HAVVA Privacy Policy

This is the Privacy Policy of HAVVA AGROTECH SDN BHD, a Malaysia incorporated company, its respective subsidiaries, affiliates, associated companies and jointly controlled entities (collectively “HAVVA”, “our”, “us” or “we”).

HAVVA respect the confidentiality of Personal Data and privacy of individuals and is committed to complying with the Personal Data Protection Act 2010 and other applicable data protection laws, where applicable. Please read this Privacy Policy so that you know and understand how we collect, use, process, protect and disclose the information you give us through the use of HAVVA’s websites and/or mobile applications (respectively “Websites” and “Apps”), as well as any products, features, forums and other services operated and/or offered by HAVVA (collectively, “Services”).

By providing your Personal Data to us and/or continuing access to our Websites, Apps or Services, you declare that you have read and understood this Privacy Policy and agree and consent to us processing your Personal Data in accordance with the manner set out in this Privacy Policy.

If you do not agree to this Privacy Policy or any amendments to this Privacy Policy, we may not be able to render all services to you and you may be required to terminate your relevant agreement with us and/or stop accessing or using our Websites, Apps or Services.

HOW HAVVA COLLECTS YOUR PERSONAL DATA

You hereby consent HAVVA to collect your personal information from the following:

(a) Information You Provide

HAVVA collects personal information you provide us, which may include: (i) contact information, such as your name, postal address, e-mail address, and phone number; (ii) additional information about you to help us get to know you better, such as your gender, age, date of birth, nationality, information about how you use our products, and demographic information; (iii) comments, questions, requests and purchases you may make; (iv) financial and/or account information needed to process payments (v) log-in information, and (vi) information about your preferences.

(b) Information Automatically Gathered from Your Device
Device and browser information. HAVVA may collect technical information about your device, such as device

type and model, browser type, an online identifier, such as a unique ID, or your Internet Protocol (or ‘IP’) address, operating system and version and platform, and device identifier. HAVVA collects this information automatically from your device and web browser through cookies and similar technologies.

Information about how you interact with us. HAVVA may collect technical data about your usage of our Websites, Apps or Services, including any purchases made, and how you interact with our digital advertisements and promotions, such as content viewed or downloaded, features used, links clicked, HAVVA promotional emails opened, and dates and times of interactions, number of times you visit or use any of our Websites, Apps or Services and the amount of time you spend using our Websites, Apps or Services. HAVVA collects this information using cookies and similar technologies.

Location information. HAVVA may collect location information, including precise real-time location information from your device and imprecise location information derived from, for example, your IP address or postal code. Our Websites, Apps or Services will NOT access precise-real time location information from your device unless you grant permission to do so.

Anonymous Information. HAVVA will also collect anonymised details about visitors to and use of our Websites, Apps or Services for the purposes of creating aggregate statistics or reporting purposes. However, no single individual will be identifiable from the anonymised details we collect for these purposes. We may share this aggregated information about our user base with our partners and advertisers.

(c) Cookies and Similar Technologies

A “cookie” is a file of information placed on your device when you visit a website. Cookies and similar technologies can enhance your user experience by saving your preferences, personalizing your online experience, and sometimes providing you with advertising which is tailored to your interests.

We want to make sure that our advertising and marketing is relevant and interesting to you and our other users. To achieve this, we use third-party advertising and technology companies to serve ads and/or provide

aggregated data to assist in serving ads when you visit or use our Websites, Apps or Services. This includes third party technology companies which collect data about you in order to build a profile of your preferences based on your activities when you visit or use our Websites, Apps or Services. We also use these companies to automatically collect data from you when you use our Websites, Apps or Services in order to help us identify the ads that are served to you and what you do after seeing those ads. In addition, we share data with providers of web analytics tools, such as Google Analytics, which we use to analyse your use of our Websites, Apps or Services. More information about how Google Analytics is used by HAVVA can be found here: https://www.google.com/analytics/terms/us.html

These third party advertising companies collect, store and use data by integrating cookies and other tracking software on our Websites, Apps or Services. The relevant data collected by these third parties includes a unique device ID, geo-location details and your assigned ID. Data which you provide to HAVVA when using our Websites, Apps or Services may also be captured by these third parties.

