Effective Date: March 19, 2025

1.1 Welcome to the VENTENY Platform operated by PT VENTENY Fortuna International, Tbk and its affiliates and subsidiaries (individually and collectively “VENTENY” or “we“). VENTENY takes seriously its responsibilities under applicable privacy laws and regulations (“Privacy Laws“) and is committed to respecting the rights and privacy concerns of all Users of our VENTENY Platform (the “Platform“) (collectively we refer to the Platform and the services we provide as described in our Site as the “Services“). We recognize the importance of the personal data you have entrusted to us and believe it is our responsibility to properly manage, protect and process your personal data. This Privacy Policy (“Privacy Policy” or “Policy“) is designed to help you understand how we collect, use, disclose and/or process the personal data that you have entrusted to us and/or we hold about you, both now and in the future, and to help you make an informed decision before providing your personal data to us.

1.2 “Personal Data” or “personal data” means data, whether true or not, about an individual who can be identified from such data, or from other data and information to which an organization has or may have access. Common examples of personal data may include name, identification number and contact
information.

1.3 By using the Services, registering an account with us, visiting our Platform, or accessing the Services, you acknowledge and agree that you accept the practices, terms, and/or policies outlined in this Privacy Policy, and you hereby authorize us to collect, use, disclose and/or process your personal data as described herein. IF YOU DO NOT CONSENT TO THE PROCESSING OF YOUR PERSONAL DATA AS DESCRIBED IN THIS PRIVACY POLICY, PLEASE DO NOT USE OUR SERVICES OR ACCESS OUR PLATFORM. If we change our Privacy Policy, we will post such changes or the amended Privacy Policy on our Platform. We reserve the right to change this Privacy Policy at any time.

1.4 This Policy applies in conjunction with any other applicable notices, contractual clauses, consent clauses relating to our collection, storage, use, disclosure and/or processing of your personal data and is
not intended to override such notices or clauses unless we state otherwise.

1.5 This Policy applies to both buyers and sellers using the Service unless expressly stated otherwise.

2.1 We will/may collect your personal data:

• when you register and/or use our Services or Platform, or open an account with us.
• when you fill in information while using our Services or Platform, submit any form, including, but not limited to, application forms or other forms relating to our products and services, either online or in physical form;
• when you enter into an agreement or provide documents or other information in connection with your interaction with us, or when you use our products and services;
• when you interact with us, such as by telephone (which may be recorded), mail, fax, face-to-face meetings, social media platforms and email, chat applications such as Whatsapp, including when you interact with our customer service agents;
• when you use our electronic services, or interact with us through our applications or use services on our Platform. This includes, without limitation, through cookies that we may use when you interact with our applications or websites;
• when you give your device permission to share information with our app or Platform;
• when you link your VENTENY account with your social media or other external accounts or use other social media features, in accordance with the provider’s policies;
• when you make a transaction through our Services;
• when you share your feedback or complaints with us;
• when you register for a contest; or
• when you submit your personal data to us for any reason.

The above list is not intended to be exhaustive and only sets out some general examples of when your personal data may be collected.

2.2 We may collect your personal data from you, our affiliates, third parties, and from other sources, including but not limited to business partners (such as logistics or payment service providers), credit bureaus or assessment agencies, marketing service providers or partners, referral or loyalty programs, other users of our Services or other publicly available or government-sourced data.

2.3 In certain situations, you may provide us with personal data of other individuals (such as your family members or friends or people on your contact list). If you provide us with their personal data, you represent and warrant that you have obtained consent for their personal data to be processed in connection with this Policy.

3.1 Personal data that VENTENY may collect includes but is not limited to:

• Name;
• email address;
• date of birth;
• billing address;
• bank account and payment information;
• phone number;
• Gender;
• information sent by or connected to the device(s) used to access our Services or Platform;
• information about your network, including your contact list when you give consent/permission on your device, and the people and accounts you interact with;
• government-issued identification or other information necessary for our due diligence, knowing your customer, identity verification, and/or fraud prevention purposes;
• any other information about the User when the User registers to use our Service or Platform, and
  when the User uses the Service or Platform, as well as information relating to how the User uses our Service or Platform;
• information or data related to any party or individual who has not been registered on the Platform provided by the User when using the Service; and
• all data about the content used by Users.

