# Jambo Privacy Policy

## **PRIVACY POLICY**

HAKUNA MATATA CHILL LIMITED (referred to as “Jambo,” "we," and "our," and "us,") understands and respects your desire to maintain your privacy. It is our priority to maintain your privacy in all your dealings with us whenever you access and use our website located at jambo.technology, the Jambo mobile application (the “App”), the JamboAcademy’s resources and any services offered through the App, and any associated Jambo Web Products (collectively, the “Web Products”). We may in the course of providing our services to you be required to collect your personal information. This Privacy Policy is intended to explain how we and our related entities will collect your personal information and protect your privacy.

BY ACCESSING OR USING THE WEB PRODUCTS, INCLUDING VIA DOWNLOADING AND USING THE APP, OR ANY PORTION THEREOF, YOU ACKNOWLEDGE AND AGREE THAT YOU HAVE READ, UNDERSTAND, AND AGREE TO THE TERMS OF THIS PRIVACY POLICY. If you do not wish to agree to the TERMS OF THIS Privacy Policy, you must not access or use the Web Products.

HAKUNA MATATA CHILL LIMITED is a Hong Kong Limited Company and our services are provided to you by us. This policy was written in English. To the extent a translated version conflicts with the English version, the English version controls.

By agreeing to this Privacy Policy, you consent to the fact that you are aware that we are collecting your personal information and disclosing it as required by us and in accordance with Hong Kong’s Personal Data (Privacy) Ordinance (Cap. 486) (the “Ordinance”) and in compliance with applicable local laws.

Unless indicated otherwise, this Privacy Policy does not apply to third-party products or services or the practices of companies that we do not own or control, including other companies you might interact with on or through our services.

This Privacy Policy governs your access to and use the Web Products, including any content, functionality and services offered on or through the Web Products.

When you access the Web Products, we will learn certain information about you, both automatically and through voluntary actions you may take, during your visit. This Privacy Policy applies to information we collect through the Web. Please read this Privacy Policy carefully before you start to use the Web Products.

### **Information About You**

This Privacy Policy covers your personal information. Personal information is information or an opinion, whether true or not, and whether recorded in a material form or not, about an identified individual, or an individual who is reasonably identifiable whether submitted electronically or otherwise. All personal information received in connection with the Web Products is subject to the Ordinance).

Common examples include your name, username, password, IP address, unique device identifiers, gender, signature, address, telephone number, email, date of birth, photos and videos of you, other identification credentials and biographical details, and commentary or opinions about you. We also collect information about your location for certain features of the Web Products to function properly.

The Web Products may host various places for users to provide information. We may collect information about you when you interact with the Web Products, including should you download the App and complete the forms necessary to create a Jambo Academy account, watch our videos, review and complete our lessons and quizzes, and interact with the JamboAcademy ambassadors. We may use the information you provide to us to respond to your questions, to deliver the requested product and/or service, to improve our overall performance, and to provide you with offers, promotions, and information.

To the extent that you voluntarily provide personal information to us, our systems will associate the automatically collected information with your personal information.

### **Personal information that we may collect from you**

We may collect some or all of the following types of personal information:

* information that you give us through your dealings with us;
* information that we may collect from you; and
* information that we may receive from you from other third-party sources.

Certain of your personal data may be shared with third-parties, including our affiliated JamboAcademy ambassadors, as part of the normal operation of our services. Additionally, we may, from time to time, expand or withdraw our business which may involve the transfer of certain of our divisions or assets to other parties, and the data we store and use, where relevant, may be transferred to such third parties.

### **Disclosure of Your Information**

We may be required to disclose your personal information for the purposes for which it was collected and also subject to our legal obligations:

* as required by law;
* to any person where necessary or desirable in connection with our provision of services; and
* on a confidential basis to our external service providers and advisors.

To be clear, you consent to our disclosure of your personal information to any of our JamboAcademy ambassadors, business partners or the like, advertisers and other advertising networks, analytics and search engine providers and other third parties provided the disclosure of your personal information is for the purpose of or ancillary to the services that we or these third parties offer you and for the purposes the information was originally collected.

We may also share your information with other third-party business partners for their own marketing purposes. These third parties include online advertisers or ad tech companies, who may provide you with targeted advertising and marketing communications, where permitted under law. The information we share includes information collected through your use of our services and information we collect about you through the use of cookies and similar technologies.

You understand that we are authorized to disclose your personal information to third parties if we buy or sell any business or assets, including our business, if we are under a duty to disclose your information, or if the disclosure of your personal information is necessary for us to conduct an investigation into any unlawful activity that we know or suspect has or may be engaged in.

### **Use of Cookies**

Similar to other commercial websites, our Web Products utilize a standard technology called “cookies” and server logs to collect information about how our site is used. Information gathered through cookies and server logs may include the date and time of visits, the pages viewed, time spent at our site, and the Web Products visited just before and just after our own, as well as your IP address.

A cookie is a very small text document, which often includes an anonymous unique identifier. When you visit a website, that site’s computer asks your computer for permission to store this file in a part of your hard drive specifically designated for cookies. Each website can send its own cookie to your browser if your browser’s preferences allow it, but (to protect your privacy) your browser only permits a website to access the cookies it has already sent to you, not the cookies sent to you by other sites.

