Last updated: November 08, 2022

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WHO ARE „WE“?

When we refer to „we“ (or “Company”, „our“ or „us“) that means Libra Incentix Pte. Ltd. Our

headquarters are in Singapore, 68 Circular Road, #02-01.

We are committed to protecting your personal information and your right to privacy. If you have

any questions or concerns about this privacy policy, or our practices with regards to your

personal information, please contact us at support@libraincentix.com.

When you use our web or mobile application, as the case may be (the "App") and more

generally, use our website or any of our services (collectively the "Services”), we appreciate

that you are trusting us with your personal information. We take your privacy very seriously. In

this privacy policy (the “Privacy Policy”) we seek to explain to you in the clearest way possible

what information we collect, how we use it and what rights you have in relation to it. We hope

you take some time to read through it carefully, as it is important. If there are any terms in this

This privacy policy applies to all information collected through our Services, as well as, any

related services, sales, marketing or events.

PLEASE READ THIS PRIVACY POLICY CAREFULLY AS IT WILL HELP YOU

UNDERSTAND WHAT WE DO WITH THE INFORMATION THAT WE COLLECT.

TABLE OF CONTENTS

1. WHAT INFORMATION DO WE COLLECT? ................................................................................. 2!

2. HOW DO WE USE YOUR INFORMATION? ................................................................................ 5!

3. WILL YOUR INFORMATION BE SHARED WITH ANYONE? ...................................................... 6!

4. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES? ....................................... 8!

5. HOW LONG DO WE KEEP YOUR INFORMATION? ................................................................... 8!

6. HOW DO WE KEEP YOUR INFORMATION SAFE? .................................................................... 8!

7. DO WE COLLECT INFORMATION FROM MINORS? ................................................................. 9!

8. WHAT ARE YOUR PRIVACY RIGHTS? ...................................................................................... 9!

9. INTERNATIONAL DATA TRANSFERS ...................................................................................... 11!

10. DO WE MAKE UPDATES TO THIS POLICY? ......................................................................... 11!

11. HOW CAN YOU CONTACT US ABOUT THIS POLICY? ......................................................... 12!

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you provide to us when you register on the App and/or

Services, express an interest in obtaining information about us or our Services, when you

participate in activities on the App and/or Services (such as redemption of loyalty points,

redemption of discount or points with monetary values associated to them or otherwise), or on

third-party services integrated with our App (such as Point of Sale systems, ecommerce sites,

CRMs, ERPs, accounting software and BI tools) or otherwise when you contact us.

The personal information that we collect depends on the context of your interactions with us and

the Services, the choices you make and the products and features you use. The personal

information we collect may include the following:

Personal Information Provided by You. We collect your name, gender, date of birth, country

of origin, email address, mobile number, usernames, passwords as well as your shopping

preferences made when using the App.

Payment Data. We use Stripe payment solutions to transfer the cash equivalent of loyalty points

between you and our partners. All payment data is stored by Stripe payment solutions. You may

find their privacy policy here.

Information automatically collected

In Short: Some information — such as your Internet Protocol (IP) address and/or browser and

device characteristics — is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use or navigate the Services. This

information does not reveal your specific identity (like your name or contact information) but may

include device and usage information, such as your IP address, browser and device

characteristics, operating system, language preferences, referring URLs, device name,

information about how and when you use our Services and other technical information. This

information is primarily needed to maintain the security and operation of our Services, and for

our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies.

The information we collect includes:

■ Log and Usage Data. Log and usage data is service-related, diagnostic, usage and

performance information that servers automatically collect when you access or use our

Services and which we record in log files. Depending on how you interact with us, this

log data may include your IP address, device information, browser type and settings and

information about your activity in the Services (such as the date/time stamps associated

with your usage, pages and files viewed, searches and other actions you take such as

which features you use), device event information (such as system activity, error reports

(sometimes called 'crash dumps') and hardware settings).