3.2 You agree not to submit any inaccurate or misleading information to us, and you agree to notify us of any inaccuracies or changes to such information. We reserve the right at our discretion to require further documentation to verify the information you provide.

3.3 If you register to become a user of our Platform using your social media account (“Social Media Account“), connect your VENTENY account with your Social Media Account or use any of VENTENY’s social media features, we may access information about you that you voluntarily submit to the Social Media Account provider in accordance with the social media provider’s policies, and we will manage and use such
personal data in accordance with this Policy at all times.

3.4 If you do not want us to collect the above information/personal data, you may opt out at any time by notifying our Data Protection Officer in writing. Further information regarding such revocation can be found in the section below entitled “How can you withdraw consent, delete, request access to, or modify information you have provided to us?” . Please note, however, that opting out of, or withdrawing consent for us to collect, use or process your personal data, may affect your use of the Services and Platform. For example, deselecting the collection of location information will cause its location-based features to be disabled.

4.1 As with most websites and mobile applications, your device sends information that may include data about you that may be recorded by the web server when you use our Platform. This typically includes without limitation, your device’s Internet Protocol (IP) address, computer/mobile device operating system, and browser type, mobile device type, mobile device characteristics, the unique device identifier (UDID) or mobile equipment identifier (MEID) for your mobile device, the address of the recommending site (if any), the pages you visit on our websites and mobile applications and the time of your visit, and sometimes “cookies” (which can be disabled by using your browser preferences) to help the site remember your last visit. If you log in, this information is associated with your personal account. The information is also included in anonymized statistics to allow us to understand how visitors use our site.

4.2 Our mobile applications may collect detailed location information from mobile devices using technologies such as GPS, Wi-Fi, etc. We collect, use, disclose and/or process the information for one or more purposes, not limited to, location-based services that you request or to deliver content to you based on your location or to allow you to share your location with other Users as part of the services on our mobile applications. For most mobile devices, you can revoke the consent you gave us to obtain this information on your location through your device settings. If you have any questions about how to disable your mobile device’s location services, please contact your mobile device service provider or the device manufacturer.

4.3 As when you view pages of our website or mobile applications, when you watch content and advertisements and access other software on our Platform or through the Services, information may be transmitted to us (including, without limitation, IP Address, operating system etc.); however, instead of page views, your device sends us information about the content, advertisements viewed and/or software installed by the Services and Platform and the time.

5.1 From time to time, we or our authorized service providers may use “cookies” or other features to enable us to collect or share information in connection with your use of the Services or the Platform. Such features
help us improve the Platform and our Services that we offer, or help us offer new services and features. “Cookies” are identifiers stored on your computer or mobile device that record data about your computer or device how and when the Services or Platform are used or visited, by how many people, and other activities on our Platform. We may link cookie information to personal data. Cookies also link to information about what items you have selected for purchase and the pages of the site you view. This information is also used to track your shopping cart, to deliver content specific to your interests, to perform data analysis and to monitor the use of our Services.

5.2 You may refuse the use of cookies by selecting the appropriate settings on your browser or device. However, please note that if you do this, you may not be able to use the full functionality of our Platform or Services.