We will use both persistent cookies, which could remain on your device until their expiration (which can be, in some cases, up to 10 years), and session cookies, which are temporary files removed from your device once your browser is closed.

The types of cookies we may use include analytical and tracking cookies, which allow us to recognize and count the number of visitors and analyze use of the services, as well as to verify transactions, and advertising and re-targeting cookies, which allow us to generate appropriate advertising directed to you on our website as well as on the App.

If you enabled cookies when accessing our website and/or App and/or other mobile applications, we will take this as consent to our use of cookies and other technologies mentioned in our Privacy Policy.

Please note that you should also refer to our website's Terms of Use for further information on this issue.

### **Electronic Communications Information**

If you choose to correspond with us through email, SMS or digital messenger (“Electronic Communications”), we may retain the content of your messages together with your email address, phone number or username and our responses. We provide the same protections for these Electronic Communications that we employ in the maintenance of information received online, mail, and telephone. This also applies when you register for our website, sign up through any of our forms using your email address or make a purchase on this site. For further information see the email policies below.

### **Email Policies**

We are committed to keeping your e-mail address confidential. We do not sell, rent, or lease our subscription lists to third parties, and will not disclose your email address to any third parties except as allowed in the section titled Disclosure of Your Information.

### **Why We Collect Information**

We collect your information to record and support your participation in the activities and services you select. If you choose to download the App, create a JamboAcademy account, and utilize any of our educational resources, we collect your information. We use this information to track your activities and to keep you informed about the products and services you have selected to receive and any related products and/or services.

### **How Do We Use the Information That You Provide to Us?**

We use personal information for purposes of presenting our Web Products to you, providing you with information, providing you with offers for products and services, administering our business activities, providing customer service, and making available other items and services to our customers and prospective customers. From time-to-time, we may use the information you provide to us to display advertisements to you that are tailored to your personal characteristics, interests, and activities, or the products you previously accessed.

### **How do we Protect Your Information and Secure Information Transmissions?**

We maintain commercially reasonable technical, administrative, and physical security measures designed to protect your information from loss, misuse, unauthorized access, disclosure, alteration, and destruction.

We cannot, however, guarantee that transmissions of your information will always be secure or that unauthorized third parties will never be able to defeat the security measures taken by us or our third-party service providers. Except to the extent that liability cannot be excluded or limited due to applicable law, we assume no liability or responsibility for disclosure of your information due to errors in transmission, unauthorized third-party access, or other causes beyond our control.

We will only keep your information for as long as reasonably necessary to fulfill the purposes for which your personal information was originally collected. We will delete your information after a reasonable time. You may be required to re-enter your personal information if it has been deleted.

You agree and acknowledge that your personal information may be stored at or transferred within Hong Kong or to a location outside of Hong Kong, the location of which may have different data protection laws to the Ordinance. This will allow staff operating outside of Hong Kong (whether employed by us or by a third party engaged by us or otherwise authorized under this Privacy Policy to access your personal information) to process your information for the purposes of providing you with our services.

In addition, we will utilize overseas IT services (including third-party AWS services, software, platforms and infrastructure), such as data storage facilities or other IT infrastructure. In such cases, we may have entered into contractual arrangements with third-party service providers to assist us with providing our services to you. Since we will utilize cross border IT services and platforms which can be accessed from various countries via an internet connection, it is not always practicable to know where your information may be held.

We will take all reasonable steps and precautions to ensure that any transmission of your personal information via the internet is secure. However, we cannot guarantee the security of any data transmitted to our Web Products and you agree and acknowledge that any such transmissions are at your own risk.

All our employees and affiliates with access to your information will be held to the confidentiality obligations as set out in this Privacy Policy.

### **Policy Changes**

It is our policy to post any changes we make to our privacy policy on this page. The date the privacy policy was last revised is identified at the bottom of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and this Privacy Policy to check for any changes.

### **Your Privacy Rights**

In accordance with the terms of the Ordinance and subject to exemptions specified in the Ordinance, you:

* have the right to check whether we hold personal data about you and have a right to receive copies of such data;
* have the right to require us to correct any personal data relating to you which is inaccurate;
* have the right to ascertain our policies and practices in relation to personal data and to be informed of the kind of personal data held by our company.

In accordance with the terms of the Ordinance, we have the right to charge a reasonable fee for processing a data access request.

If you have any questions in relation to our Privacy Policy, we welcome your questions or comments, please, feel free to contact us at: info@jambowallet.com

### **Complaints**

We take all complaints very seriously. It is our policy to handle complaints in a timely, effective, fair and consistent manner. If you are concerned about a possible interference with your privacy or about the potential misuse of your personal information, please contact us at info@jambowallet.com

### **Privacy Policy updates**

This Privacy Policy was last updated in October 2022.

We reserve the right to make changes to this Privacy Policy at any time. We encourage you to regularly review this Privacy Policy to make sure you are aware of any changes and how your information may be used.