■ Device Data. We collect device data such as information about your computer, phone,

tablet or other device you use to access the Services. Depending on the device used,

this device data may include information such as your IP address (or proxy server),

device and application identification numbers, location, browser type, hardware model

Internet service provider and/or mobile carrier, operating system and system

configuration information.

Information collected through our App

In Short: We collect information regarding your geo-location, mobile device, push notifications,

when you use our App.

If you use our App, we also collect the following information:

■ Geo-Location Information. We may request access or permission to and track location-

based information from your mobile device, either continuously or while you are using

our App, to provide certain location-based services. If you wish to change our access or

permissions, you may do so in your device's settings.

■ Mobile Device Access. We may request access or permission to certain features from

your mobile device, including your mobile device's reminders, sms messages, emails,

storage, and other features. If you wish to change our access or permissions, you may

do so in your device's settings.

■ Mobile Device Data. We automatically collect device information (such as your mobile

device ID, model and manufacturer), operating system, version information and system

configuration information, device and application identification numbers, browser type

and version, hardware model Internet service provider and/or mobile carrier, and Internet

Protocol (IP) address (or proxy server). If you are using our App, we may also collect

information about the phone network associated with your mobile device, your mobile

device’s operating system or platform, the type of mobile device you use, your mobile

device’s unique device ID and information about the features of our App you accessed.

■ Push Notifications. We may request to send you push notifications regarding your

account or certain features of the App. If you wish to opt-out from receiving these types

of communications, you may turn them off in your device's settings.

This information is primarily needed to maintain the security and operation of our App, for

troubleshooting and for our internal analytics and reporting purposes.

Information collected from other sources

In Short: We may collect data from third party service providers integrated with our App or from

our partners that use the App.

In order to better understand your consumer trends, to identify loyalty points awarded to you,

loyalty points redeemed by you or exchanged for points with monetary value associated with

them, and make more informed marketing decisions, we may obtain information about you from

other sources, such as third party service providers integrated with our App or from our partners

that use the App. This information includes your personal profile data, data relating to point

accrual and redemption.

2. HOW DO WE USE YOUR INFORMATION?

In Short: We process your information for purposes based on the fulfilment of our contract with

you, compliance with our legal obligations, legitimate business interests and/or your consent.

We use your personal information for a variety of business purposes described below. We

process your personal information for these purposes in order to enter into or perform a contract

with you, in reliance on our legitimate business interests, with your consent, and/or for

compliance with our legal obligations. We indicate the specific processing grounds we rely on

next to each purpose listed below.

We use the information we collect or receive:

■ To facilitate account creation and logon process. We use you information in order to

facilitate creation of your account and logon process.

■ To manage user accounts. We may use your information for the purposes of managing

your account and keeping it in working order.

■ To send information to you. We may use your personal information to send you

notification about or in connection with App, about new rewards or coupons redeemable

in the App, new or existing features, new partners and their rewards or coupons

redeemable, and/or information about changes to our terms, conditions, and policies.

■ To protect our Services. We may use your information as part of our efforts to keep our

Services safe and secure (for example, for fraud monitoring and prevention).

■ To enforce our terms, conditions and policies for business purposes, to comply

with legal and regulatory requirements or in connection with our contract.

■ To respond to legal requests and prevent harm. If we receive a subpoena or other

legal request, we may need to inspect the data we hold to determine how to respond.

■ Fulfil and manage your loyalty points redemption, tasks and performances. We

may use your information to fulfil and manage your loyalty points redemption, tasks and

performances.

■ Administer prize draws and competitions. We may use your information to administer

prize draws and competitions when you elect to participate in our competitions.

■ To respond to user inquiries/offer support to users. We may use your information to

respond to your inquiries and solve any potential issues you might have with the use of

our Services.

■ To send you marketing and promotional communications. We and/or our third-party

partners may use the personal information for marketing purposes, if this is in accordance

with your preferences. For example, when expressing an interest in obtaining information

about us or our Services, our new partners, new promotions, discount offers and other,

we will collect personal information from you. You can opt-out of our marketing emails at

any time (see the "WHAT ARE YOUR PRIVACY RIGHTS" below).

