Latest Update: September 26th, 2023

Effective Date: September 26th, 2023

Ø Introduction

This Privacy Policy is fully committed to implementing and complying with applicable privacy laws and regulations, including but not limited to the Personal Data Protection Act 2012 of Singapore (“PDPA”) in order to inform you of your choices and our practices regarding any personal information you provide to us. Your use of the product(s), service(s) and related websites (“Service”) provided by JIMI PTE.LTD(Singapore) limited (“JIMI PTE.LTD”, “we” or “us”) involves the collection, disclosure and use of your personal information. It is important for you to understand how this happens and how you may control it. This Privacy Policy explains the types of information that we may collect, disclose and hold, how that information is used and with whom the data is shared. It also sets out how you can contact us if you have any queries or concerns about this Privacy Policy.

When you use the Service provided by us, you accept our rules and policies regarding your personal information and you expressly consent to us collecting, processing, using, disclosing and storing your personal information, as described in this Privacy Policy. You have the right to withdraw your consent at any time, and upon such withdrawal, we will cease to collect, process, store, disclose and use your personal information.

If you do not agree to the terms and conditions in this Privacy Policy, or if you do not want us to collect, use or disclose your personal information as described herein, please do not use the Service.

Ø The Types of Personal Information We Use

This section describes the different types of personal information we collect and how we collect it. We will collect and use the following information about you:

² Information you provide:

(i) When you register for the Service using third-party social media or similar accounts (e.g. Facebook, Twitter, Google or Apple etc., collectively “Social Media Accounts”) in order to set up your profile (we import from your connected Social Media Accounts your personal information which may include your name/nickname/username as it appears on your social media profile, your profile picture, your friend list, and your account ID);

(ii)When you register for the Service using email addresses (including your email address and your name/nickname/username);

(iii)When you set up your profile for the Service (including information you voluntarily elect to provide in order to customize gameplay, including but not limited to your name/nickname/username, your gender, your age, etc.) and set up your account for the Service (including information you provide to help set up the account, including but not limited to your phone number, email address, security questions, etc.);

(iv)When you submit your name, date of birth, domestic citizenship or foreign status information for age verification or compliance with applicable laws and regulations;

(v) When you submit your contact details to us (including your name, email address and physical address) as part of promotional activities for the Service;

(vi)When you use location-based functions in the Service (“Location Services”) (including GPS location information, cell-ID, Wi-Fi connection location); and

(vii)When you make purchases using your account (in which case we will process the information you provide to us to facilitate the payment), etc.

² Information we collect about you:

We automatically collect certain data from you when you use the Service, including your IP address and device information (such as device type, network data, operating system etc.) and information regarding your use of and interaction with the Service, such as date and time stamps of actions. We also collect and store your data each time you interact with us, for example, when you use in-app support to communicate with us.

² Information you generate and display in the course of using the Service:

You may provide additional information as part of your profile. You may also provide or generate information when you communicate with other users in the Service (e.g., chat log). You acknowledge and agree that information generated within our Service should not be considered private and communications within our Service may be viewed/heard by other users. Please avoid revealing any personally identifiable or sensitive information during such communications.

Ø Representations and Warranties

You represent and warrant that:

(i)any information you provide when registering an account or when using the Service are true, accurate, current and complete; and

(ii)If you provide the personal information of another individual to us: (a) you have obtained the consent of such individual to provide us with his or her personal information for the relevant purposes and are otherwise permitted to do so under applicable law, without us taking any further steps; (b) we may collect, use, disclose and store such information as described in this Privacy Policy, (c) the individual concerned is aware of the terms and conditions in this Privacy Policy, (d) the information you provide to us about such individual are true, accurate, current and complete.

Ø Purposes of Data Collection and Use

Your personal information collected and stored by us may be used for the following purposes:

² Provision of product and services

(i)Provide you with a product or service you have requested (including any product or service updates) and checking that a payment is not made fraudulently, and delivering your purchase to you or ensuring that you benefit from any relevant special offer or promotion (and fulfil its obligations under any other agreement it may have with you);

(ii) Provide customer service (whether in-person, online, by phone, email, social media or otherwise)

(iii) Provide customer service and support, installation, warranty, repair, returns and other after sales services;

(iv) Conduct and host our events, competitions, roadshows, seminars, workshops and engaging in our redemption activities;

(v) Establish and maintain your account with us;

(vi) Provide our checkout assistance service;

(vii) Facilitate your use of services provided by JIMI PTE.LTD.

