DROPSYSTEM PRIVACY POLICY

Last Updated: 29 Apr 2024

AMDC Holding Limited and its affiliates (hereinafter referred to “AMDC”, “we”, “our” or us”) want you to be familiar with how we collect personal data from you and how we process such data. This Privacy Policy describes our practices in connection with information that we collect through:

· our website (https://www.dropsystem.io/) from which you are accessing this Privacy Policy (our “Site”);

· our DROP System app or any other applications or software we provide from time to time (collectively our “App”); and

· HTML-formatted email messages that we send to you that link to this Privacy Policy or other communications with you.

Collectively, we refer to the Site, App and emails as the “Services”.

AMDC Holding Limited

1. Definitions

1.1 ‘Marketplace’ refers to the universal platform provided by DROP System that facilitates, among others, loyalty programmes, event token collection, and reward redemption.

1.2 “Other Information” is any information that does not reveal your specific identity or does not directly relate to an identifiable individual. The Services collect Other Information such as:

· Browser and device information;

· Information collected through cookies, pixel tags and other technologies;

· Demographic information and other information provided by you that does not reveal your specific identity;

· Information that has been aggregated in a manner such that it no longer reveals your specific identity.

1.3 ‘Personal Information’ is information that identifies you as an individual or relates to an identifiable individual. The Services collect Personal Information, including:

· Email address;

· Phone number;

· Token wallet address, including related data used to detect cryptocurrency and NFT holdings;

· IP address (we may also derive your approximate location from your IP address);

· In-App activity, such as merchants interacted with, Token transactions, NFT transactions, etc.

1.4 ‘Token’ refers to the ‘DROP’ token which is an ERC-1155 token issued on the Polygon network.

2. Collection of Personal Information

2.1 For the purposes outlined in Clause 3, we may collect and process Personal Information that you provide us by filling in forms on our Site or our App, or by corresponding with us (by phone, email or otherwise), for example:

· when you register for an account with us on our Site;

· when you report any problem to us;

· when you use certain features on our Site or our App;

· when you request any support from us; or

· when you complete any survey or questionnaire we send you.

Note: Phone numbers may be collected and used for the delivery of Tokens or other necessary purposes as clearly communicated at the time of collection. Merchants may also collect your phone number directly using their chosen communication tools, such as WhatsApp, for similar purposes. You will always have the option to provide your phone number voluntarily. We recommend consulting the privacy policies of the respective merchants to better understand their specific practices regarding the handling of phone numbers.

2.2 We need to collect Personal Information in order to provide the requested Services to you. If you do not provide the information requested, we may not be able to provide the Services. If you disclose any Personal Information relating to other people to us or to our service providers in connection with the Services, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.

3. Use of Personal Information

3.1 We use Personal Information for the following purposes:

(a) Providing the functionality of the Services and fulfilling your requests.

· To provide the Services’ functionality to you, such as arranging access to your registered account, completing your transactions, and providing you with related benefits, special promotions, or customer service.

· To respond to your inquiries and fulfil your requests, for example, when you send us questions, suggestions, compliments, or complaints, or when you request information about our Services.

· To send administrative information to you, such as changes to our terms, conditions, and policies.

We will engage in these activities to manage our contractual relationship with you and/or to comply with a legal obligation.

(b) Providing you with our marketing materials and facilitating social sharing.

· To send you marketing related emails, with information about our services, new products, and other news about our company.

· To facilitate social sharing functionality that you choose to use.

We will engage in this activity with your consent or where we have a legitimate interest.

· To analyse or predict our users’ preferences in order to prepare aggregated trend reports on how our digital content is used, so we can improve our Services.

· To better understand your interests and preferences, so that we can personalize our interactions with you and provide you with information and/or offers tailored to your interests.

· To better understand your preferences so that we can deliver content via our Services that we believe will be relevant and interesting to you.

We will provide personalized services based on our legitimate interests, and with your consent to the extent required by applicable law.

(d) Allowing you to participate in promotions

· We may offer you the opportunity to other promotions.

· Some of these promotions have additional rules containing information about how we will use and disclose your Personal Information. Please read those additional rules before choosing to participate.

