Altum Group Personal Data Protection and Privacy Policy

Altum International Pty Limited and its subsidiaries (including Altum Asia Limited) (the "Altum Group") are an Asia-Pacific-based group focused on providing the life-changing benefits of cannabinoids to consumers in the region. The Altum Group is also committed to protecting the privacy of all individuals and ensuring that personal data is property collected and stored. This Personal Data Protection and Privacy Policy (the "Policy") sets out how the Altum Group (the antecedent of the pronouns "we," "us," or "our" in this Policy) collect, use, and disclose your personal information.

1. Our Commitment

This Policy applies to all products and services provided by us to our customers and business partners, including but not limited to products or services offered through our apps or any other program or software creating any rewards or loyalty program. We are committed to protecting your personal data and your privacy and pledge to comply with the requirements of the Personal Data (Privacy) Ordinance (Cap. 486) (the "Ordinance") in Hong Kong and any other applicable legislation in respect of that information. In order to do that, we will protect and handle your personal information in accordance with the terms and conditions set out in this Policy.

2. Collection of Personal Data

2.1 Your privacy is important to us and we will not collect excessive personal information from you.

2.2 When you provide personal data to us, we may ask you to provide certain personal information, including without limitation your name, date of birth, gender, phone number, email address, contact/delivery address, membership number and credits, and your payment information (collectively, "Customer Data"). Please note that it is necessary for you to provide certain fields of Customer Data to us, as specified at the time of collection, in order for us to provide you with our products and services.

2.3 In addition to Customer Data, we may also collect from you information concerning the products or services you purchase, including your preferences and your interaction with our Web site or store locations (collectively, the "Consumer Data" and, together with your Customer Data, the "Personal Data").

2.4 We will collect most Personal Data from you directly, although we may also collect Personal Data about you from authorized third parties.

3. Use and Transfer of Personal Data

3.1 We may collect and process your Personal Data. Any Personal Data provided to us means you authorise us to collect, retain, and use Personal Data for the following purposes: (a) operating or managing your account; (b) verifying your identity; (c) providing you with rewards, promotions, vouchers, or services under our services; (d) updating you on our latest products or services; (e) providing you with customer services and responding to your queries; (f) performing statistics and analysis in order to develop or improve our services; (g) for marketing and promotional purposes; (h) for making such disclosures as may be required for any of the above purposes or as required by law; (i) in respect of any feedback or claims made by you; and (j) for administrative purposes.

3.2 You further agree that we may disclose and transfer (in Hong Kong or overseas) your Personal Data to third-party service providers ("Service Providers") engaged by us to provide (a) data entry and analysis, (b) customer database management, (c) customer contact, (d) secure data disposal services, and (e) data storage. The Service Providers are under a duty of confidentiality to us and are permitted to use your Personal Data only in connection with the purposes specified above and not for their own purposes (including direct marketing).

3.3 When necessary we may also disclose and transfer (in Hong Kong or overseas) your Personal Data to our professional advisers, law enforcement agencies, insurers, government and regulatory and other organisations (collectively, the "Other Interested Parties") for the purposes specified above.

3.4 We may share unidentified aggregate data with third parties for various purposes (including marketing and advertising), and may use this data in order to better understand your needs and to improve our products and services.

3.5 Any Personal Data supplied by you will be retained by us and will be accessible by our employees, the Service Providers and Other Interested Parties, for or in relation to any of the purposes specified above.

3.6 We will retain your Personal Data for as long as necessary for the purpose for which it was collected or for any other permitted purpose. Personal Data which is no longer needed will be irreversibly anonymised or destroyed.

4. Safety of Personal Data

All reasonable efforts are made to ensure that any Personal Data held by us is stored in a secure and safe place, and accessed only by our authorised employees, authorised Service Providers, or Other Interested Parties. Notwithstanding the foregoing, no system is completely secure and no information provided over apps or the internet can be guaranteed to be completely secured. Thus, we cannot guarantee the security of any information that you transmit to us or receive from us by any relevant apps or the Internet.

5. Use by Third Parties

In operating our business, we may link to other apps, Web sites, or Web pages that are operated by third parties. We have no control over the content of the linked apps, Web sites and/or Web pages or the way in which the operators of those apps, Web sites, or Web pages deal with your Personal Data. You should review the Personal Data Protection and Privacy Policy for those third-party apps, Web sites, or Web pages to understand the ways in which your Personal Data may be used by those third parties.

6. Access or Amend Personal Data

6.1 Under the Ordinance, you have the right of access to Personal Data held by us about you and to request correction of your Personal Data.

6.2 If you have any questions regarding this Personal Data Protection and Privacy Policy or if you wish to access or correct your Personal Data, you may send your request in writing to the following address: G/F., 54 Sai Street, Sheung Wan, Hong Kong.

6.3 In accordance with the Ordinance, we reserve the right to charge you a reasonable fee for the processing of any Personal Data access or correction request.

7. Updates

We may amend or update this Policy from time to time without prior notice and your Personal Data collected shall be governed by our latest Personal Data Protection and Privacy Policy, which shall be available on our website.

8. Versions

In case of discrepancies between the English and Chinese versions in respect of all or any part of this policy, the English version shall prevail.