■ Deliver targeted advertising to you. We may use your information to develop and

display personalized content and advertising (and work with third parties who do so)

tailored to your interests and/or location and to measure its effectiveness.

■ For other business purposes. We may use your information for other business

purposes, such as data analysis, identifying usage trends, determining the effectiveness

of our promotional campaigns and to evaluate and improve our Services, products,

marketing and your experience. We may use and store this information in aggregated

and anonymized form so that it is not associated with individual end users and does not

include personal information. We will not use identifiable personal information without

your consent.

3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?

In Short: We only share information with your consent, to comply with laws, to provide you with

services, to protect your rights, or to fulfil business obligations.

We may process or share your data that we hold based on the following legal basis:

■ Consent: We may process your data if you have given us specific consent to use your

personal information for a specific purpose. Consent may be withdrawn at any time.

■ Legitimate Interests: We may process your data when it is reasonably necessary to

achieve our legitimate business interests.

■ Performance of a Contract: Where we have entered into a contract with you, we may

process your personal information to fulfil the terms and conditions of our contract.

■ Legal Obligations: We may disclose your information where we are legally required to

do so in order to comply with applicable law, governmental requests, a judicial

proceeding, court order, or legal process, such as in response to a court order or a

subpoena (including in response to public authorities to meet national security or law

enforcement requirements).

■ Vital Interests: We may disclose your information where we believe it is necessary to

investigate, prevent, or take action regarding potential violations of our policies,

suspected fraud, situations involving potential threats to the safety of any person and

illegal activities, or as evidence in litigation in which we are involved.

More specifically, we may need to process your data or share your personal information in the

following situations:

■ Business Transfers. We may share or transfer your information in connection with, or

during negotiations of, any merger, sale of company assets, financing, or acquisition of

all or a portion of our business to another company.

■ Partners, Consultants and Other Third-Party Service Providers. We may share your

data with our partners, third-party service providers, contractors or agents who perform

services for us or on our behalf and require access to such information to do that work.

Examples include: payment processing, data analysis, email delivery, hosting services,

customer service and marketing efforts. Unless described in this policy, we do not share,

sell, rent or trade any of your information with third parties for their promotional purposes.

We have contracts in place with our data processors, which are designed to help

safeguard your personal information. This means that they cannot do anything with your

personal information unless we have instructed them to do it. They will also not share

your personal information with any organization apart from us. They also commit to

protect the data they hold on our behalf and to retain it for the period we instruct.

■ Partners. We may share your information with our partners so that you may be awarded

and redeem loyalty points, exchange them for discounts or points with monetary value

associated with them, to offer you certain loyalty program discounts, promote partners

special products or services.

4. DO WE USE COOKIES AND OTHER TRACKING

TECHNOLOGIES?

In Short: We may use cookies and other tracking technologies to collect and store your

information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to access

or store information. Specific information about how we use such technologies and how you can

refuse certain cookies is set out in our Cookie Policy.

5. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfil the purposes outlined in

this privacy policy unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set

out in this privacy policy, unless a longer retention period is required or permitted by law (such

as tax, accounting or other legal requirements). No purpose in this policy will require us keeping

your personal information for longer than 14 days past the deactivation of your App account.

Past aforementioned 14 days, we will, whenever possible, delete your personal information and

you will no longer be able to access such information.

When we have no ongoing legitimate business need to process your personal information, we

will either delete or anonymize such information, or, if this is not possible (for example, because

your personal information has been stored in backup archives), then we will securely store your

personal information and isolate it from any further processing until deletion is possible.

6. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim to protect your personal information through a system of organizational and

technical security measures.

To keep your information safe we have implemented appropriate technical and organizational

security measures designed to protect the security of any personal information we process.

