KESS INNOVATION Privacy Policy

Thank you for using our products and services! We respect your concerns about privacy and appreciate your trust and confidence in us.

Here is a summary of the information contained in this privacy policy. This summary is to help you navigate the privacy policy and it is not a substitute for reading everything! You can use the hyperlinks below to jump directly to particular sections.

What information do you need to provide KESS INNOVATION?

If you register an account to use KESS INNOVATION then we will need some information from you to set this up (e.g., to set up a profile and validate your phone number). To set up your account, we will need a nickname, your mobile number, and a password. You can further refine and populate your profile with additional information. If you use the services available within KESS INNOVATION, we will process information to allow the services to operate.

How do we use your information?

We use your information to provide KESS INNOVATION to you, allow you to communicate with other users, and to use the features of the KESS INNOVATION Open Platform. We use your information for account setup, to facilitate communications, provide support, allow you to access features of KESS INNOVATION, and to improve KESS INNOVATION. KESS INNOVATION uses contact channels provided by you, such as mobile number or email address, for verifying and protecting your account and for important administrative reasons and does not use these channels for promotional or marketing reasons.

Who do we share your data with?

We do not share your information with any third parties, except where we need to in order to provide the service (e.g., use SMS service providers for account validation for mapping services for other pointofinterest services using our affiliates around the world to help us to deliver KESS INNOVATION) or if we are instructed to by a court, authority or compelled by law. We use these third party services solely to process or store your information for the purposes described in this policy. Any third party (selected by us) with whom we share user data is required to provide the same or equal protection of user data as stated in this policy.

Where do we process your data?

Our servers are located in Phnom Penh, Cambodia and Singapore. We also have support, engineering and other teams that support the provision of KESS INNOVATION to you, located around the world. Your data may be accessed from such locations. Rigorous internal control measures are undertaken to strictly limit access to your data by designated team members.

How long do we keep hold of your data?

The time we retain your information for depends on the type of information for example, login data is retained for up to 90 days from the date the data is collected. If you instruct us to delete your KESS INNOVATION account, your information is deleted within 60 days of the latter of verification of account ownership and receiving your account deletion request.

How can I exercise my rights over my data?

Depending on where you live, you may have special rights over your data and how we can use it. These include how you can access the data, erasing the data, restricting how your data can be used, objecting to its use, and getting a copy of your information.

How will we notify you of changes?

If there are any significant changes to this Privacy Policy, we will update the policy here and notify you before the change becomes effective.

Contact Information for Dispute Resolution

If you have any concerns or complaints, please contact us here.

Data Controllers:

Email: support@kesspay.io

Address: Floor 4, S&C Office Space Building, Street 1984A, Sen Sok, Phnom Penh, Kampuchia (Cambodia) 4, S&C Office Space Building, Street 1984A, Sen S)

KESS INNOVATIONPrivacy Policy

INTRODUCTION

Welcome to KESS INNOVATION!

The use of our services (being the KESS INNOVATION mobile app, the website www.kessinnovation.io or any third party platforms through which KESS INNOVATIONis provided) (together, KESS INNOVATION) involve the processing of your Information.

This privacy policy explains the when, how, and why when it comes to processing of your Information in connection with KESS INNOVATION, and sets out your choices and rights in relation to that Information. Please read it carefully it is important for you to understand how we collect and use your Information, and how you can control it.

By using KESS INNOVATION you agree to the processing of your Information in accordance with this Privacy Policy.

When you use certain features you will be asked to agree to the processing of your Information in certain ways (for example, when you follow an Official Account, you are asked if you agree to the transfer of your data to a third party). You can find information on how to control your preferences and the use of your Information via your account here. For certain Information you may withdraw your agreement to the processing of that Information in accordance with this Privacy Policy.

If you do not agree to the processing of your Information in the way this privacy policy describes, please do not provide your Information when requested and stop using KESS INNOVATION.

SCOPE AND APPLICATION OF THIS PRIVACY POLICY

This Privacy Policy applies to KESS INNOVATION, as well as any services accessible on the KESS INNOVATION platform that state that this Privacy Policy applies to the use of such service (for example, users that follow or use Official Accounts, Mini Programs and KESS CHAT Login for thirdparty apps). Those KESS INNOVATION services may have further privacyrelated terms that you must agree to if you use those services. Any capitalised terms used in this Privacy Policy have the same meaning as the equivalent defined terms in the KESS INNOVATIONTerms of Service, unless they are defined otherwise in this Privacy Policy.

Please note that this Privacy Policy does not apply to Information that you choose to disclose or submit to:

a) services other than KESS INNOVATION (such as other products or services supplied or operated by us or our affiliates), that do not expressly state that this Privacy Policy applies

b) any thirdparty services (including any thirdparty websites) that you may access through KESS INNOVATION or

c) companies or organizations that advertise products or services on KESS INNOVATION.