6.1 We may collect, use, disclose and/or process your personal data for one or more of the following purposes:

• consider and/or process your applications/transactions with us or your transactions or communications with third parties through the Service;
• manage, operate, provide and/or administer your use of and/or access to our Services and our Platform (including, but not limited to, remembering your preferences), as well as your relationship and your user account with us;
• respond to, process, deal with or resolve your transactions, complaints, and/or fulfill your requests
  for certain products and services and notify you of service issues and unusual account actions;
• enforce the Terms of Service or any applicable end user license agreement;
• protect personal safety and the rights, property or safety of others;
• for identification, verification. due diligence, or know your customer goals;
• to evaluate and make decisions with respect to your credit or risk profile and your eligibility for financing or credit products, whichever is applicable;;
• to make recommendations on products, suggest sizes, and on how clothing materials fit;
• maintain and provide any software and/or other updates and support that may be required from time to time to ensure the smooth running of our Services;
• dealing with or facilitating customer service, carrying out your instructions, dealing with or responding to any queries raised by (or purportedly raised by) you or on your behalf;
• contact you or communicate with you by telephone calls, text messages and/or fax messages, email and/or postal mail or any other means for the purpose of administering and/or managing your
  relationship with us or your use of our Services, such as but not limited to communicating
  administrative information to you relating to our Services. You acknowledge and agree that such communications by us may be made by sending letters, documents or notices to you, which may involve disclosing certain personal data about you in order to make such delivery as well as listed on the outer cover of the postal envelope/package; 
• allowing other Users to interact, connect with you or view some of your activity on the Platform, including notifying you when another User has sent you a private message, posted a comment to you on the Platform or connected with you using social features on the Platform;
• conduct research, analysis and development activities (including, but not limited to, data analysis,
  surveys, product and service development and/or profiling), to analyze how you use our Services, improve our Services or products and/or enhance your customer experience;
• enable audits and surveys to, among other things, validate the size and composition of our target audience and understand their experience with the VENTENY Services;
• for marketing and advertising, and in this regard, sending you via various modes of communication, marketing and promotional information and materials relating to products and/or services (including, but not limited to products and/or services of third parties collaborating or associated with VENTENY) which VENTENY (and/or its affiliates, or related corporations) may sell, market or promote, whether such products or services exist now, or are created in the future. You may unsubscribe from receiving marketing information at any time by using the unsubscribe function in electronic marketing materials or by contacting our Customer Service. We may use your contact information to send you newsletters from us and from companies associated with us;
• to automatically subscribe you to VENTENY’s newsletter once you have verified your e-mail
  address via OTP (which if you do not wish to do, you can simply click the “unsubscribe” button found at the bottom of the e-mail newsletter you receive);
• offer loyalty, partner and bonus programs and offers and other co-branded marketing efforts, such as merchant loyalty programs, merchant offers or co-branded credit cards in collaboration with third parties;
• respond to legal process or comply or as otherwise required by any applicable law, governmental
  or regulatory requirement with the relevant jurisdiction or if we have a good faith belief that such disclosure isnecessary, including, without limitation, satisfying the requirement to make disclosures under legal requirements that are binding on VENTENY or its related companies or affiliates (including, where applicable, the display of your name, contact details and company details);
• generating statistics and research for internal reporting and those required by law and/or records retention requirements;
• carry out due diligence or other screening activities (including, without limitation, background
  checks) in accordance with any legal or regulatory obligations or our risk management procedures that may be required by law or that we have put in place;
• to conduct risk and/or credit assessments and to determine the products or terms, including credit products, financial services, or other products (whichever is applicable), provided by either VENTENY or its affiliates, to be offered to you;
• to provide creditworthiness reports, credit scoring and/or related services to third parties that you expressly authorize and consent to obtain your personal data from any third party as a data source and/or data processor, including us, subject to the terms of service and privacy policy of the third party recipient of such services;
• audit our Services or VENTENY’s business;
• prevent or investigate any actual or suspected breach of the Terms of Service any fraud, unlawful activity, omission or misconduct, whether in connection with your use of our Services or any other matter whatsoever arising out of your relationship with us;
• respond to any threatened or actual claim brought against VENTENY or any other claim that any
  Content violates the rights of a third party;
• store, host, back up (whether for disaster recovery or otherwise) your personal data, whether within
  or outside your jurisdiction;
• dealing with/and or facilitating a business asset transaction or possible business asset transaction,
  where such transaction involves VENTENY as a participant or involves only VENTENY’s related
  companies or affiliates as participants or involves VENTENY and/or one or more VENTENY’s
  related companies or affiliates as participants, and there may also be other third party organizations that are participants in such transaction. “Business asset transaction” refers to the purchase, sale, lease, merger, consolidation or any other form of acquisition, disposal or financing of an organization or part of an organization or any business or assets of an organization; and/or
• to perform automated decision-making in accordance with each of the purposes referred to above;
  and/or 
• any other purpose which we will inform you of at the time of obtaining your consent.

