PICKUPP DATA PROTECTION POLICY

1.1. Hong Kong Pick-Up Limited. (“Pickupp”) is committed to protecting and respecting your privacy in accordance with Hong Kong's Personal Data (Privacy) Ordinance (Cap. 486) (the “Ordinance”). 1.2. “Personal Data” means any data, whether true or not, which is (a) about an individual who can be identified (i) from that data; or (ii) from that data and other information to which we have or are likely to have access and would include data in our records as may be updated from time to time, or (b) defined as “personal data” under the Ordinance. 1.3. This Privacy Policy describes how Pickupp along with its affiliates (referred to as “we”, “our”, “us” and “Pickupp”) collect, hold, process, transfer and use your Personal Data and what corresponding rights you have in relation to the processing of Personal Data. 1.4. This Privacy Policy covers the following Personal Data that we collect about you (i) “online” when you use or access our web applications, mobile applications (jointly referred to as “Applications”) and our website at https://hk.pickupp.io/en/; and (ii) “offline” (e.g., collection of Personal Data through telephone calls or in person) from activities owned, operated, provided and/or made available by us. 1.5. We operate Applications and websites for logistic services through a platform that connect users of our platform to independent contractors providing delivery, warehouse, fulfillment and other related services including drivers, bikers, or individuals using other modes of transportation, shippers, warehouse and e-fulfilment partners (collectively “Delivery Agents” or “DAs”), and to help facilitate such DAs to provide delivery services and other related services including a marketplace for users of our platform to list their merchandises (“Services”). 1.6. This Privacy Policy applies to Personal Data of (referred as “you” or “your”): 1.6.1. Visitors: individuals, companies, merchants or any entities who who visit our website or download or access the Applications without being a User as defined below; 1.6.2. Users: individuals, companies, merchants or any entities who: (i) use, request or receive Services; (ii) contact us through our website, Applications or by phone or other means of communications; or (iii) subscribe to our updates or blog; 1.6.3. Agents: representatives of companies, merchants or any entities, or business partners such as owners, managers, leaders or other representatives of a fleet; and 1.6.4. Delivery Agents: independent individuals, companies or any entities who provide or submit applications to us to provide Services through our Applications individually or through partner companies, whether or not subsequently successfully registered as a DA for Pickupp. 1.7. Please read this Privacy Policy and understand it before using our website, Services or Applications. 1.8. BY AGREEING TO GIVE US YOUR PERSONAL DATA UPON VISITING OUR WEBSITE, ACCESSING OUR APPLICATIONS, OR OTHER ACTIVITIES OPERATED BY US, YOU ACKNOWLEDGE AND AGREE TO THE TERMS OF THIS PRIVACY POLICY AND GIVE US YOUR CONSENT TO PROCESS YOUR PERSONAL DATA.

2.1. When you visit our website, access or use our Applications and Services, we are likely to ask you to provide your Personal Data. If you do not provide the relevant data, we may not be able to provide you with our Services or respond to any queries you may have. 2.2. We will collect and process the Personal Data: 2.2.1. provided by you directly to us, such as during account creation through our Applications, your participations in our promotional activities, subscribing to our blog or updates, or sending us correspondence through our website, Applications or by phone; 2.2.2. generated during your use of our website, Services and Applications. For example, we may collect your IP address and device information when you visit our website. 2.2.3. we obtained from third parties (such as third party agents, other Users, our service providers and business partners). For example, our third party agents may provide us with additional verification and background information of DAs. 2.3. We may also collect Personal Data through software development kits (“SDKs”) used in providing the Services.