In some cases, these third parties will also use the data that they collect for their own purposes, for example they may aggregate your data with other data they hold and use this to inform advertising related services provided to other clients.

Please see our Cookies Policy for more information on the third party advertising companies which collect, use and store data about you, the use of cookies and other tracking technologies on our Websites, Apps or Services and how you can amend your cookies setting in your browser settings.

(d) Information from Business Partners and other Third Parties

HAVVA collects personal information through our Business Partners. This information may include contact information, such as name, address, e-mail address, and phone number.

HAVVA may also obtain personal information from other third-party sources, including publicly and commercially available sources. We may combine the information we receive from our Business Partners and other third-party sources with information that we collect from you or your device, as described above.

You have choices about the personal information you provide HAVVA. You may choose not to provide information that we request, but if you do so, we may not be able to provide you a relevant service or a

particular feature for our Websites, Apps or Services.

HOW HAVVA USES YOUR PERSONAL DATA

You hereby consent HAVVA to use your personal information to:

  • to develop, improve and manage our relationships with you and our Business Partners;
  • to build your own personal profile on our Websites, Apps or Services;
  • to provide you with a consistent and personalised service across different devices and platforms and parts of our Websites, Apps or Services, for example, we may keep track of your preferences (such as your language selection, preferred settings etc.) and past activities on our Websites, Apps or Services so that we may provide you with the correct versions of our Websites, Apps or Services;
  • to restrict users from attempting to use our Websites, Apps or Services from a restricted territory or who are under-age (without the consent of the parent and/or guardian) and attempting to access inappropriate content in breach of our Terms of Service;
  • to ensure that you are complying with our Terms of Service when you use our Websites, Apps or Services and taking any necessary action if you are not complying with our Terms of Service;
  • to moderate any chat messages in chat forums, in order to restrict access to harmful, infringing or illegal content;
  • to process any refunds requested by you subject to our Terms of Service; and
  • to provide you with our customer services support subject to our Terms of Service.
  • to detect and prevent fraud, hacking and/or other cyber-attacks (for example, we use automated decision making in relation to your IP address to ensure that you are not a bot and/or carrying out a malicious attack);
  • to keep our Websites, Apps or Services secure;
  • to customise our Websites, Apps or Services which are available to you;
  • to improve our Websites, Apps or Services, for analysis and reporting purposes (this also includes using data to log any crashes in our provision of our Websites, Apps or Services, so we may report such interruptions (and to do this, we may use a third party to assist us);
  • to understand your preferences and personalise your experience of our Websites, Apps or Services;
  • to send you push notifications with service-related information for certain services or in relation to events selected by you within your account settings (which you can choose not to accept or turn off by visiting your account settings or the settings section of your device and selecting the appropriate setting);
  • to help us manage advertising and provide you with advertising and/or other services that is relevant to you or that we believe may be of interest to you (and to do this, we may use a third party to assist us);
  • to record your preferences in relation to advertising and marketing communications in your account setting. You may change the settings available in the account section available on our Websites, App and Services. In the event, you click “Unsubscribe” in any communication, which means you will no longer receive these marketing messages. Additionally, the withdrawal of your consent may however result in certain consequences. For example, in certain cases, we may not be able to provide you with certain services.
  • to develop new HAVVA Websites, App and Services including for research and product development purposes.
  • to address legal issues which may include (i) to comply with our obligations to retain certain business records for minimum retention periods, (ii) establishing, exercising or defending legal claims, (iii) complying with laws, regulations, court orders, or other legal process, (iv) detecting, preventing, and responding to fraud, intellectual property infringement, violation of our contracts or agreements, violations of law, or other misuse of HAVVA Websites, Apps, or Services; and (v) protecting HAVV’s rights or property, or yours or others’ safety, welfare, rights, or property.

The above uses of your personal information are necessary in order for us to provide our Websites, Apps or Services, and for you and other users to be able to use them, in accordance to our Terms of Service.