(collectively referred to as the “Purposes “).

6.2 You acknowledge, agree and consent that VENTENY may access, retain and disclose your personal data and information and your Account Content if required by law or pursuant to a court order or by any governmental or regulatory priority having jurisdiction over VENTENY or in the good faith belief that such access retention or disclosure is reasonably necessary to: (a) comply with legal process; (b) fulfill a request from any governmental or regulatory authority having jurisdiction over VENTENY; (c) enforce VENTENY’s Terms of Service or this Privacy Policy; (d) respond to any threatened or actual claim against VENTENY or other claim that any Content violates the rights of a third party; (e) respond to your requests for customer service; or (f) protect the rights, property or personal safety of VENTENY, its users and/or the public.

6.3 Because the purposes for which we will/may collect, use, disclose or process your personal data depend on the circumstances, those purposes may not be listed above. However, we will inform you of such other purposes at the time of obtaining your consent, unless the processing of the applicable data without your consent is permitted by the Privacy Act.

7.1 We implement various security measures and endeavor to ensure the safety of your personal data on our systems. Users’ personal data is behind a secure network and can only be accessed by a small number of employees who have special access rights to such systems. Nevertheless, there is no guarantee or absolute security is inevitable.

7.2 We will retain personal data in accordance with the Privacy Act and/or other applicable laws. Namely, we will destroy or anonymize your personal data when we reasonably consider that (i) the purpose for which the personal data was collected is no longer served by the retention of such personal data; (ii) retention is no longer necessary for any legal or business purpose; and (iii) there is no warrant legitimizing further withdrawal of such personal data. If you stop using our Platform, or your authorization to use the Platform and/or Services is terminated or withdrawn, we may continue to retain, use and/or disclose your personal data in accordance with the Privacy Policy and our obligations under the Privacy Act and other applicable laws and regulations. Subject to applicable law, we may securely dispose of your personal data without prior notice to you.

8.1 In the course of our business, we will/may need to use, process, disclose and/or transfer your personal data to our third party service providers, agents and/or affiliates or associated companies, and/or other third
parties, which may be located in Indonesia or outside Indonesia, for one or more of the Purposes mentioned above. Such third party service providers, agents and/or affiliates or associated companies and/or other third parties will process your personal data on behalf of us or others, for one or more of the Purposes mentioned above. We endeavor to ensure that our third parties and affiliates keep your personal data secure from unauthorized access, collection, use, disclosure, processing or similar risks and retain your personal data only for as long as your personal data is needed for the Purposes mentioned above. Such third parties include, without limitation:

• our subsidiaries, affiliates and related companies;
• buyers or sellers who have transacted or interacted with you on the Platform or in connection with
  your use of the Service for the Purposes mentioned above;
• other Users of the Platform for one or more of the aforementioned Purposes;
• contractors, agents, service providers and other third parties that we use to support our business and/or whose products and/or services are available or provided on the Platform. This includes but is not limited to parties that provide administrative or other services and/or products to us and/or to users such as,financial service providers, credit scoring companies, telecommunications companies, information technology companies and data centers;
• VENTENY affiliates or other third parties where you have connected your VENTENY account with such third parties using “Connect with VENTENY” or other similar features;
• governmental or regulatory authority having jurisdiction over VENTENY or as permitted under Section 6.2;
• pto a purchaser or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of VENTENY’s assets, whether on a going concern basis or as part of an insolvency, liquidation or similar proceeding, where personal data held by VENTENY about Users of our Services is one of the assets transferred; or to a counterparty in a business asset transaction involving VENTENY or one of its affiliates or related companies; and
• third parties to whom we disclose such data for one or more Purposes and such third parties will in
  turn collect and process your personal data for one or more Purposes.