If you are using KESS INNOVATION on behalf of a company, partnership, association, government or other organization (your Organization), you agree to notify your Organization's relevant individual owners, shareholders, directors, officers, managers, employees and other relevant individuals whose Personal Information we collect or you provide to us from time to time (Connected Persons) of the collection of their Personal Information, and you agree to obtain your Connected Person consent to the processing of their Personal Information in accordance with this Privacy Policy as required by applicable laws and regulations. When this Privacy Policy refers to you or you're this includes you and any Connected Persons. If you or any Connected Persons would like to request your personal information be removed from our database, please contact us at support@kesspay.io.

WHAT INFORMATION DO YOU NEED TO PROVIDE KESS INNOVATION?

This section describes the different types of personal information we collect from you and how we collect it. If you would like to know more about specific types of data and how we use that data, please see the section entitled How do we use your information below.

We process different categories of information and data in providing KESS INNOVATION. These are set out below:

Location Data is information that is derived from your GPS, WiFi, compass, accelerometer, IP address, or public posts that contain location information. Location information will be disclosed (either to us, to other users, or both):

when you use locationbased features, such as People Nearby, POI search and when you share your location with other KESS INNOVATION users and

when you access KESS INNOVATION, as we derive location information from your IP address, device or internet service to prevent multiple or fraudulent logins to your account.

Log Data is information that we automatically collect when you use KESS INNOVATION, whether through the use of cookies, web beacons, log files, scripts or ETags (as explained in more detail in our Cookies Policy), including:

technical information, such as your mobile carrierrelated information, configuration information made available by your web browser or other programs you use to access KESS INNOVATION, your IP address and your device's version and identification number

about what you have searched for and looked at while using KESS INNOVATION, such as web search terms used, social media profiles visited, and details of other information and content accessed or requested by you in using KESS INNOVATION

metadata, which means information related to items you have made available through KESS INNOVATION, such as the date, time or location that a shared photograph or video was taken or posted.

Non Personal Information is any information that is not reasonably practicable to directly or indirectly identify you.

Personal Information is any information, or combination of information, that relates to you, that can be used (directly or indirectly) to identify you. We set out examples of Personal Information (and how we collect such Personal Information) in How do we use your information below.

Shared Information is information about you or relating to you that is voluntarily shared by you on KESS INNOVATION. Shared Information may include postings that you make on KESS INNOVATION (including your public profile, the lists you create, and photos, videos and voice recordings as accessed with your prior consent through your device's camera and/or microphone sensor), any postings from others that you repost and Location Data and Log Data associated with such postings. Shared Information also includes information about you (including Location Data and Log Data) that others who are using KESS INNOVATION share about you.

References to Information in this Privacy Policy mean both Personal Information and Non Personal Information.

HOW DO WE USE YOUR INFORMATION?

This section provides more detail on the types of personal information we collect from you, and why.It also identifies the legal basis under which we process your data:

Information Purpose of Processing

Registration Data and Login Data. Your name, user alias, mobile phone number, password, gender, and IP address.

Legal Basis (EEA): Necessary to perform our contract with you to provide your KESS INNOVATION profile and provide KESS INNOVATION services.

to set up and log in to a user account on KESS INNOVATION

to notify you about changes to KESS INNOVATION

to facilitate communication

to provide you with user support

to enforce our terms, conditions, and policies

to communicate with you

to provide personalized help and instructions

to better understand how you access and use KESS INNOVATION

to develop new and improve existing services

to provide language and location customization

to protect any rights, property or safety of ours, our affiliate companies, or other users of KESS INNOVATION and

to administer KESS INNOVATION and for internal operations, including troubleshooting, data analysis, testing, research, security, frauddetection, account management, and survey purposes.

User Profile Search Data. Record of search inquiries.

Legal Basis (EEA): Necessary to perform our contract with you to provide efficient access to your KESS INNOVATION activity.

to provide quick access to previous searches.

Shared Information Profile Data. Any information that you include in your publiclyvisible KESS INNOVATION profile, which may include your profile ID, name, and photo.

Legal Basis (EEA): Necessary to perform our contract with you to provide your KESS INNOVATION profile and provide KESS INNOVATION services.

to administer the KESS INNOVATION platform in accordance with your instructions and requests

to provide personalised help and instructions

to provide language and location customisation

to develop new and improve existing services

to better understand how you access and use KESS INNOVATION

to maintain your KESS INNOVATION account in accordance with your instructions and requests.

Shared Information Profile Media. This comprises all of the information you make available to other users via KESS INNOVATION, comprising:

Legal Basis (EEA): Necessary to perform our contract with you to provide your KESS INNOVATION profile and provide KESS INNOVATION services.

to administer the KESS INNOVATION platform

to provide personalised help and instructions

to provide language and location customisation

to develop new and improve existing services

to maintain your KESS INNOVATION account

account security.

Chat Data. Content of communications between you and another user or group of users. This is stored on your device and the devices of the users that you have sent communications to. We do not permanently store this information on our servers and it only passes through our servers so that it can be distributed to the users you have chosen to send communications to.

Legal Basis (EEA): Necessary to perform our contract with you to provide the chat services of KESS INNOVATION.

to facilitate delivery of communication to another user.

