Personal Data Protection Notice

BetterGoMax Ventures Pte. Ltd. ("BetterGoMax Ventures", "we", "us" or "our") is committed to protecting the personal data of individuals who interact with us or with our website bettergomax.com (the "Website").

This Personal Data Protection Notice (the "Notice") sets out the basis on which we collect, use, disclose and otherwise process personal data in accordance with the PDPA and the guidelines issued by the Personal Data Protection Commission of Singapore ("PDPC").

By accessing the Website, contacting us or otherwise providing personal data to us, you acknowledge that you have read and understood this Notice.

The organisation responsible for the personal data processed under this Notice is:

BetterGoMax Ventures Pte. Ltd.
77 High Street, #10-12B, High Street Plaza,
Singapore 179433
UEN: 202631454G

In accordance with Section 11(3) PDPA, we have designated a Data Protection Officer ("DPO") responsible for ensuring our compliance with the PDPA. You may contact the DPO on any matter relating to your personal data or this Notice:

Data Protection Officer: Maximilian Böhm
Email: info@bettergomax.com
Postal address: 77 High Street, #10-12B, High Street Plaza, Singapore 179433

Under the PDPA, "personal data" means data, whether true or not, about an individual who can be identified from that data, or from that data and other information to which we have or are likely to have access.

Depending on how you interact with us, we may collect the following categories of personal data:

• Contact and correspondence data that you voluntarily provide when you email us or otherwise communicate with us, such as your name, email address, employer or company, position, and the content of your message.
• Technical data automatically transmitted by your device when accessing the Website, such as your IP address, date and time of request, requested URL, HTTP status code, referrer URL, and information about your browser and operating system (see Section 9 on hosting and server log files).

We do not knowingly collect sensitive personal data (such as data relating to health, race, religion or political views) through the Website. Please do not send us such information unsolicited.

In accordance with Sections 13, 18 and 20 PDPA, we collect, use and disclose personal data only for purposes that a reasonable person would consider appropriate in the circumstances and, in particular, for the following purposes:

• responding to enquiries, requests and other communications that you send to us;
• providing information about our services and, where applicable, evaluating potential business relationships;
• operating, maintaining, securing and improving the Website, including preventing fraud, abuse and unauthorised access;
• complying with applicable laws, regulations, codes of practice, guidelines and lawful requests from public authorities;
• establishing, exercising or defending legal claims and managing our business risks.

We collect, use and disclose your personal data on the basis of your consent, unless an exception under the PDPA applies (for example, deemed consent under Section 15 PDPA when you voluntarily provide personal data for a purpose that is objectively obvious, or the exceptions set out in the First and Second Schedules to the PDPA, including legitimate interests and business improvement exceptions).

You may withdraw your consent to our continued collection, use or disclosure of your personal data at any time by giving us reasonable notice in writing to the DPO at info@bettergomax.com. Upon receipt of such notice, we will inform you of the likely consequences of the withdrawal. Please note that withdrawing your consent may affect our ability to continue providing information or services to you.

We do not sell personal data. We may disclose personal data to the following categories of recipients, only to the extent necessary for the purposes set out in Section 5 above:

• our service providers and data intermediaries acting on our behalf (for example, our hosting provider and email service provider), who are contractually required to protect personal data in accordance with the PDPA;
• professional advisors, including legal counsel, auditors and consultants, where reasonably required;
• government authorities, regulators, courts or law enforcement agencies, where required or authorised by law;
• any successor entity in connection with a corporate transaction (merger, acquisition, reorganisation or sale of assets).

Where we engage a data intermediary to process personal data on our behalf, we remain responsible for that personal data in accordance with Section 4(3) PDPA.

Some of our service providers may be located, or process personal data, outside Singapore. In accordance with Section 26 PDPA and Part 3 of the Personal Data Protection Regulations 2021, we take reasonable steps to ensure that any recipient of personal data outside Singapore is bound by legally enforceable obligations to provide a standard of protection that is comparable to the protection under the PDPA (for example, by way of contractual clauses, binding corporate rules or other lawful transfer mechanisms).