8.2 This may require, among other things, for us to share information, including statistical and demographic information, about our Users and information regarding their use of the Services with advertising and programming suppliers.

8.3 For the avoidance of doubt, in the event that the Privacy Act or other applicable law permits an organization such as us to collect, use or disclose your personal data without your consent, the permission granted by such law shall continue to apply.

8.4 Third parties may intercept or access personal data transmitted to or stored on the site without authorization, technology may malfunction or not work as expected, or someone may access, utilize or misuse information without any fault on our part. We will however use reasonable security arrangements to protect your personal data as required by the Privacy Act; inevitably, however, there is no guarantee of absolute security such as but not limited to unauthorized disclosure arising from malicious and sophisticated hacking by displeased or hostile parties without any fault on our part.

8.5 As set forth in VENTENY’s Terms of Service, Users (including any employee, agent, representative or any other person acting on behalf of such Users or on behalf of Users) who come into possession of the personal data of other Users through the use of the Services (“Receiving Parties”) hereby agree that, they will (i) comply with all applicable Privacy Laws with respect to such data including any collection, processing, storage or transfer of such data, (ii) allow VENTENY or the User whose personal data has been collected by the Receiving Party (“Disclosing Party”) to delete its collected data from the Receiving Party’s database, in each case (ii) and (iii) allow VENTENY or the Disclosing Party to review what information has been collected about them by the Receiving Party, in each case (ii) and (iii) above, in accordance with and if required by law; and (iii) allow VENTENY or the Disclosing Party to review what information has been
collected about them by the Receiving Party, in each case (ii) and (iii) above, in accordance with and where required by applicable law.

8.6 Notwithstanding any other provision set forth herein, the Seller (including any employee, agent, representative or any other person acting on behalf of such Seller or on behalf of the Seller) shall comply with all applicable Privacy Laws and, with respect to any buyer’s personal data received from VENTEN, (i) shall not be permitted to use such buyer’s personal data except as reasonably necessary to respond to the buyer’s inquiries and to respond to, process, handle or complete transactions without the prior written consent of the buyer and VENTENY; (ii) shall refrain from contacting the buyer using such information outside of the VENTENY platform; (iii) shall not disclose such buyer’s personal data to any unauthorized third party without the prior written consent of the buyer and VENTENY; (iv) shall use adequate security measures to protect the personal data of each VENTENY user in their possession retain such data only to the extent necessary for the purposes stated above and in accordance with the Privacy Act, and to delete or return such data to VENTENY whenever requested by VENTENY or as soon as possible after completing a transaction; and (v) to notify VENTENY’s Personal Data Protection Officer at dpo@VENTENY.com in the event of a potential data breach or loss of such user’s data.

9.1 The Services are not directed to children under the age of 21. We do not knowingly collect or store any personal data or non-personal information from anyone under the age of 21 and any part of our Platform or other Services is not directed to children under the age of 21. As a parent or legal guardian, please do not authorize children in your care to submit personal data to VENTENY. In the event that personal data of children under the age of 21 under your care is disclosed to VENTENY, you hereby consent to the processing of such child’s personal data and accept and agree to be bound by this Privacy Policy on behalf of such child. We will close any accounts used exclusively by such children and will release and/or delete any personal data that we believe was submitted without parental or legal guardian consent by a child under the age of 17.

10.1 Our Platform uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses cookies, which are text files placed on your device, to help the Platform analyze how users use the Platform. The information generated by the cookie regarding use of the Platform (including your IP address) will be transmitted to, and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of our Platform, compiling reports on website activity for website operators and providing other services relating to website activity and Internet usage.Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google.

10.2 We, and third parties, may from time to time provide downloads of software applications for your use on the Platform or through the Services. All of these applications may separately access, and allow third parties to view, information that can identify you, such as your name, User ID, IP Address of your device or other information, such as what cookies may be pre-installed, or installed for you by a third party software application or website. In addition, all of these applications may ask you to provide additional information directly to the third party. Third-party products or services through these applications are not owned or controlled by VENTENY. You are encouraged to read other terms and policies published by such third parties on their websites or otherwise.

