-money laundering service providers.
4. Marketing partners and marketing platform providers.
5. Data analytics providers.
6. Merchant partners.
7. Insurance and financing partner.
8. Third party intermediaries involved in the managed investment of funds, such as brokers, asset managers and custodians.
9. Service providers who perform identity verification services.
10. Job Recruitment service.

Affiliates and Acquisitions
We may share some or all of your Personal Information with our joint ventures, or other companies under a common control (our “Affiliates”), in which case we will require our Affiliates to honor this Privacy Policy.

Sharing of Personal Information with Advertisers
We generally will not DISCLOSE any Personal Information to advertiser; however, we do allow advertisers to request that their advertisements are directed at certain users (e.g. users in certain geographical location, or age, gender or with certain interests). In the event that you interact with certain advertisements, the advertisers (or the company which the advertisers work with, for example, its advertising agency or an advertising network) may determine certain characteristic about you.

Third Party directed to consented to by you
We may share your Personal Information with any persons directed by or consented to by you.

Professional Advisors
We may share your Personal Information with our professional advisors including but not limited to legal advisors, tax advisors, financial advisors and respective advisors.

Other Disclosures
Regardless of any choices you make regarding your Personal Information, we may disclose Personal Information if we believe in good faith that such disclosure is necessary:

1. In connection with any legal investigation.
2. To comply with relevant laws or to respond to subpoenas or warrants served on us.
3. To protect or defend our rights or property or users of the Services.
4. To investigate or assist us in preventing any violation or potential violation of the laws, this Privacy Notice, or the Terms of Use.

Retention and Security of Your Personal Information

We take great measures in protecting your Personal Information for the period of retaining Personal Information to fulfil the purposes stated in this Privacy Policy unless retention period is no longer required or allowed by law or you have deactivated and deleted your account. We ensure that your Personal Information are safe with us as we regularly review and implement up-to-date technical and organization security measures to safeguard the confidentiality and security of all your Personal Information against unauthorize access. We take steps to erase, destroy, anonymize or prevent access or use of such Personal Information for any purpose other than compliance with this Privacy Policy, or for purposes of safety, security, fraud prevention and detection, in accordance with the requirements of applicable laws.

Protection Of Your Personal Information

We will take reasonable legal, organizational and technical measures to ensure that your Personal Information is protected. This includes measures stated above to prevent Personal Information from getting lost or used or accessed in an unauthorized way. We limit access to your Personal Information to our employees on a known basis. Those processing your Personal Information will only do so in an authorized manner and are required to treat your information with confidentiality. Nevertheless, please understand that the transmission of information via the internet is not completely secure. Although we will do our best to protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted through any online means, therefore, any transmission remains at your own risk.