² Product and service development

(i) Work constantly to improve our Service to better meet customer requirements, to ensure data quality, to develop identity management, and to strengthen network and information security;

(ii) Conduct prize draws, contests and other promotional offers;

(iii) Post messages to our social media, internet platform or any other means or answer a survey;

(iv) Tailor our Service to your needs - information on service use may be used to compile aggregate statistics and carry out analysis in order to help us create content and navigation that is most relevant and user friendly to users;

(v) Conduct analytics to better target and provide personalized contents, recommendations or advertisements within any service, or application used by you;

(vi) Other purposes directly relating to any of the above.

² Preventing unauthorized use of the Service

(i) Detect, investigate, and respond to security incidents and protect against illegal or objectionable activities, including the unauthorized use of the Service.

Ø Transfer of Personal Information

You acknowledge and authorize your personal information will be retained by us and stored in one or more of our databases. We will maintain full control over and safeguard, according to strict standards of security and confidentiality, but may share your personal information with the following individuals and/or entities whether within or outside of Singapore, for any of the purposes set out above:

(i) Any agent, contractor or third party service provider who provides services to us including analytic and processing, administrative, accounting, customer service, data hosting, logistics distribution, delivery and fulfillment, installation, fraud detection, telecommunications, computer, payment gateway, marketing, insurance, financing, legal, and other professional services to us;

(ii) Any branch, subsidiary, holding company, associated company or affiliate of ours;

(iii) Credit reference or debt collection agency or similar provider of debt collection or credit information services to us for purpose of credit reporting, verification and risk management;

(iv)Third party advertising partners so that they can better target and/or personalize advertisements displayed within any application used by you;

(v) A third party purchaser or seller, and its and our professional advisors, in connection with a corporate event such as a merger, business acquisition or insolvency situation;

(vi) Any person or authority to whom we are under an obligation to make disclosure under the requirement of any law, regulations, rules, codes of practice or guidelines binding on or applicable to us;

(vii) Any other entity under a duty of confidentiality to us which has undertaken to keep such information confidential;

(viii) Persons whom you transact with through our Service such as online merchants, or any banking, financial or other institutions.

Where there is a transfer of your personal information out of Singapore, we will take steps to ensure that your personal information continues to receive a standard of protection comparable to that provided under the PDPA.

Ø Direct Marketing

In accordance with the requirements of the PDPA, we intend to use and transfer your personal information for the purposes of conducting direct marketing and may not do so unless we have received your consent or written consent (in the case of transfer).

With your consent or written consent (in the case of transfer) (which includes an indication of no objection), we may:

(i) use personal information, including your name, contact details including email, phone number and address for direct marketing purposes;

(ii) conduct direct marketing in relation to the products and services that we, our affiliates, our co-branding partners and our business partners may offer;

(iii) provide the personal information described in the section entitled “The Types of Personal Information We Use” to any agent or contractor for the purpose of carrying out direct marketing of the above products and/or services on our behalf ; and

(iv) in addition to marketing the above products and services, share the personal information described in the section entitled “The Types of Personal Information We Use”, with any third party provider of any of the classes of products and/or services as described in the section entitled “Transfer of Personal Information” for direct marketing purposes in relation to such classes of products and/or services, and we require your written consent (which includes an indication of no objection) for the purposes and will not do so without your written consent.

If you do not consent to us using and/or sharing your personal information for any of those purposes, we may not conduct direct marketing to you and provide your personal information to others for direct marketing purposes. You may also subsequently withdraw your consent by writing to our Data Protection Officer at the below address. If you exercise your right to opt out of the use/sharing of your personal information for any of the above purposes, it will mean that we, our group companies and/or third party service providers will not be able to send you any direct marketing, targeted or special offers in the future. When you exercise your right to opt out of direct marketing, we shall cease to use and transfer your personal information for direct marketing purposes, without charge.

Ø Cookies and Other Tracking Technologies

We may use cookies and other similar technologies (e.g. web beacons, log files, scripts and eTags) (“Cookies”) to enhance your experience when using the Service. Selected third parties may also use Cookies when you access your account using Social Media Accounts. Cookies are small files which, when placed on your device, enable us to provide certain features and functionality. The data collected from cookies is currently used to improve the functionality of our Service.

