Privacy Policy (October 2021) Our Commitment to Protect Your Privacy We highly values your personal data and privacy and is committed to preserving the confidentiality and security of all personal information. When you use our services, you entrust us with your personal information. This Privacy Policy sets out the standards and expectations on OUR’s commitment to safeguarding your personal data in terms of what information we gather about you, how we use and process that information and who we give that information to. It also defines your rights in relation to your personal data and who you can contact for more information or queries. To ensure that you feel comfortable and confident about providing your personal data for us, please read this Privacy Policy carefully to understand how and why we collect and process your personal data. We will notify you when there are any changes to our Privacy Policy, including by posting the revised policy on our website. The changes will be effective from the date of posting. 1. What this Privacy Policy covers and Who it applies to We recognise the indispensability of your personal data and are committed to protecting your privacy and handling your personal information in an open, transparent and secure manner. This Privacy Policy outlines how we will collect, handle, use, store, share and protect your personal data when you: 1. Making a purchase for our products and services; 2. Visiting and/or using our website; or 3. Participating in our promotion events, activities, or register as our loyalty program member. This Privacy Policy applies to any personal information collected on or through OUR websites and mobile apps. Under specific circumstances, we will provide a separated privacy notices, with detailed rationales and purposes that this Privacy Policy does not cover. 2. What Personal Data we collect They comprise of personal data contained in the following: A. Consumer Data including, but not limited to:- 1. Personal Information: full name, contact number, email address, delivery address; 2. Feedback after purchasing our products and services; 3. Personal interests and preferences. B. Sensitive Personal Data Under specific scenarios, we may also collect “sensitive”, or “special categories” of personal data that are fit for purpose, such as the following: 1. Unique Personal Identifier a. Identification Number, b. Address The above-mentioned definition are broad categories that can be found in multiple jurisdiction, under the specific circumstances, we will provide more detail under the specific privacy notice on the types of sensitive personal data, purpose and subsequent handling requirements that would be expected from us. An explicit consent would also be required if you wish to provide us with the sensitive personal data. If the provision of such sensitive personal data is mandatory for the purpose of collection, we will clearly indicate to you that the provision of this information is mandatory, and the consequences if you choose not to provide the relevant information. 3. How we will collect and use your Personal Data We will primarily collect personal data directly from you, however, in some cases we may also collect your personal data indirectly from the following sources: 1. Background check providers; 2. Third party service providers that assist us to operate and run our business; 3. Ours Affiliates, Subsidiaries, or Business Partners such as Coca-Cola Company Limited. Such collection from external sources will be notified and stated in the specific privacy notice prior to the engagement and collection from such sources. We will collect and process your personal data primarily in the following scenarios: 1. Placing an order for any of our products or services; 2. Browsing or using our website via your browsers with cookies enabled; 3. Participating in our promotion events or activities 4. Purposes of collecting your Personal Data WE may use your personal data for the following purposes: A. For personal data collected from the consumer 1. To provide our products and services for you, to contact you in relation to logistic arrangements of delivering the products and services to you, and to send you service-related communications; 2. To tailor and personalise our products and services to you, to better match your preferences and interests, and to provide or facilitate any special assistance you may have asked for; 3. To record and facilitate your payment for purchasing our products and services; 4. To carry out your instructions, to respond to your enquiries, and to provide customer services and assistance; 5. To notify you about our new products, special offers and other special promotions with your explicit consent; 6. To perform investigation, research or statistical analysis in order to improve our products and services, and benefit our customer; 7. To ensure safety and security of our consumers, and to undertake any necessary activities during emergency events; or 8. To comply with any legal, governmental or regulatory requirements in relevant jurisdiction including but not limited to verifying and processing payment, screening against fraud, screening against abusive purchasing, money laundering and other criminal or unlawful activities. We will process your personal data following the requirement of applicable laws on an appropriate legal basis, including: • Necessary for the performance of a contract; • Necessary for any legal obligations; • Necessary to protect the vital interest that are essential for someone’s life; • Necessary for the performance of a task in public interest; • Processing based on the legitimate interest of US or a third party when we use your personal data to contact you, conduct direct marketing or make a survey, improve our products and services. Legitimate interest includes enabling us to more effectively manage and operate our business and provide our products and services; protecting the security of our businesses, systems, products, services, customers, consumers, business partners, employees and internal management, complying with internal policies and processes; and other legitimate interest described in this policy. We will not intentionally use, share or sell your personal data in ways which are unrelated to the above purposes (or purposes as specified in Personal Information Collection Statement or Privacy Notice when we collect your Personal Data) without your prior consent. We will notify you when there are any changes to our purpose of collecting your personal data, we might need to re-obtain your consent if there is any alteration beyond the processing purpose as mentioned above. 5. Who we share your Personal Data with To facilitate the purposes mentioned in 4. Purposes of collecting your Personal Data, we may transfer, disclose, grant access to or share your Personal Data under specific scenarios, with third-parties for the following purposes (whether within or outside the country in which you are located): 1. Third-party service providers engaged by us to assist with providing you with our products and services; 2. Third-party service providers engaged by US to assist processing your Personal Data such as payroll providers, background check providers or recruiters; 3. WE direct and indirect subsidiaries, holding companies and associated companies or affiliates 4. Other business partners such as website, mobile app and loyalty programme operators; 5. Marketing partners who provide marketing services or conduct marketing or social interaction activities including campaigns, contests, sweepstakes, market research, customer surveys and data analytics; 6. Law enforcement agencies, government and regulatory bodies, and other organisations. Details of such external sharing of personal data would be specified in the individual Privacy Notice(s) or Personal Information Collection Statement(s) prior to your collection. Depending on your region, explicit consent may be required for such processing or sharing to take place. 6. Usage of your Personal Data for Statistical Analysis We may also use your personal data to analyse our customers’ and consumers’ preferences to establish market trends and derive insights. This may involve combining personal data that we hold about your purchased records with information that we have collected about your web usage. Similar to 5. Who we share your Personal Data with, the aggregated data that are used for statistical analysis are not personally identifiable. 7. Retention of your Personal Data Your personal data will be retained for as long as the purpose(s) for which it was collected and any other permitted associated purpose(s). Our retention periods are based on the actual business needs and your information will either irreversibly anonymised or securely disposed of once the purpose of collection has been fulfilled. 8. Your rights and contacting us You control the personal data shared with us, and have the right to exercise any of your entitled Data Subject Rights based on the respective jurisdiction or statutory requirements within the specific region. As such Data Subject Rights differ from different jurisdiction, please refer to the Appendix for more details. 9. Changes to this Privacy Policy This Privacy Policy was last updated on October 2021. This Privacy Policy does not extend to third-party websites that may be linked from our website, or from any other broadcast affiliated with us. It may be subject to amendments. Any future changes or additions to the processing of personal information as described in this policy affecting you will be communicated to you through an appropriate channel, depending on how we normally communicate with you.