3.1. The Personal Data collected by us about you will include the following data: 3.1.1. from Visitors: IP address or other unique device identifiers; and usage of our website or the Applications. 3.1.2. from Users: 1) Profile Data: name (individual or company name); company information (including business registration, certificate of incorporation, directors and shareholders, financial information); national identification documents; email address; phone number; address; correspondence with us; IP address or other unique device identifiers; payment and banking information; geolocation; User profile information(including login details and passwords, profile picture, language preference, feedback, ratings, compliments, order details, and type of service used and referrer and referee information of a referral program participated by the User); Applications usage or other relevant data; Personal Data voluntarily entered by the User in free text box when using our Services; and any Personal Data voluntarily provided by the Users. 2) Transaction Data: delivery / warehouse / fulfillment items information (weight, dimension, types); details of merchandise that you have listed on, supplied to or purchased through our marketplace; payment and banking information including credit card details; recipient information (name , address, phone number, email); and recipients feedback (ratings, comments); proof of delivery information including drop-off photos, recipient signatures and call logs screenshot; and any other information that may be reasonably required to facilitate the delivery of your items or delivery of our Services . 3.1.3. from Agents: name; email address; company name; job title; phone number; business industry; address; correspondence with us; IP address or other unique device identifiers; payment and banking information; geolocation; agent profile information (including profile photo); applications usage or other relevant Personal Data; copy of ID card or national identification number and expiry date; and any Personal Data voluntarily provided by the Agents. 3.1.4. from DAs: name (individual or company name); company information (including business registration, certificate of incorporation, directors and shareholders, financial information); phone number; email address; home / company address; correspondence with us; IP address or other unique device identifiers; payment and banking information; geolocation; DAs profile information (including login details and passwords, profile picture, vehicle picture, language preference, feedback, ratings, compliments and referrer and referee information of a referral program participated by the DAs); applications usage or other relevant data; driving licence identification number and expiry date; information required to collect and pay any fees; vehicle information and picture; vehicle insurance information; national identification documents; date of birth; information provided during the delivery and completion of Services including proof of delivery information for example drop-off photos, recipient signatures and call logs screenshot; and any Personal Data voluntarily provided by the DAs. 3.2. We only collect Personal Data that we reasonably need for use in connection with the purposes stated in paragraph ‎4 of this Privacy Policy. We do not collect Personal Data that is unnecessary or excessive.

4.1. We may process your Personal Data for the following purposes. 4.1.1. for Visitors, Users and Agents: 1) for the management and administration of our business (including accounting, risk management, compliance and record keeping purposes); 2) to provide and maintain our Services such as to create, update and maintain your account registered with us; enable the delivery and completion of Services; track deliveries or our Services; and offer, process or facilitate payment for deliveries or our Services; 3) for customer service requests, receive feedback and support needs; 4) for conducting investigations relating to disputes, billing or fraud; 5) for resolving complaints, problems or disputes; 6) for facilitating any correspondence between the DAs and you; 7) for processing any insurance claims and payments that may arise under our policies; 8) for legal purposes including but not limited to obtaining legal advice and dispute resolution and meeting or complying with any applicable rules, laws, regulations, codes of practice or guidelines issued by any legal or regulatory bodies which are binding on us; 9) to monitor the use of our website, Services or Applications; 10) to help maintain the safety, security and integrity of our Services and prevent crime and fraud; 11) to personalise your experience on our Applications: identifying your preferences and behaviour help us to better understand your individual needs and interests and provide you with more tailored Services.; 12) to improve our website, Services and Applications or develop new ones: we may use your Personal Data to develop new features and functionality, to improve our software and interface design, we may use the error reports to improve security features; 13) for research and development: your Personal Data will help us test, research, analyse, assist with product development and machine learning to improve your experience; 14) to compile aggregate statistics about you and to analyse your Services and Applications usage; 15) for non-marketing communications related to our Services such as notifications of changes to our Applications or our Services; 16) for marketing and promotions, subject to having obtained your consent in accordance with applicable laws and as contemplated in paragraph ‎14 of this Privacy Policy. 4.1.2. for DAs: 1) for the management and administration of our business (including accounting, risk management, compliance and record keeping purposes); 2) to provide and maintain our Services such as to: create, update and maintain your account registered with us; enable the delivery and completion of Services; track deliveries or our Services; and offer, process or facilitate payment for deliveries or our Services; 3) for customer service requests, receive feedback and support needs; 4) for conducting investigations relating to disputes, billing or fraud; 5) for resolving complaints, problems or disputes; 6) for facilitating any correspondence between the DAs and you; 7) for the purchase of insurance for the DAs and processing any insurance claims and payments that may arise under such insurance policies; 8) for legal purposes including but not limited to obtaining legal advice and dispute resolution and meeting or complying with any applicable rules, laws, regulations, codes of practice or guidelines issued by any legal or regulatory bodies which are binding on us; 9) to monitor the use of our website, Services or Applications; 10) to help maintain the safety, security and integrity of our Services and prevent crime and fraud, including DA screening and due diligence; 11) to personalise your experience on our Applications: identifying your preferences and behaviour help us to better understand your individual needs and interests and provide you with more tailored Services.; 12) to improve our website, Services and Applications or develop new ones: we may use your Personal Data to develop new features and functionality, to improve our software and interface design, we may use the error reports to improve security features; 13) for research and development: your Personal Data will help us test, research, analyse, assist with product development and machine learning to improve your experience; 14) to compile aggregate statistics about you and to analyse your Services and Applications usage; 15) for non-marketing communications related to our Services such as notifications of changes to our Applications or our Services; 16) for marketing and promotions, subject to having obtained your consent in accordance with applicable laws and as contemplated in paragraph ‎14 of this Privacy Policy.