WHEN HAVVA MAY SHARE OR DISCLOSE YOUR PERSONAL DATA

You hereby consent HAVVA to share or disclose your personal information with various third parties (including our affiliate companies in other countries) as follows:

  • We use third parties to help us manage your information and our Websites, Apps or Services, such as our IT service providers, cloud service providers and customer service software and support ticketing providers. These are companies who are authorised to process data on our behalf only as necessary to provide the relevant services to us and cannot use it for their own independent purposes;
  • We share your data with our third party payment providers where you have asked us to complete any purchases using our Websites, Apps or Services. These third-party payment providers may also ask us to share your data with them to confirm the nature of any payment transaction and to verify your identity and payment details;
  • We share your personal information with companies that assist us with our marketing activities where you have opted-in for such communications. If you wish to stop receiving marketing communications, you can choose to opt-out of receiving messages from us or our Websites, Apps or Services by following the directions on the bottom of the email message you receive or by opting-out via your account settings;
  • If you create a profile for certain services which may be visible to other users. Your personal information will be shared to other users who can choose to add you as a friend. You can change your settings through the ‘edit profile’ function in our Websites, Apps or Services at any time;
  • We or our third-party partners may disclose your personal data where we are required or permitted to do so by law or to protect or enforce our rights or the rights of any third party. We may also share your data with third parties to prevent fraud, abusive or unlawful behaviour or to demonstrate our compliance with other terms or laws;
  • where it is in our legitimate interests to do so to run, grow and develop our Websites, Apps or Services, such as:

o if we sell or buy any of our Websites, Apps or Services or assets, we may disclose your personal information to the prospective seller or buyer of such business or assets;

o if substantially all of our or any of our affiliate’s assets are acquired by a third party, in which

case personal information held by us will be one of the transferred assets;
o if we are under a duty to disclose or share your personal information in order to comply with any legal obligation, any lawful request from government or law enforcement officials and as may be required to meet national security or law enforcement requirements or prevent illegal activity;

  • in order to enforce or apply our Terms of Service or any other agreement or terms of use, to respond to any claims, to protect our rights or the rights of a third party, to protect the safety of any person or to prevent any illegal activity;
  • to protect the rights, property or safety of HAVVA, our staff, our customers or other persons. This may include exchanging personal information with other organisations for the purposes of fraud protection;
  • We may also disclose and use anonymised, aggregated reporting and statistics about users of our website or our goods and services for the purpose of internal reporting or reporting to our group or other third parties, and for our marketing and promotion purposes. None of these anonymised, aggregated reports or statistics will enable our users to be personally identified.

Save as expressly detailed above, we will never share, sell or rent any of your personal information to any third party without notifying you and, where necessary, obtaining your consent. If you have given your consent for us to use your personal information in a particular way, but later change your mind, you should contact us and we will stop doing so.

Any third parties with whom we share your personal information are limited (by law and by contract) in their ability to use your personal information for any purpose other than to provide services for us. We will always take reasonable steps to ensure that any third parties with whom we share your personal information are subject to privacy and security obligations consistent with this Privacy Policy and applicable laws.

RETENTION OF YOUR PERSONAL DATA

We keep your personal information for no longer than necessary for the purposes for which the personal information is processed. The length of time for which we retain personal information depends on the purposes for which we collect and use it and/or as required to comply with the applicable laws and to establish, exercise or defend our legal rights. If it is no longer required for the purpose for which it was to be processed,

we will take all reasonable steps to destroyed or permanently delete the information.

ACCESS TO YOUR PERSONAL DATA

You may review, correct and update your personal information held by us and be able to correct that personal information where the personal information is inaccurate, incomplete, misleading or not up-to-date, except where compliance with a request to such access or correction is refused under the applicable laws.

We will process your request not later than twenty-one (21) days from the date of receipt of your request. Please take note that (i) we require proof of identity before responding to your requests and (ii) certain personal information may be exempt from such requests in certain circumstances, for example if we need to

keep using the information to comply with our own legal obligations or to establish, exercise or defend legal claims. If an exception applies, we will inform you the refusal and the reasons for the refusal when we respond to your request.

CHILDREN

Most of our Websites, Apps or Services are not intended for children under 13 years of age. We do not collect information relating to the age of individuals using our Websites, Apps or Services and, therefore, we recommend parents and guardians of children using our Websites, Apps or Services regularly clear their browser cache and/or browsing history to clear cookies. Please see our Cookies Policy for more information. We will not knowingly solicit or collect personal information from or about children under 13, or the relevant minimum age under applicable local legal requirements, except as permitted under applicable law.