We use this information to manage our contractual relationship with you.

(e) Aggregating and/or anonymizing Personal Information.

· We may aggregate and/or anonymize Personal Information so that it will no longer be considered Personal Information. We do so to generate other data for our use, which we may use and disclose for any purpose, as it no longer identifies you or any other individual.

(f) Accomplishing our business purposes.

· For data analysis, for example, to improve the efficiency and quality of our Services;

· Debug, identify and repair errors that impair the intended functionality of our Services;

· For audits, to verify that our internal processes function as intended and to address legal, regulatory, or contractual requirements;

· For fraud prevention and fraud security monitoring purposes, for example, to detect and prevent cyberattacks or attempts to commit identity theft;

· For developing new products and services;

· For enhancing, improving, repairing, maintaining, or modifying our current products and services, as well as undertaking quality and safety assurance measures;

· For identifying usage trends, for example, understanding which parts of our Services are of most interest to users;

· For determining the effectiveness of our promotional campaigns, so that we can adapt our campaigns to the needs and interests of our users; and

· For operating and expanding our business activities, for example, understanding which parts of our Services are of most interest to our users so we can focus our energies on meeting our users’ interests.

We engage in these activities to manage our contractual relationship with you, to comply with a legal obligation, and/or based on our legitimate interest.

4. DISCLOSURE OF PRESONAL INFORMATION

4.1 We will keep your Personal Information confidential, but you agree we may provide information:

(a) to our affiliates (including subsidiaries) for the purposes described in this Privacy Policy;

· Those affiliates are: [None].

(b) to our third-party service providers, to facilitate services they provide to us.

These can include providers of services such as website hosting, data analysis, fraud prevention, information technology and related infrastructure provision, customer service or related benefits, email delivery, auditing, and other services.

5. Other uses and disclosures

5.1 We also use and disclose your Personal Information as necessary or appropriate, in particular when we have a legal obligation or legitimate interest to do so:

(a) To comply with applicable law and regulations.

· This may include laws outside your country of residence.

(b) To cooperate with public and government authorities.

· To respond to a request or to provide information we believe is necessary or appropriate.

· These can include authorities outside your country of residence.

· For example, when we respond to law enforcement requests and orders or provide information we believe is important.

(d) For other legal reasons.

· To enforce our terms and conditions; and

· To protect our rights, privacy, safety or property, and/or that of our affiliates, you or others.

(e) In connection with a sale or business transaction.

· We have a legitimate interest in disclosing or transferring your Personal Information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings).

6. COLLECTION OF Other Information

6.1 We and our service providers may collect Other Information in a variety of ways, including:

(a) Your browser or device.

· Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Mac), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version and the name and version of the Services you are using. We use this information to ensure that the Services function properly.

(b) Cookies.

· Cookies are pieces of information stored directly on the computer that you are using. Cookies allow us to collect information such as browser type, time spent on the Services, pages visited, language preferences, mouse clicks, page scrolls, keystrokes, and other traffic data. We and our service providers use the information for security purposes, to facilitate navigation, to display information more effectively, and to personalize your experience. We also gather statistical information about use of the Services in order to continually improve their design and functionality, understand how they are used, and assist us with resolving questions regarding them. Cookies further allow us to select which of our advertisements or offers are most likely to appeal to you and display them while you are on the Services. We may also use cookies or other technologies in online advertising to track responses to our ads. We do not currently respond to browser do-not-track signals. If you do not want information collected through the use of cookies, most browsers allow you to automatically decline cookies or be given the choice of declining or accepting a particular cookie (or cookies) from a particular website. You may also wish to refer to http://www.allaboutcookies.org/manage-cookies/index.html . If, however, you do not accept cookies, you may experience some inconvenience in your use of the Services. You also may not receive advertising or other offers from us that are relevant to your interests and needs.

· Pixel tags (also known as web beacons and clear GIFs) may be used to, among other things, track the actions of users of the Services (including email recipients), measure the success of our marketing campaigns, and compile statistics about usage of the Services and response rates.

