Personal Information Collection Statement

At En-Novelty Limited (“En-Novelty”, “we”, “us” or “our”), we hold as one of our core values the protection of privacy of our customer’s personal data. As a provider of innovation services, collection and use of personal data of our customers is at the heart of our business. En-Novelty respects the privacy of your personal data and are committed to fully complying with the Personal Data (Privacy) Ordinance (Cap. 486). This Personal Information Collection Statement (this “Statement”) is made by En-Novelty, and applies between us and you (“you”, or “your”). This Statement should be read together with the terms and conditions (if any) of any software application (the “Application”) (as applicable), and the website at https://www.en-novelty.com/ (the “Website”) that refers to and/or contains this Statement (the “Terms and Conditions”), provided that, in the event of any inconsistency between this Statement and the Terms and Conditions concerning matters relating to personal data, this Statement shall prevail.

In order to enable us to perform the Purposes (as defined in the “Purposes for using personal data collected” section below), you are required to provide all the requested/mandatory personal data in the Documentation, the Application, and/or the Website (as applicable) that refers to and/or contains this Statement. If you do not provide the required personal data, then we may not be able to perform the Purposes and/or provide goods or services to you.

Kinds of personal data collected

The kinds of personal data we may collect from you and/or from other sources as mentioned below in this Statement and/or hold, use and/or disclose/share with (whether contained here or otherwise obtained) include your name, gender, age (or age range), date of birth, contact details, e-mail address, mailing/residential/correspondence address, contact number, membership number, medical and health records, and information on your family, lifestyle and social circumstances, username and password, Log Files (see below), interests and favourite activities, tracking information about your use of the Application and/or the Website (as the case may be) and transaction information (including your characteristics and transaction behaviour) (“Tracking Data”), social media account information and etc. (if applicable). For Tracking Data collected through the use of cookies and other tracking mechanisms, please also refer to our related policies for further details as to how we collect, use and process Tracking Data.

Apart from the data collected stated in the above privacy policy and personal information collection statement, we will, for certain functions of the Platform, collect your biometric data including but not limited to your voice pattern, fingerprint, facial and body images, your location information based on your device, financial and medical information to provide the better user experience and enhanced health monitoring feature. While the provision of your biometric data is voluntary, failing to provide such biometric data may render certain functions of the Platform inaccessible, as it would be otherwise not possible to use the enhanced health monitoring feature. The biometric data collected may be transferred to other third party service providers, including but not limited to PANOPTICAI LIMITED and its contractors for the purpose of analyzing of such data, which will be stored in encrypted form such that it will not be able to link up the data with a particular person. We will ensure the collection of biometric data will not have any adverse impact on your rights and liberties, and will not rely upon the biometric data to take any adverse actions against you. PANOPTICAI LIMITED and its contractors will procure the deletion of the collected biometric data regularly.] In the event that you would like to request access, correction or deletion of the biometric data, you may send your request to our Data Protection Officer, by emailing hello@en-novelty.com or writing to En-Novelty Limited, 713, Atelier King’s Road, 728 King's Road, Quarry Bay, Hong Kong (marked Confidential). In accordance with the Personal Data (Privacy) Ordinance (Cap. 486, Laws of Hong Kong) (the “PDPO”), we have the right to charge you a reasonable fee for the processing of any personal data access request.

Purposes for using personal data collected

The personal data to be collected from you and/or from other sources as mentioned below in this Statement will be used and retained by us (and/or our Affiliates and/or our Marketing Partners as defined in the

“Direct Marketing” section below, as applicable) for the following purposes (as may be applicable from time to time) (together, the “Purposes”):

