Last updated: 11 Nov 2020

This Privacy Policy and its Addendum(s) ("Policy") describe how Iconix Co-Living Sdn Bhd (Company No.: 1439156A) its respective subsidiaries, affiliates, associated companies and jointly controlled entities (collectively "Iconix", "we", "us" or "our") collect, use, process and disclose your Personal Data through the use of Iconix's mobile applications and websites (respectively "Apps" and "Websites"), as well as products, features and other services globally, operated by Iconix (collectively, "Services"). Authorised Users and individual users will each be referred to as a "User" and collectively as "Users". We are committed to protecting personal data and strives to provide a safe and secure user experience.

This Policy applies to our Authorized Users which includes but not limited to customers, landlords, owners, tenants, agents, vendors, suppliers, users, partners (such as collaborating operators, sales, operations, management companies and merchant partners), contractors and service providers.

This Privacy Policy is formulated in accordance with the Malaysia Personal Data Protection Act 2010 (Act 709) ("Act") and describes how the users personal data are collected and used.

"Personal Data" is any information which can be used to identify you or from which you are identifiable. This includes but is not limited to your name, nationality, telephone number, bank and credit card details, personal interests, business or personal email address, your image, government-issued identification numbers, biometric data, race, date of birth, marital status, religion, health information, vehicle and insurance information, employment information, financial information or other identifying information about the User as reasonably requested by us.

Each User unconditionally, irrevocably and unequivocally acknowledges, covenants, consents and agrees that we may access, preserve and disclose any of the personal data that each User makes available to us when accessing or using or registering as a User on the Website or Apps, if required to do so by law or in a good faith belief that such access, preservation or disclosure is reasonably necessary to (a) respond to claims asserted against us; (b) to comply with legal process; (c) for fraud prevention, risk assessment, investigation, customer support, product development, maintenance and de-bugging purposes, (d) to protect the rights, property or personal safety of us, our users, or members of the public and for all other general purposes stipulated under paragraph 2(a) below. Each User undertakes, agrees, warrants and covenants that the User will not hold us liable or seek any legal or equitable remedy from us for any damages, expenses, costs or losses of whatsoever nature suffered or incurred by the User, or any third-party as a direct or indirect result of any of access, preservation or disclosure of the User's or any third-party personal data.

1. COLLECTION OF PERSONAL DATA

We collect Personal Data about you in the ways listed below. We may also combine the collected Personal Data with other Personal Data in our possession. If you have or are a party to multiple relationships with us (for example if you use our Services across our various business verticals, or if you are both a Tenant as well as an Owner on our property management vertical or a Sales agent/partner or Customer or Operator/Management Company on our other business verticals), we will link your Personal Data collected across your various capacities to facilitate your use of our Services and for the Purposes described below.

You provide your Personal Data to us

We collect your Personal Data when you voluntarily provide it to us. For example, you may provide your Personal Data to us when you:

• complete a user profile or registration forms (such as your name, contact information and other identification information where needed);
• provide information to assess your eligibility to provide services as a Merchant, Sales, Marketing, Operation partner or Technical partner (such as your identification license information, company information and background check results (as legally permissible));
• interact with our social media pages (such as your social media account ID, profile photo and any other publicly available data);
• participate in contests, photo taking initiatives, or events organized by us (such as the pictures, audio files, or videos you may submit or provide, which may include images of yourself);
• verify your identity through various means (such as social media logins, submission of selfie images or independently verified payment card information);
• fill up demographic information in surveys (such as your age, gender, and other information you may volunteer such as your marital status, occupation and income information); and
• agree to surveys and testimonials with audio and/or video recording features

In certain circumstances, you may need to provide your Personal Data in order to comply with legal requirements or contractual obligations, or where it is necessary to conclude a contract. Failure to provide such Personal Data, under such circumstance, may constitute failure to comply with legal requirements or contractual obligations, or inability to conclude a contract with you, as the case may be.