5.1. Our Services require that we share your Personal Data with other users. This includes: 5.1.1. sharing Users’ or Agents’ full name, phone number, Personal Data contained in free text box voluntarily entered by a User, and pick up or drop off locations, details of recipients (including phone number, address) with DAs for the purposes of providing Services; 5.1.2. sharing the DAs’ name, phone number, driver profile information, vehicle information, vehicle picture and geolocation with Users or Agents after a delivery has been initiated for the purposes of completing a delivery; and 5.1.3. if you are a member of a fleet, your Personal Data (e.g. name, phone number, driver profile information, records and reports of usage of our Services and Applications, records of payment, vehicle information) will be shared with the owner or manager of the fleet. 5.2. We may also share your Personal Data to provide our website, Services, Applications with: 5.2.1. our employees, officers, shareholders or independent consultants; 5.2.2. our auditors and external legal and financial advisors; 5.2.3. our suppliers, business partners, data processors and sub-contractors including: 1) payment processors and facilitators; 2) cloud service providers; 3) logistics, delivery, fleet and manpower partners or sub-contractors; 4) debt collectors; 5) data analytics providers; 6) research partners; 7) marketing and advertising agencies who create our advertisements and promotions; 8) background check and identity verification providers; 9) vendors that assist us to enhance the safety and security of our website and Applications, including data protection consultants and certification agencies; and 10) customer service providers. 5.2.4. our insurers, bankers and financiers; 5.2.5. any regulator or government body to whom we are under an obligation or otherwise required to make disclosure under the requirements of any applicable laws; 5.2.6. our affiliates, including our parent company and subsidiaries; 5.2.7. any applicable persons if we believe it is required by applicable laws, legal process (including small claims proceedings and legal proceedings initiated by us to recover the amount owed to us), governmental request or where the disclosure is appropriate due to safety concerns. This includes exchanging your Personal Data with other companies or organisations for the purposes of crime / fraud protection and prevention; or 5.2.8. another company with connection in or during negotiations of any merger, sale of company assets, consolidation or restructuring, financing or acquisition of all or a portion of our business by or into that other company. 5.3. We will ensure third parties are under confidentiality obligations before we share your Personal Data with the third parties set out in paragraph ‎5.2 of this Privacy Policy.

6.1. Your Personal Data may be transferred from the country, state and city (“Home Country”) in which you are present while using our Services to another country, state and city (“Alternate Country”). 6.2. When we transfer your Personal Data from your Home Country to the Alternate Country, we will comply with our legal and regulatory obligations in relation to your Personal Data, including having a lawful basis for transferring Personal Data and putting appropriate safeguards in place to ensure an adequate level of protection for the Personal Data. We will also ensure that the recipient in Alternate Country is obliged to protect your Personal Data at a standard of protection comparable to the protection under applicable laws.

7.1. We will use all reasonably practicable steps and security measures, including organisational, physical and technical security measures that are in line with the industry standards to ensure that your Personal Data is stored securely and protected by us and our data processors against unauthorised or accidental access, processing, erasure, loss or use. However, we will not be responsible for any unauthorized use of Personal Data by third parties which is attributable to factors beyond our control. 7.2. Your Personal Data will be kept confidential and secure except for the purposes and uses as set out in this Privacy Policy and will only be disclosed on a “need-to-know” basis. 7.3. If we outsource and entrust your Personal Data with data processors, we will use contractual and other means to monitor the data processors’ compliance with this Privacy Policy. 7.4. The transmission of information through the internet is not completely secure. Although we use security measures to secure your Personal Data, we cannot guarantee the security of your Personal Data transmitted to the Applications and any transmission is at your own risk.

