Fintastic App Privacy Policy

Last modified: 21 February 2023

Introduction

Livingtone Overseas Inc. (“Company” or “We“) respect your privacy and are committed to protecting it through our compliance with this policy. This policy describes:

• The types of information we may collect or that you may provide when you download, install, access, or use the Fintastic App (the “App“).
• Our practices for collecting, using, maintaining, protecting, and disclosing that information.

This policy applies only to information we collect in this App and in email, text, and other electronic communications sent through or in connection with this App.

This policy DOES NOT apply to information that:

• We collect offline or on any other Company apps or websites, including websites you may access through this App.
• You provide to or is collected by any third party.

Our websites and apps, and these other third parties have their own privacy policies, which we encourage you to read before providing information on or through them.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, do not download, register with, or use this App. By downloading, registering with, or using this App, you agree to this privacy policy. This policy may change from time to time. Your continued use of this App after we revise this policy means you accept those changes, so please check the policy periodically for updates.

Children Under the Age of 16

The App is not intended for children under 16 years of age, and we do not knowingly collect personal information from children under 16. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at [email protected].

Information We Collect and How We Collect It

We collect information from and about users of our App:

• Directly from you when you provide it to us.
• Automatically when you use the App.
• From our third parties.

We may collect, use, store and transfer different kinds of personal data about you and for different purposes. For your use, we made the table with data categories, purposes of their use, and lawful bases for processing.

Data Type	Purposes of processing	Lawful basis of processing
App interactions	App functionality Analytics Advertising or marketing	Necessary to perform our contract with you. Necessary for our legitimate interests (to provide effective and personalized customer services to you and to update you in relation to our services that are available to you, etc.).
Crash logs	App functionality Analytics
Diagnostics	App functionality Analytics
Other app performance data	App functionality Analytics
Device or other IDs	App functionality Analytics Advertising or marketing
Identity and contact data	Communication with users by their request, e.g. when you report a problem with the App

Third-Party Information Collection

When you use the App or its content, certain third parties may use automatic information collection technologies to collect information about you or your device. These third parties may include:

• Advertisers, ad networks, and ad servers.
• Analytics companies.
• Digital distribution companies.

Link to privacy policy of third party service providers used by the App:

• Google Play Services
• Firebase Analytics
• Firebase Crashlytics and App Distribution Data Processing and Security
• Firebase Data Processing
• Appsflyer

These third parties may use tracking technologies to collect information about you when you use this App. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites, apps, and other online services websites.

Disclosure of Your Information

We may disclose aggregated information about our users, and information that does not identify any individual or device, without restriction.

In addition, we may disclose personal information that we collect or you provide:

• To our subsidiaries and affiliates.
• To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Company’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Company about our App users is among the assets transferred.
• To comply with any court order, law, or legal process, including to respond to any government or regulatory request.

Cross-Border transfers of your Personal Data

Where we transfer your personal data outside of the British Virgin Islands, we will ensure that it is protected and transferred in a manner consistent with legal requirements applicable to the information and where required, with your consent.

We may put in place appropriate safeguards (such as contractual commitments) in accordance with applicable with applicable data protections laws to ensure that your personal data is adequately protected. We may during the course of business transfer and store your personal data to a web hosting and/or cloud service provider, which may be located outside of the British Virgin Islands. You can request further details about the safeguards that we have in place in respect of transfers of personal data outside the British Virgin Islands.

Retention of Your Personal Data

We retain your personal data for the length of time required for the specific purpose or purposes for which it was collected.

Protection of Your Personal Data

We take the security of our physical premises, our servers and the App seriously and we take all appropriate technical measures using recognized security procedures and tools in accordance with good industry practice to protect your personal information.

We use technical and organizational security measures in order to protect the personal data we have under our control against accidental or intentional manipulation, loss, destruction and against access by unauthorised persons.

Your Rights

Your rights in relation to the personal data include:

Right to Access: You have the right request a confirmation from us as to whether or not we process your personal data and forward you a copy of same. You also have the right to certain other supplementary information that this Privacy policy is already designed to address. Please note that there may be circumstances in which we are entitled to refuse requests for access to copies of personal information. In particular, information that is subject to legal professional privilege will not be disclosed other than to our users and as authorised by our users.

Right to Rectification: You have the right to have your incomplete personal data completed.

Right to Erasure: This provides for the right to have your data erased in case the processing of your personal data is not justified. Please note that there may be circumstances where you ask us to erase your personal information, but we are legally entitled/obliged to retain it.

Right to Restrict: You have the right to restrict the processing of your personal data.

Right to Object: In some cases, required by law, you may ask us to stop processing your personal data.

Right of Portability: You have the right to receive the personal data concerning you in a structured, commonly used, and machine-readable format and/or transmit those personal data to another data controller.

Withdrawal of consent: You have the right to withdraw your consent at any point in time, although in certain circumstances it may be lawful for us to continue processing without your consent if we have another legitimate reason (other than consent) for doing so. Withdrawal will not affect the lawfulness of processing before the withdrawal.

Right to Compliant: You have the right to lodge a complaint regarding the processing of your personal data by us.

If you want to exercise your rights or you are unhappy with the way in which your personal data has been processed or should you have any questions regarding the processing of your personal data, you may refer in the first instance to the data controller, who is available, at the following email address: [email protected] or you can write to the address below: Intershore Chambers, P.O. Box 4342, Road Town, Tortola, British Virgin Islands.

Your requests can be sent to us in a free form (in the body of a letter, scan, etc.) to [email protected] with your full name and contact information for a quicker processing of your request. In case of doubt of your identity, we may ask you to justify it by enclosing a copy of any identity document. If we are not satisfied you are who you claim to be, we reserve the right to refuse to grant your requests.

Changes to this Privacy Policy

The App and/or any other information displayed on the App may change from time to time. As a result, at times it may be necessary for us to make changes to the App and this Privacy policy. You will be notified of important changes to the Privacy policy regarding the purposes of the processing, the identity of the controller, how rights are exercised, and cross-border transfers. Such notification will be made within a reasonable time before the changes take effect.

You may request a copy of this privacy policy from us using the contact details set out above. If we change this Privacy policy, the updated version will be posted in a timely manner.

Contact Us

Data Controller

Livingtone Overseas Inc.

Address: Intershore Chambers, P.O. Box 4342, Road Town, Tortola, British Virgin Islands

Email: [email protected]