· [We utilize data analytics tools to analyse user interactions with our Services, understand user behaviour, enhance performance, and personalize experiences. It is important to note that data on the blockchain is publicly accessible, including information linked to your wallet address such as transaction history and token holdings. Given the public nature of blockchain data, opt-out provisions for internal analytics do not apply to this information. However, for data we collect directly through our Services, you can manage your data privacy preferences in our service settings. These settings provide options to opt-out or specify which data points you are comfortable with sharing. We employ robust security measures to protect user data within our analytics tools.]

7. Uses and Disclosures of Other Information

We may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. If we are required to treat Other Information as Personal Information under applicable law, we may use and disclose it for the purposes for which we use and disclose Personal Information as detailed in this Policy. In some instances, we may combine Other Information with Personal Information. If we do, we will treat the combined information as Personal Information as long as it is combined.

8. Security

We seek to use reasonable organizational, technical and administrative measures to protect Personal Information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “Contacting Us” section below.

9. Choices and access

Your choices regarding our use and disclosure of your Personal Information:

We give you choices regarding our use and disclosure of your Personal Information for marketing purposes. If you no longer want to receive marketing related emails from us on a going-forward basis, you may opt out by clicking the unsubscribe link in such email.

We will try to comply with your request(s) as soon as reasonably practicable. Please note that if you opt out of receiving marketing related emails from us, we may still send you important administrative messages, from which you cannot opt out.

10. How you can access, change, or delete your Personal Information

If you would like to request to access, correct, update, suppress, restrict, or delete Personal Information, object to or opt out of the processing of Personal Information, or if you would like to request to receive a copy of your Personal Information for purposes of transmitting it to another company (to the extent these rights are provided to you by applicable law), you may contact us in accordance with the “Contacting Us” section below. We will respond to your request consistent with applicable law. In your request, please make clear what Personal Information you would like to have changed or whether you would like to have your Personal Information suppressed from our database. For your protection, we may only implement requests with respect to the Personal Information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable.

Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion (e.g., when you make a purchase or enter a promotion, you may not be able to change or delete the Personal Information provided until after the completion of such purchase or promotion).

11. Retention period

11.1 We retain Personal Information for as long as needed or permitted in light of the purpose(s) for which it was obtained and consistent with applicable law.

11.2 The criteria used to determine our retention periods include:

· The length of time we have an ongoing relationship with you and provide the Services to you (for example, for as long as you have an account with us or keep using the Services);

· Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); or

· Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).

11.3 Special Consideration for Blockchain Data: Please be aware that any data recorded on a blockchain is inherently immutable and will remain on the blockchain indefinitely. This permanence is due to the decentralized and immutable nature of blockchain technology. Once data has been added to the blockchain, it cannot be altered or deleted. Consequently, this data may be available for as long as the blockchain exists.

12. Third-Party Sites

Our Site, our App or our communication with you may from time to time contain links to third-party websites over which we have no control. If you follow a link to any of these websites, please note that they have their own practices and policies. We encourage you to read the privacy policies or statements of these websites understand your rights. We accept no responsibility or liability for any practices of third-party websites.

13. DATA TRANSFER

13.1 The data that we collect from you may be transferred to, and stored at, a destination outside Hong Kong. It may also be processed by persons referred to in Clause 4. above who operate outside Hong Kong.

13.2 By submitting your personal data you agree to this transfer, storing or processing of data outside Hong Kong. We will take all steps reasonably necessary to ensure that your data is treated securely in accordance with this Privacy Policy.

14. Updates to this privacy policy

The “LAST UPDATED” legend at the top of this Privacy Policy indicates when this Privacy Policy was last revised. Any changes will become effective when we post the revised Privacy Policy on the Services.

15. Contacting us

15.1 AMDC Holding Limited, located at Flat 1005, Block A, 10/F, New Mandarin Plaza, 14 Science Museum Road, Tsim Sha Tsui, Kowloon, is the company responsible for collection, use, and disclosure of your Personal Information under this Privacy Policy.

15.2 If you have any questions about this Privacy Policy, please contact us at enquiry@dropsystem.io, or AMDC Holding Limited, Flat 1005, Block A, 10/F, New Mandarin Plaza, 14 Science Museum Road, Tsim Sha Tsui, Kowloon.