11.1 WE DO NOT GUARANTEE THE SECURITY OF ANY PERSONAL DATA AND/OR OTHER INFORMATION YOU PROVIDE ON THIRD PARTY SITES. We do implement a variety of security measures to maintain the safety of your personal data that is with us or under our control. Your personal data is held behind a secure network and can only be accessed by a limited number of people who have special access rights to such systems, and are required to keep such personal data confidential. When you place an order or access personal data, we offer the use of a secure server. All personal data or sensitive information that you provide is encrypted into our database and can only be accessed as stated above.

11.2 In an effort to provide you with increased value, we may select various third-party websites to link to, and frame within the Platform. We may also participate in co-branding and other relationships to offer e commerce and other services and features for our visitors. All of these linked sites have their own separate and independent privacy policies and security settings. Even if the third party is affiliated with us, we have no control over these linked sites, each of which has its own privacy and data collection practices separate from ours. Data collected by our co-branded partners or third-party websites (even if offered on or through our Platform) may not be accepted by us.

11.3 Accordingly, we take no responsibility or liability for the content, security arrangements (or lack of security arrangements) and activities of these linked sites. These linked sites are for your convenience only, and therefore you access them at your own risk. However, we endeavor to protect the integrity of our Platform and the links placed on each site, and therefore, we welcome any feedback regarding these linked sites (including, but not limited to, if certain links do not work).

12.1 Your personal data and/or information may be transferred, stored or processed outside your country for one or more Purposes. VENTENY will only transfer your information overseas in accordance with Privacy Laws.

13.1 User Rights

13.1.1 Right to Access, Data Acquisition, and Correction of Personal Data

The User has the right to (i) obtain information about the basis and purpose of the request and use of Personal Data and the use of Personal Data and (ii) obtain access to and obtain a copy of Personal Data about him/her in accordance with the provisions of laws and regulations. Where necessary (including, where applicable, to submit a request to obtain a copy of his/her personal data in a common format and request VENTENY to transfer his/her personal data to another Personal Data Controller), and (iii) the User may supplement, update and/or correct any errors and/or inaccuracies in the Personal Data about him/her in accordance with the purposes of processing the Personal Data.

13.1.2 Right to Terminate, Delete Personal Data and Withdraw Consent.

The User has the right to terminate the processing, delete and/or destroy Personal Data about him/her and withdraw the consent to the processing of Personal Data about him/her that has been given to VENTENY, in accordance with the provisions of laws and regulations and in the manner specified by VENTENY in the Privacy Policy.

13.1.3 The right to object to decision-making measures that are based solely on automated processing of a person’s profile (profiling)

The User has the right to object to decision-making actions based solely on automated processing, including profiling, that give rise to legal consequences or have a significant impact on the User.

13.1.4 The right to suspend or restrict processing of personal data in a manner proportionate to the purposes for which the personal data is processed The User has the right to suspend or restrict the processing of Personal Data so that it is only processed in accordance with the purposes of processing Personal Data to which the User has consented.

13.2 Revoke Consent

13.2.1 You may withdraw your consent to our collection, use and/or disclosure and/or request erasure of your personal data in our possession, or under our control, by emailing the Personal Data Protection Officer at dpo@venteny.com, and we will process your request in accordance with this Privacy Policy and our obligations under the Privacy Act and other applicable laws. However, revocation of your consent may mean that we will not be able to continue providing the Services to you, and we may have to terminate our relationship with you and/or the contract you entered into with us.

13.3 Requesting Access to, or Correction of Personal Data

13.3.1 We reserve the right to charge you a reasonable fee for handling and processing your request to access your personal data, subject to applicable regulations, and to notify you of the estimated fee.

13.3.2 We will correct/update your personal data based on your request in accordance with the provisions of the Privacy Act, unless otherwise stipulated in other applicable regulations.

If you have any questions or concerns about our privacy practices please contact us via dpo@venteny.com.