• Identifying and verifying your identity and/or as a
• Registering you as a user of the Application and/or the Website (as the case may be);
• To serve you better and/or maintain your personal data and/or information across multiple pages within or across one or more sessions when using the Application and/or the Website (as the case may be);
• Following registration as a user, accessing your account information (including, but not limited to, your name, membership number, etc.) and managing your account (including, but not limited to, changing your password, updating your personal information, subscribing/unsubscribing from direct marketing, etc.);
• Research, development, and analysis in relation to your/customer behaviour including carrying out data sorting and analysis to enable us to better understand your characteristics and transaction behaviour (subject to your consent for direct marketing, if/where applicable) to provide other goods and/or services better tailored to your needs, and to assist us in selecting Marketing Subjects (see below) that are likely to be of interest to you, and carrying out aggregated behavioural analysis, including using personal data for statistical analysis, data science studies and data mining;
• For you to make enquiries, complaints, and/or suggestions to us in relation to the Purposes and/or the Goods and Services (including, but not limited to, through an in-app text box on your mobile device or through our official social media page and/or our official website, or by text message, email and/or mail, and/or other media whether now known or available in the future);
• Seeking your feedback, including through surveys, in relation to the Purposes and/or the Goods and Services (including, but not limited to,through an in-app text box on your mobile device or through our official social media page and/or our official website, or by text message, email and/or mail, and/or other media whether now known or available in the future);
• Improving the Documentation, the Application and/or the Website, the Purposes, and our and our Affiliates’ and Marketing Partners ‘Goods and Services;
• Direct marketing and cross-marketing for the Marketing Subjects, subject to consent (see below section entitled “Direct marketing”);
• Data analytics, profiling, information management and database administration;
• Deterring, detection, investigation and/or prevention of activities that may violate, or may be suspected to violate, our terms or may be abusive,

illegal, and/or criminal;

• Compliance with the obligations, requirements or arrangements for disclosing and using data that apply to us or with which it is expected to

comply according to:

• any law binding or applying to it within or outside Hong Kong existing currently and in the future;
• any guidelines or guidance given or issued by any legal, regulatory, governmental, tax, law enforcement or other authorities, within or outside Hong Kong existing currently and in the future; andany present or future contractual or other commitment with local or foreign legal, regulatory, governmental, tax, law enforcement or other authorities, that is assumed by or imposed on us by reason of its financial, commercial, business or other interests or activities in or related to the jurisdiction of the relevant local or foreign legal, regulatory, governmental, tax, law enforcement or other authorities.

• The normal management, operation, and maintenance of the Application and/or the Website and the provision of the Goods and Services to you;
• Storing your personal data (whether by a single or multiple Affiliates (including us) or our Marketing Partners)

for the purpose of sharing such personal data with our Affiliates and/or our Marketing Partners for any and all of the other Purposes listed above (and subject to your consent in the event that transfer to any or all such data transferees for direct marketing are involved); and/or

• Other purposes ancillary or related to the

Those with whom we share personal data

The personal data you provide to us will be kept confidential, except that it may be disclosed/shared with the following parties:

• any agent, contractor or third party service provider, in each case, that provides health care, technology, risk intelligence, administrative, telecommunications, computer, Internet or for any of the Purposes;

• any person to whom we are under an obligation or otherwise required to make disclosure under the requirement of any law binding on or applying to us or any of its Affiliates, or any disclosure under and for the purposes of any guidelines or guidance given or issued by any legal, regulatory, governmental, tax, law enforcement or other authorities with which we are expected to comply or any disclosure pursuant to any contractual or other commitment of us with local or foreign legal, regulatory, governmental, tax, law enforcement or other authorities, or self-regulatory or industry bodies or associations of financial services providers, all of which may be within or outside Hong Kong and may be existing currently and in the

We may also engage agents, contractors, suppliers and service providers (whether within or outside the Hong Kong Special Administrative Region of the People’s Republic of China (“Hong Kong”)) in connection with the Purposes and/or the provision of the Goods and Services, e.g. IT/software solutions/technology services providers, marketing agents, social media, research companies, and service providers of development and maintenance, administrative, data processing, digital storage, or other similar services, and may transfer to or share your personal data with them for the Purposes within or outside Hong Kong. We may also share your personal data (subject to your consent, if/where applicable) with our Affiliates, our Marketing Partners (see below) and the social media platforms that we and/or our Affiliates/our Marketing Partners (see below) use for such Purposes. Where we are required by the law of any country or place or requested by any court, regulatory body or governmental body of any country or place, we may also disclose your personal data as required. In the event of any actual or proposed transfer of business, transfer of shares, re- structuring, amalgamation, merger, sale, transfer, or purchase of us or our business or our Affiliates or our Affiliates' businesses, your personal data may be transferred to the new entity as part of the transaction, provided that the new entity abides by this Statement and continues to exercise the same level of care, in respect of your personal data, as we would. You will be notified of such event and you may decide to withdraw your consent to the use of your personal data.

Your personal data may be transferred to and/or stored by us in physical locations and/or servers located within or outside Hong Kong and/or shared with our Affiliates and/or our Marketing Partners (see below) located within or outside Hong Kong. However, we will take all reasonable measures to ensure that your personal data is stored and processed securely, regardless of the country or place in which it is stored, and we procure by contract or use our reasonable endeavours to ensure that our Affiliates and our Marketing Partners (see below) do the same.