The Website is hosted by Hostinger. When you access the Website, our hosting infrastructure automatically records technical connection data in server log files, including in particular:

• the IP address of the requesting device;
• the date and time of the request;
• the requested URL and HTTP status code;
• the referrer URL;
• the user agent (browser type and operating system).

This information is used to operate the Website securely, to investigate abuse and to troubleshoot technical incidents. It is retained for as long as reasonably necessary for these operational and security purposes and is then deleted or anonymised.

The Website currently does not set analytics, advertising or profiling cookies and does not embed tracking pixels, session recording tools, advertising networks or social media plugins. No user profile is created across visits.

Only strictly necessary technical mechanisms may be used to deliver the pages you request. Should any non-essential cookies or tracking technologies be introduced in the future, we will update this Notice and, where required, obtain your consent before such technologies are activated.

The Website loads the typefaces "Fraunces" and "Inter" from Google's font service (operated by Google Ireland Limited / Google LLC). When a page loads, your browser establishes a connection to Google's servers and transmits your IP address and technical request headers. No cookies are set by this integration. This is done in the context of our legitimate interest in a consistent typographic presentation of the Website.

In accordance with Section 25 PDPA, we cease to retain personal data, or remove the means by which the personal data can be associated with particular individuals, as soon as it is reasonable to assume that:

• the purpose for which the personal data was collected is no longer being served by retention of the personal data; and
• retention is no longer necessary for legal or business purposes.

Correspondence data is generally retained for the duration of the relevant business relationship and for a reasonable period thereafter, to enable us to respond to follow-up enquiries and to comply with our legal obligations.

We implement reasonable administrative, technical and physical security arrangements to protect personal data in our possession or under our control against unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, in accordance with Section 24 PDPA.

However, no method of transmission over the Internet or method of electronic storage is fully secure. We cannot guarantee absolute security and any transmission of personal data to us is done at your own risk.

We make a reasonable effort to ensure that personal data collected by or on behalf of BetterGoMax Ventures is accurate and complete, in accordance with Section 23 PDPA. We rely on you to notify us of any changes to your personal data so that we may keep it accurate and up to date.

Subject to the exceptions and limitations set out in the PDPA, you have the right to:

• request access to personal data about you that is in our possession or under our control, and information about the ways in which the personal data has been or may have been used or disclosed within a year before the request (Section 21 PDPA); and
• request correction of an error or omission in the personal data about you that is in our possession or under our control (Section 22 PDPA).

To make an access or correction request, please write to the DPO at info@bettergomax.com. We may require you to provide sufficient information to verify your identity and to identify the personal data concerned before we respond. We may charge a reasonable fee for handling an access request, in accordance with the Personal Data Protection Regulations 2021, and will notify you of the fee in advance.

If you have any concern about the way in which we handle your personal data, we encourage you to contact our DPO first at info@bettergomax.com so that we may address your concern.

If your concern is not satisfactorily resolved, you may lodge a complaint with the Personal Data Protection Commission of Singapore. Information about the PDPC and its complaint process is available at www.pdpc.gov.sg.

The Website may contain links to third-party websites which are not operated by us. This Notice does not apply to such third-party websites and we are not responsible for their content or their personal data practices. We encourage you to review the privacy notices of any third-party website that you visit.

The Website is not directed to minors. We do not knowingly collect personal data from minors without the consent of a parent or guardian. If you believe that we have collected personal data from a minor, please contact the DPO so that we may take appropriate action.

We may update this Notice from time to time to reflect changes in our practices, in the services provided through the Website or in applicable law. The updated version will be posted on this page and will be effective as of the date of publication. Your continued use of the Website following such changes constitutes your acknowledgement of the updated Notice.

For any question or request relating to this Notice or to the processing of your personal data, please contact:

BetterGoMax Ventures Pte. Ltd.
Attn.: Data Protection Officer — Maximilian Böhm
77 High Street, #10-12B, High Street Plaza,
Singapore 179433
Email: info@bettergomax.com