Ø Security

We are concerned with the security of your personal data collected and has put in place measures to prevent unauthorized access to that data. Our systems safeguard electronic communications by utilizing appropriate security protocols for authentication and authorization, including SSL, encryption and firewalls.

Ø DISCLAIMER REGARDING SECURITY AND THIRD PARTY SITES

(i)WE DO NOT GUARANTEE THE SECURITY OF PERSONAL DATA AND/OR OTHER INFORMATION THAT YOU PROVIDE ON THIRD PARTY SITES. We do implement a variety of security measures to maintain the safety of your personal data that is in our possession or under our control. Your personal data is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems, and are required to keep the personal data confidential. When you place orders or access your personal data, we offer the use of a secure server. All personal data or sensitive information you supply is encrypted into our databases to be only accessed as stated above.

(ii) In an attempt to provide you with increased value, we may choose various third party websites to link to, and frame within, the Site or Games. We may also participate in co-branding and other relationships to offer e-commerce and other services and features to our visitors. 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 Site or Games) may not be received by us.

(iii)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. To the maximum extent permitted by applicable laws, we shall not be liable and do not accept any liability for any damage or loss of any kind which arises, whether directly or indirectly, from your access and use of such linked sites. Nonetheless, we seek to protect the integrity of our Site and Games and the links placed upon each of them and therefore welcome any feedback about these linked sites (including, without limitation, if a specific link does not work).

Ø INFORMATION ON CHILDREN

The Service are not intended for children under the age of 13 (or other age threshold required by local laws). We do not knowingly collect or maintain any personal data or non-personally-identifiable information from anyone under the age of 13 nor is any part of our Site, Games or other Services intended for them. As a parent or legal guardian, please do not allow such children under your care to submit personal data to JIMI and please also consult us for more information. In the event that personal data of a child under the age of 13 in your care is disclosed to us, you hereby consent to the processing of the child’s personal data and your acceptance and agreement to be bound by the terms of this Privacy Policy on behalf of such child. In the event you do not in fact consent to the processing of the personal data of a child under the age of 13 in your care, please contact our Data Protection Officer. We will close any accounts used exclusively by such children and remove and/or delete any personal data that was submitted without parental consent by such child or as otherwise required by applicable law.

Ø Period of Retention

We retain your personal information for as long as necessary for the purposes set out in this Privacy Policy, or as agreed between you and us, unless otherwise required or permitted under applicable law. Where we no longer require your personal information for the purposes under this Privacy Policy, or otherwise required under applicable law, we will take appropriate steps to securely delete or destroy your personal information.

Ø Access, correction and deletion of personal data

In accordance with the PDPA, you have the right to request access to, correction of and deletion of the personal data we hold about you. If you have such a request, please contact us through our customer support service or fill out the Data Access/Correction/Deletion Request Form available on our website. We will process your request as quickly as possible and provide you with the requested information or perform the necessary corrections or deletions, as required by law.

Ø Updates to The Privacy Policy

We respect our users' privacy and recognize the need to update this Privacy Policy as and when new features and business services are offered by us. Users will be notified of any changes to the Privacy Policy before the changes become effective. If you do not agree to any updates or changes to the Privacy Policy, please do not use the Service (or any part thereof). Your continued use of the Service and submission of personal data and other information in connection with your use of the Service shall be deemed as your acknowledgement and acceptance of the revised Privacy Policy.

Ø Contact Us

For requests to access/correct/delete your personal data, please complete Data Access/Correction/Deletion Request Form (which should include customer information, requested data, correction, deleted data, use of personal data) and post to: business@jmjimi.com or the following address: 10 ANSON ROAD #33-17 INTERNATIONAL PLAZA SINGAPORE (079903)

Please note that a reasonable fee may be charged for an access request. If so, we will inform you of the fee before processing your access requests.

Please note, in accordance with the PDPA, we will process your request as quickly as possible after receiving it, subject to payment of the relevant administrative fees (if any).

If we are unable to process your request or we have legitimate reasons to deny your request, we will notify you as soon as possible. To ensure that we can process your request in a timely and accurate manner, we may need to obtain more information about you. We will guarantee that all processing of personal information complies with the PDPA.