Direct marketing

Subject to your consent, we may use your personal data to send you direct marketing (including, but not limited to, special offers, news, information and marketing) about us, our Affiliates and/or our Marketing Partners in relation to the Marketing Subjects whether by in-app messages and/or notifications and/or push notifications to your mobile device, post, email, telephone, text message, or other media whether now known or available in the future.

Subject to your consent, we may also use your personal data for, or provide your personal data to, our Affiliates and/or our Marketing Partners so that they may send you direct marketing (including, but not limited to, special offers, news, information and marketing) about us, our Affiliates and/or our Marketing Partners in relation to the Marketing Subjects whether by in-app messages and/or notifications and/or push notifications to your mobile device, post, email, telephone, text message, and/or other media whether now known or available in the future.

As we may share your personal data with our Affiliates and/or our Marketing Partners, we may also receive your personal data from them. Subject to your consent given to our Affiliates and/or our Marketing Partners, we may also use such personal data to send you direct marketing about us, our Affiliates and/or our Marketing Partners in relation to the Marketing Subjects.

We cannot use or provide your personal data for direct marketing purposes and/or provide your personal data to third parties (whether to our Affiliates and/or our Marketing Partners) for their direct marketing purposes unless you consent. Even if you give your consent, you can opt out of direct marketing at any time (or you may request that we cease to provide your personal data to third parties, at which point we will cease to do so), free of charge, by emailing hello@en-novelty.com or writing to our Data Protection Officer, En-Novelty Limited, 713, Atelier King’s Road, 728 King's Road, Quarry Bay, Hong Kong (marked Confidential).

Your rights

• Apart from your right to opt out of direct marketing as mentioned above, you have the following additional rights to check whether we hold any of your personal data;
• access your personal data held by us;
• require us to correct any personal data which is inaccurate; and
• ascertain our policies and practices (from time to time) in relation to personal data and the types of personal data held by us.

If you would like to make a request in relation to the above (or make any general enquiries), please contact our Data Protection Officer, by emailing hello@en-novelty.com or writing to En-Novelty Limited, 713, Atelier King’s Road, 728 King's Road, Quarry Bay, Hong Kong (marked Confidential).In accordance with the Personal Data (Privacy) Ordinance (Cap. 486, Laws of Hong Kong) (the “PDPO”), we have the right to charge you a reasonable fee for the processing of any personal data access request.

Privacy Policy Statement

We shall deal with all personal data in accordance with the Personal Data (Privacy) Ordinance of the laws of Hong Kong and our Privacy Policy Statement. Please refer to our Privacy Policy Statement here: https://www.en-novelty.com/

Inconsistency or conflict

If there is any inconsistency or conflict between the English and Chinese version of this Statement, the English version shall prevail.

Miscellaneous

This Statement may be updated from time to time to reflect changes to our policy with respect to personal data protection and/or changes to personal data/data privacy laws and regulations. Where there are significant changes, we will notify you and obtain your acceptance of the changes, consents, and/or opt in (as necessary or applicable). If you do not accept the changes and/or provide your consent, then we may not be able to perform the Purposes and/or provide goods or services to you. You are advised to check the Application and/or the Website (as the case may be) for updates to this Statement on a regular basis.

Nothing in this Statement shall limit your rights under the PDPO. If you are:

(i) an individual located in Mainland China who visits our relevant website(s) or uses our relevant mobile application(s), or otherwise uses our products and/or services by phone or any other means from Mainland China; and/or

(ii) an individual holding a Mainland China passport and/or resident identity card who visits our physical premises in Hong Kong or otherwise uses our products and/or services by phone or any other means in Hong Kong,

your personal data will be processed by us in accordance with the “People’s Republic of China Addendum” in addition to the (i) En-Novelty Privacy Policy Statement; and (ii) this Statement, as well as the applicable data protection laws and regulations in Mainland China.

“Mainland China” refers to the People’s Republic of China excluding the Hong Kong Special Administrative Region of the People’s Republic of China (“Hong Kong”), the Macau Special Administrative Region of the People’s Republic of China and Taiwan.

Please browse https://www.en-novelty.com/ for details.

This Statement shall be governed by, and construed in accordance with, the laws of Hong Kong.