Contacts List. Your ondevice contact list.

Legal Basis (EEA): Necessary to perform our contract with you to provide KESS INNOVATION and connect you with your friends.

to connect you with other KESS INNOVATION users using the Recommended Friends function.

OpenID. We generate an OpenID each instance your KESS CHAT account activates a thirdparty KESS INNOVATION Open Platform service. It is a unique identifier that only exists for one account connecting to a single service and allows it to be identified without using other personal information for example, your name or email address.

Legal Basis (EEA): Necessary to perform our contract with you to provide your KESS INNOVATION profile and provide KESS INNOVATION services.

to allow you to follow an Official Account

to allow you to use a Mini Program and

to allow you to use your KESS INNOVATION ID to login to third party services.

Log Data. See definition above.

Legal Basis (EEA): It is in our legitimate interest to ensure the security of our services, manage registrations and improve our services.

to better understand how you access and use KESS INNOVATION

to administer KESS INNOVATION

for internal operations, including troubleshooting, data analysis, testing, research, security, frauddetection, and account management.

Location Information. See definition above.

Legal Basis (EEA): Necessary to perform our contract with you to provide KESS INNOVATION locationrelated services.

For security, frauddetection and account management (such as to ensure there are not multiple logins or suspicious logins on your account)

to provide you with locationbased services that you choose to use:

Share Location (when you select to share your location within a chat with other users)

Official Accounts (if you select to disclose your location to an Official Account, that information will be shared with the Official Account)

Mini Program (if you choose to disclose your location to a Mini Program, or choose to find Mini Programs Nearby)

Search (if you perform an external search using KESS INNOVATION, the service uses your location to provide you with locally relevant information)

to provide language and location customization.

Credit card information

Legal Basis (EEA): We process this data in accordance with our obligations under applicable law.

In some regions, credit card information is collected and the card information verified via a thirdparty payment processing service for the purpose of verifying parental or guardian consent to use KESS INNOVATION by an underage minor. This information is not permanently stored to KESS INNOVATION's servers and is immediately disposed after a verification request has been performed by the thirdparty payment processing service.

Customer Support Information. Any information that you provide to our customer support team.

Legal Basis (EEA): Necessary to perform our contract with you to provide and support KESS INNOVATION.

to investigate your support issue.

Device Data. Media stored on your device

Legal Basis (EEA): Necessary to perform our contract with you to provide KESS INNOVATION services.

to facilitate the sharing of such media using KESS INNOVATION.

Legal Basis (EEA): Necessary to perform our contract with you to provide KESS INNOVATION services.

if you choose to connect a third party social media account to your KESS CHAT account, we process this information to facilitate login to KESS INNOVATION via social media account.

Legal Basis (EEA): We collect this information with your consent

to better understand how you access and use KESS INNOVATION

to provide personalized help and instructions

to develop new and improve existing services

to improve KESS INNOVATION and respond to customer requests and preferences.

Contest Information. Any information that you provide to us in submitting an entry to a contest offered on KESS CHAT.

Legal Basis (EEA): Necessary to perform our contract with you to validate contest entry and award prizes.

to facilitate your participation in the contest

to award prizes, if applicable.

Legal Basis (EEA): It is in our legitimate interest to ensure the security of our services, manage registrations and improve our services.

Analysis of what features or actions are taken within the app in order to improve app experience

Fraud detection and account safety analysis

User demographic analysis on items such as region, phone model, operating system platform, system language, and KESS INNOVATION version in order to better understand how our users are using KESS INNOVATION Web and account traffic statistics of what content and services are used when users access thirdparty services on the KESS INNOVATION Open Platform as a method for informing thirdparty service providers basic analysis of how their service is being used by KESS INNOVATION users

Some features of KESS INNOVATION are only available to users in certain jurisdictions. For these features we collect additional information as follows:

Information Purpose of Processing

Additional Registration Data Verified Account. Nationality, date of birth, residential address, copy of residential address proof, copy of personal identification document (for example passport, identification card etc.), personal identification document number, occupation, and source of funds.

Availability: This feature is only available to users with mobile numbers issued in certain jurisdictions If you choose to apply for account verification (in order to unlock additional payment and fund settlement features in KESS

INNOVATION), we use this information to:

to verify your identity and

to facilitate payment and funds settlement.

Payments Information. Your credit card number, expiry, CVC, cardholder name, and transactional payment data via MIDAS payments SDK.. Please note that where a payment is processed by a third party payment service provider, we do not collect or store any Personal Information, though we may receive summary information about transactions.

Availability: This feature is only available to users with mobile numbers issued in certain jurisdictions

to facilitate your purchases within KESS INNOVATION

to validate your real name to facilitate the creation of your KESS INNOVATION Pay account

Personal Information within Your Content

If any of your Personal Information comprises Your Content (as defined in the KESS INNOVATIONTerms of Service), we and our affiliate companies may (subject to this Privacy Policy) use such Personal Information in accordance with the Your Content section of the KESS INNOVATIONT erms of Service.