8.1. Personal data collected from you will not be kept longer than necessary for the carrying out of the purposes stated in paragraph ‎4 of this Privacy Policy, unless otherwise required or permitted by applicable laws. 8.2. Your Personal Data will be retained by us for as long as is necessary for the purposes stated in paragraph 4 of this Privacy Policy, or for as long as is permitted by applicable laws. We may retain your Personal Data for a longer period if it is necessary for us to do so to comply with our contractual or legal obligations, or you have consented to our continued retention of it. 8.3. At the end of the retention period, we will take steps to erase, destroy, anonymise or prevent access or use of such Personal Data 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.

9.1. You have the right, if expressly permitted by the applicable laws and regulations, to: 9.1.1. check whether we hold any Personal Data and, if we hold the Personal Data, to access or receive copies of such Personal Data; 9.1.2. request us to make necessary correction to any Personal Data if it is inaccurate or incomplete; 9.1.3. request the restriction of, object to or withdraw consent to the processing of any Personal Data; and 9.1.4. request that we erase, block or anonymise your Personal Data. 9.2. You can exercise some of your rights through your Applications account or you can exercise all your rights by contacting us using the details set out in the “Contact us” section below. 9.3. Exercising your rights pursuant to paragraphs 9.1.3. And 9.1.4. above could mean that we are unable to perform the actions necessary to achieve the purposes of processing described in paragraph 4 of this Privacy Policy or that you are unable to make use of the Applications or the Services. 9.4. After exercising your rights pursuant to paragraphs 9.1.3. And 9.1.4. above, we may be able to continue to process your Personal Data to the extent required or otherwise permitted by applicable laws and regulations.

10.1. We or our authorized service providers and advertising partners may from time to time use certain cookies (such as Google Analytics’ cookies) and other similar technologies for the purpose of enabling you to use the Services (for example to enable you to complete a registration or access information) and for us to understand and save your preferences for future visits, keep track of advertisements and compile aggregate data about site traffic and site interaction so that we can offer better site experiences and tools in the future. 10.2. “Cookies” are identifiers that are stored on your computer or mobile device that record data about computer or device, how and when our website, Applications and Services are used or visited, by how many people and other activity within our website and Application. We may link cookie information to Personal Data. 10.3. You can choose to disable cookies (through your browser or device settings) although you should be aware that this may prevent you from being able to use all parts of our Services.

11.1. We may, from time to time, include or offer links to third party products or services on our website or Applications. 11.2. These linked sites have separate and independent privacy policies as well as security arrangements. Even if the third party is affiliated with us, we have no control over these linked sites, each of which has separate privacy and data collection practices independent of us. Data collected by our co-brand partners or third party web sites (even if offered on or through our Platform) may not be received by us. 11.3. We therefore have no responsibility or liability for the content, security arrangements (or lack thereof) and activities of these linked sites. These linked sites are only for your convenience and you therefore access them at your own risk.

12.1. We may modify, update or amend this Privacy Policy from time to time. When we modify, update or amend our Privacy Policy, we will take appropriate measures to inform you, consistent with the significance of the changes we make. 12.2. You should review this Privacy Policy periodically. By continuing to use our website, our Applications or Services or continuing to communicate or engage with Pickupp following the effective date of the modifications, updates or amendments to this Privacy Policy, whether or not reviewed by you, you will be deemed to have accepted the changes or updates to this Privacy Policy and shall constitute your agreement to be bound by such amendments.

13.1. For any questions relating to your Personal Data or about this Privacy Policy, if you have a complaint regarding the collection, use or handling of your Personal Data by us, you may contact our Data Protection Officer through email dpo@pickupp.io.

14.1. We may use your Personal Data to send you marketing communications relating to products, services and offers that may be of interest to you based on your profile. 14.2. The marketing activities we conduct using your Personal Data includes 1) newsletters and our blog updates 2) promotions and advertisements in respect our website, Services or Applications 3) updates in respect our website, Services or Applications 4) surveys in respect of our website, Services or Applications 5) event invitations 6) festive greetings 7) loyalty program with gifts 14.3. You may request us to cease using your Personal Data for marketing purposes at any time by replying with the heading “unsubscribe” to any marketing communication from us.

15.1. In case of any inconsistencies between the English version and any other language version, the English version shall prevail.