However, despite our safeguards and efforts to secure your information, no electronic

transmission over the Internet or information storage technology can be guaranteed to be 100%

secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized

third parties will not be able to defeat our security, and improperly collect, access, steal, or modify

your information. Although we will do our best to protect your personal information, transmission

of personal information to and from our Services is at your own risk. You should only access the

Services within a secure environment.

7. DO WE COLLECT INFORMATION FROM MINORS?

In Short: We do not knowingly collect data from or market to children under 18 years of age.

We do not knowingly solicit data from or market to children under 18 years of age. By using the

Services, you represent that you are at least 18 or that you are the parent or guardian of such a

minor and consent to such minor dependent’s use of the Services. If we learn that personal

information from users less than 18 years of age has been collected, we will deactivate the

account and take reasonable measures to promptly delete such data from our records. If you

become aware of any data we may have collected from children under age 18, please contact

us at support@libraincentix.com

8. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: You may see, access, rectify your information, deactivate your account, control your

location information or change your marketing preferences.

■ Personal Information. We may see, access and rectify any information relating to you that

we collect and process by logging into your personal profile page.

■ Deactivating Your Account. You may at any time deactivate your account within the App

simply by selecting your profile icon any choosing deactivate.

■ Location information. In order to provide certain Services, we may request access to

location information, including precise geolocation information collected from your device. If

you do not consent to the collection of this information, certain Services will not function

properly and you will not be able to use those Services. You can stop our collection of

location information at any time by changing the preferences on your device. If you do so,

some Services will no longer function.

■ Marketing promotions. You may at any time opt out of receiving marketing promotions

simply by accessing your personal profile page and change marketing settings.

If you have questions or comments about your privacy rights, you may email us at

support@libraincentix.com.

Account Information

If you would at any time like to review or change the information in your account or terminate

your account, you can:

■ Log in to your profile page and update your user account.

■ Contact us using the contact information provided.

Upon your request to terminate your account, we will deactivate or delete your account and

information from our active databases. However, we may retain some information in our files to

prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms of Use

and/or comply with applicable legal requirements.

ADDITIONAL COUNTRY DISCLOSURES

If you are a EU citizen you have all the rights in accordance with General Data Protection

Regulation.

You have the following rights granted by General Data Protection Regulation:

§ To access your personal data and request a copy of your personal data

§ To rectify inaccurate personal data

§ To obtain the erasure of your personal data once we have no legal basis for collection

and process

§ In cases set forth by the applicable law to apply for the restriction of the processing,

collecting and use of personal data

§ To lodge a complaint with supervisory authority.

If we are relying on your consent to process your personal information, you have the right to

withdraw your consent at any time. Please note, however, that this will not affect the lawfulness

of the processing before its withdrawal, nor will it affect the processing of your personal

information conducted in reliance on lawful processing grounds other than consent.

9. INTERNATIONAL DATA TRANSFERS

We operate in many countries, and we (or our service providers) may move your data and

process it outside the country where you live. We use third-party service providers to process

and store your information in the United States. When we transfer your personal data to our

affiliates outside the EU, we make use of standard contractual clauses (which have been

approved by the European Commission) to help ensure your information is afforded a high

standard of protection, and that your privacy rights can be vindicated. You agree to receive SMS messages from Libra Incentix for one-time password (OTP)
verification during the enrolment process

10. DO WE MAKE UPDATES TO THIS POLICY?

In Short: Yes, we will update this policy as necessary to stay compliant with relevant laws.

We may update this privacy policy from time to time. The updated version will be indicated by

an updated "Revised" date and the updated version will be effective as soon as it is accessible.

If we make material changes to this privacy policy, we may notify you either by prominently

posting a policy of such changes or by directly sending you a notification. We encourage you to

review this privacy policy frequently to be informed of how we are protecting your information.

11. HOW CAN YOU CONTACT US ABOUT THIS POLICY?

If you have questions or comments about this policy, you may email us at

support@libraincentix.com.