For some of our Websites, Apps or Services it may be possible for those under the age of 13 to register an account and access to our Websites, Apps or Services and other content (with parental or guardian consent). Where children under 13 sign up and use certain aspects of our Websites, Apps or Services, we rely on the checks carried about by our third party suppliers associated with those aspects of our Websites, Apps or

Services, to ensure appropriate parent/guardian consent has been obtained.

RISK AND SECURITIES OF YOUR PERSONAL DATA

(a) Risk Identification

The main risk of processing your personal information is if it is lost, stolen or misused. This could lead to your personal information being in the hands of someone else who may use it fraudulently or make public, information that you would prefer to keep private.

(b) Risk Mitigation

For this reason, HAVVA is committed to protect your personal information from loss, theft, unauthorised disclosure, misuse or alteration. We take all reasonable precautions to safeguard the confidentiality of your personal information, including through use of appropriate organisational and technical measures. We secure your personal information, and use a secure service to prevent unauthorized access to the information. Your personal information is protected by encryption and secured through access control lists, security keys / tokens, IP whitelisting and by the use of username / password access. HAVVA also carries out access audits of its staff in order to detect any unauthorized access.

(c) Transmission Security

In the course of provision of your personal information to us, your personal information may be transferred over the electronic networks linked to the internet. Although we make every effort to protect your personal information, the transmission of information over the internet is not completely secure. As such, you acknowledge and accept that we cannot guarantee the security of your personal information provided transmitted over the internet to our Website, Apps or Services and that any such transmission is at your own risk and we shall not be responsible for breaches of security beyond our reasonable control.

(d) Your Responsibility

Where we have given you (or where you have chosen) a password which enables you to access your online account, you are responsible for keeping this password confidential. We require that you do not share your

passwords with anyone else.

Do note that you should bear the sole responsibility in taking care of your mobile and/or any other electronic devices and preparing the necessary backups for App, Wallet Password, Mnemonic Words, Private Key and Keystore. If you have misplaced your mobile device and/or any other electronic; deleted your App or your Wallet without a backup; forgotten your Wallet Password, Private Key, Mnemonic Words or Keystore; or having your Wallet stolen; we will not in any way be able to recover your Wallet or your Wallet Password, Private Key, Mnemonic Words or Keystore.

You are also advised to perform a thorough checking before proceeding with a transaction. We may not be able to cancel any transactions performed due to the mishandling of users (such as typing in wrong addresses for transactions OR wrong amount to be exchanged) and we shall not be held responsible in any way in respect of the same.

LINKS TO THIRD PARTY INTERNET SITES AND PLUGINS

Our Websites, Apps or Services may links or contains hyperlinks to websites or mobile apps that are not operated by us and plugins from social media platforms and other third parties. These hyperlinks are provided for your reference and convenience only and do not imply any endorsement of the activities of such third- party websites or any association with their operators. This Privacy Policy only applies to the personal information that we collect or which we receive from third party sources, and we cannot be responsible for personal information about you that is collected and stored by the third parties. To learn about the information collected by these third-party websites, apps, and plugins, please visit their privacy policies. We encourage you to review the privacy policies for the websites, apps, and social media platforms you visit before using them or providing personal information. We do not endorse or otherwise accept any responsibility or liability for the content of such third party websites or third party terms and conditions or policies.

WITHDRAWAL OF CONSENT TO USE, COLLECT, SHARE AND/OR DISCLOSE PERSONAL DATA

If you would like to exercise your right to object, block, or remove your consent please email us at info@havva.my. In this case, however, we may not be able to adequately provide you the services you requested. When you object, block, or remove your consent, HAVVA shall no longer process your personal data, except in circumstances allowed or required by the applicable law.

CHANGES TO THIS PRIVACY POLICY

We reserve the right to update, modify, alter or amend our Privacy Policy at any time and without prior notice. Any changes we make to our Privacy Policy in the future will be posted on this site, along with information on any material changes. Any amendments to this Privacy Policy will be effective after the posting. Please check back frequently to see any updates or amendments to our Privacy Policy. By continuing to use the services and/or access to our Websites, Apps or Services after acceptance of posting of any amendments to this Privacy Policy, you will be treated as having agreed to and accepted those amendments.

This Privacy Policy was last revised in March, 2021.