When our services are used

Personal Data may be collected through the normal operation of our Apps, Websites and Services. Some examples are:

• feedback, ratings and compliments;
• transaction information (such as payment method and behavior);
• information about how you interacted with our Apps, Website or Services (such as features used, content viewed, abnormal login/user variations);
• device information (such as hardware model and serial number, IP address, file names and versions and advertising identifiers or any information that may provide indication of device or app modification);
• your location (to detect locations or abnormal user variations);
• personal data you enter in messages when you use our in-app/website communication features; and
• personal data that may be captured through your interaction with us, our agents, audio and/or video recording during a communication (such as your image or images provided or voice or both, and its related metadata).

From other sources

When we collect Personal Data, including but not limited to your name, contact information and other identification information where needed from other sources, we make sure that that data is transferred to us in accordance with applicable laws. Such sources include:

• referral programs;
• our business partners, such as merchant partners, payment providers, operation partners and sales and marketing partners;
• insurance and financial providers;
• credit bureaus and other credit reporting agencies;
• publicly available sources of data;
• governmental sources of data;
• when our users add you as an emergency contact or a referrer; and
• marketing/sales services providers or partners.

Sensitive Personal Data

Some of the Personal Data that we collect is sensitive in nature. This includes Personal Data pertaining to your race, national ID information, religious beliefs, background information (including financial and criminal records, where legally permissible), health data, disability, marital status and biometric data, as applicable. We collect this information only with your consent and/or in strict compliance with applicable laws.

Iconix's applications or devices

Iconix may install in-app or website audio and/or video recording applications or devices to better enhance better user experience of users, partners and agents. Your Personal Data may be captured in these audio and/or video recordings. Where in-app or website audio and/or video recordings are made, such recordings are collected, processed, used and stored in a manner that is compliant with applicable laws.

Personal Data of minors

As a parent or legal guardian, please do not allow minors under your care to submit Personal Data to Iconix. In the event that such Personal Data of a minor is disclosed to Iconix, you hereby consent to the processing of the minor's Personal Data and accept and agree to be bound by this Policy and take responsibility for his or her actions.

When you provide Personal Data of other individuals to us

In some situations, you may provide Personal Data of other individuals (such as your spouse, family members or friends) to us. For example, you may add them as your emergency contact or referrer. If you provide us with their Personal Data, you represent and warrant that you have obtained their consent for their Personal Data to be collected, used and disclosed as set out in this Policy. To aid in serving the Users better, we may supplement personal data that we have collected directly from the User with other personal data that we obtain offline from the User itself, or through third parties or from our affiliates or other services with the user's or owner's consent.

Safety and security

We use best efforts to implement technical, administrative and physical security measures to protect personal data from unauthorized access and improper use. No method of transmission over the Internet or method of electronic storage is 100% secure or error free, nor is stored data free from vulnerabilities. We cannot guarantee or warrant that personal data will not be intercepted while being transmitted to us over the Internet. We are not responsible for the actions of any third party who hack, intercept, carry out fraudulent or mischievous acts relating to or otherwise obtain unauthorised use of personal data.

2. USE OF PERSONAL DATA

Iconix may use, combine and process your Personal Data for the following purposes ("Purposes"):

Providing services and features

Your Personal Data will be used to provide, personalize, maintain and improve our Apps, Websites and Services. This includes using your Personal Data to:

• provide you with Services across our various business verticals;
• engage you to provide Services;
• to enable you to access or continue to access or use or continue to use our Apps/Website; to operate, protect, improve and optimize this Website or App and our user's experience; to help create and maintain a trusted and safer environment on this Website or App, such as fraud detection and prevention, conducting investigations, risk assessments, verifying the address or any other information provided by the user and conducting checks against databases such as public government databases; to send the User's service, support and administrative messages, confirmations, reminders, technical notices, updates, security alerts and information requested by the User, Owner or partners; to send the user marketing and promotional messages and other information that may be of interest to the User, to administer promotional activities or resolve disputes related to our services.
• create, administer and update your account;
• conduct due diligence checks;
• verify your identity;
• verify your age (where necessary);
• validate your use of our services and process payments;
• offer, obtain, provide, facilitate or maintain insurance or financing solutions;
• enable features that personalize your App, such as lists of your favorite places and previous preferences;
• make your experience more seamless, such as automatically filling in your registration information (such as your name or phone number) from one Service to another Service or when you participate in our surveys, contests or events;
• for communications where we may scan, review and analyze Users communications with each other, with us or with other parties through this Website or Apps for fraud prevention, risk assessment, regulatory compliance, investigation, product development, research and customer support purposes. For example, we may scan, review and analyze communications between the User and others exchanged through this Website or Apps in the event if there is any dispute, disagreement, misunderstanding or miscommunication between the User and others.
• perform internal operations necessary to provide our Services, including troubleshooting software bugs and operational problems, conducting data analysis, testing and research, monitoring and analyzing usage and activity trends;
• protect the security or integrity of the Services and any facilities or equipment used to make the Services available; process and manage your rewards, points;
• enable communications between our users, partners, associated companies and agents;
• process, manage or verify your application such as promotions, rewards and subscriptions to any services with Iconix, its partners, agents and respective subsidiaries, affiliates, associated companies;
• enable our partners to manage and allocate resources; and
• fulfil the services to you as a data processor, where you have provided consent to the data controller (i.e. the organization, company, partner or owner you had purchased goods or services from, and for whom Iconix is providing services on behalf of) for such services to be rendered.

Customer support

We use Personal Data to resolve customer support issues. For example, we may:

• investigate and address concerns;
• monitor and improve our customer support responses;
• respond to questions, comments and feedback; and
• inform you about steps taken to resolve customer support issues.

Research and development and security

We may use the Personal Data we collect for testing, research, analysis and product development. This allows us to understand and analyse your needs and preferences, protect your Personal Data, improve and enhance the safety and security of our Services, develop new features, products and services, and facilitate insurance and finance solutions.

Legal purposes

We may use the Personal Data we collect to investigate and resolve claims or disputes, or as allowed or required by applicable law.

We may also use your Personal Data when we are required, advised, recommended, expected or requested to do so by our legal advisors or any local or foreign legal, regulatory, governmental or other authority.

For example, we may use your Personal Data to:

• comply with court orders or other legal, governmental or regulatory requirements;
• enforce our Terms of Service or other agreements; and
• protect our rights or property in the event of a claim or dispute.

We may also use your Personal Data in connection with mergers, acquisitions, joint ventures, sale of company assets, consolidation, restructuring, financing, business asset transactions, or acquisition of all or part of our business by another company.

Marketing and promotions

We may use your Personal Data to market Iconix and Iconix's partners', sponsors' and advertisers' products, services, events or promotions. For example, we may:

• send you alerts, newsletters, updates, mailers, promotional materials, special privileges, festive greetings; and
• notify, invite and manage your participation in our events or activities.

We may communicate such marketing to you by post, telephone call, short message service, online messaging service, push notification by hand and by email.

If you wish to unsubscribe to the processing of your Personal Data for marketing and promotions, please click on the unsubscribe link in the relevant email or message. Alternatively, you may also update your preferences in our App/Website settings.

3. DISCLOSURE OF PERSONAL DATA

We need to share Personal Data with various parties for the Purposes. These parties include:

Other users

For example:

• If you are a tenant/licensee, we may share your Personal Data and information with our owners, or sales agents and operation partners in fulfilling your requests.
• If you are a sales and marketing partner, we may share your Personal Data with your customers including your name and photo and average rating.
• If you are a delivery and operation partner, we may share your Personal Data with your selected merchant and user, including your name and photo and average rating.
• If you are using our Iconix service, we may share your Personal Data with the parties in charge of fulfilling your service request.
• If you use our in-app chat service, we may share your mobile number and Iconix-registered name with the other parties to your chat.

With Iconix partners at your request

For example, if you requested a service through an Iconix partner or used a promotion provided by an Iconix partner, Iconix may share your Personal Data with that Iconix partners. Our partners include partners that integrate with our App/Website or our App/Website integrates with, services partners, or business partners which Iconix collaborates with to deliver a promotion, competition or other services.

With subsidiaries and affiliates

We share Personal Data with our subsidiaries, associated companies, jointly controlled entities and affiliates.

The Website or App may contain links to other web sites. We are not responsible for the privacy practices of any other web sites. This privacy policy applies solely to personal data collected by this Website or App.

With service providers and business partners

We may provide Personal Data to our vendors, consultants, marketing partners, research firms, and other service providers or business partners. This includes:

• payment processors and facilitators;
• debt collectors;
• credit bureaus and other credit reporting agencies;
• background check and anti-money laundering service providers;
• cloud storage providers;
• marketing partners and marketing platform providers;
• data analytics providers;
• research partners, including those performing surveys or research projects in partnership with Iconix or on Iconix's behalf;
• fleet and merchant partners;
• insurance and financing partners;
• third party intermediaries involved in the managed investment of funds, such as brokers, asset managers, and custodians;
• service providers who perform identity verification services; and
• operation solution partners, operators or third party management companies

With our legal advisors and governmental authorities

We may share your Personal Data with our legal advisors, law enforcement officials, government authorities and other third parties. This may take place to fulfil the legal purposes (mentioned above), or any of the following circumstances:

1. where it is necessary to respond to an emergency that threatens the life, health or safety of a person; or
2. where it is necessary in the public interest (e.g. in a public health crisis, for contact tracing purposes and safeguarding our community).

4. COOKIES AND ADVERTISING ON THIRD PARTY PLATFORMS

We collect personal data through technology to make this Website/App more responsive, relevant and useful. Iconix, and third parties with whom we partner, may use cookies, web beacons, tags, scripts, local shared objects such as HTML5 and Flash (sometimes called "flash cookies"), advertising identifiers (including mobile identifiers such as Apple's IDFA or Google's Advertising ID) and similar technology ("Cookies") in connection with your use of the Websites and Apps. Cookies may have unique identifiers, and reside, among other places, on your computer or mobile device, in emails we send to you, and on our web pages. Cookies may transmit Personal Data about you and your use of the Service, such as your browser type, search preferences, IP address, data relating to advertisements that have been displayed to you or that you have clicked on, and the date and time of your use. Cookies may be persistent or stored only during an individual session. We may allow third parties to use Cookies on the Websites and Apps to collect the same type of Personal Data for the same purposes Iconix does for itself. Third parties may be able to associate the Personal Data they collect with other Personal Data they have about you from other sources. We do not necessarily have access to or control over the Cookies they use.

Additionally, we may share non-personally identifiable Personal Data with third parties, such as location data, advertising identifiers, or a cryptographic hash of a common account identifier (such as an email address), to facilitate the display of targeted advertising on third party platforms.

If you do not wish for your Personal Data to be collected via Cookies on the Websites, you may deactivate cookies by adjusting your internet browser settings to disable, block or deactivate cookies, by deleting your browsing history and clearing the cache from your internet browser.

5. PROTECTION OF PERSONAL DATA

We will take reasonable legal, organisational and technical measures to ensure that your Personal Data is protected. This includes measures to prevent Personal Data from getting lost, or used or accessed in an unauthorised way. We limit access to your Personal Data to our employees on a need to know basis. Those processing your Personal Data will only do so in an authorised manner and are required to treat your information with confidentiality.

Nevertheless, please understand that the transmission of information via the internet is not completely secure. Although we will do our best to protect your Personal Data, we cannot guarantee the security of your Personal Data transmitted through any online means, therefore, any transmission remains at your own risk.

6. AMENDMENTS AND UPDATES

We reserve the right to modify, alter, vary, amend or otherwise update this Privacy Policy at any time or from time to time and the User and the Owner irrevocably, unconditionally and unequivocally agree, covenant and consent to be bound by such modifications, alterations, variations, amendments or updates.

We will notify the User and the Owner of material changes to this Privacy Policy by posting the revised policy with the date it was revised on this page. By continuing to use the Apps, Websites or Services, or continuing to communicate or engage with us following the modifications, updates or amendments to this Policy, you signify your acceptance of such modifications, updates or amendments. The Users continued use (including access, searching, browsing, or use of any interactive feature) of this Website or Apps constitutes the Users agreement to this Privacy Policy and any amendments.

The original of this Policy is written in the English language. In the event of any conflict between the English and other language versions, the English version shall prevail.