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The GrowthOps group of companies operating in Asia (referred to as "GrowthOps", "we" or "our") are committed to protecting your Personal Information in accordance with applicable data protection and privacy laws in the jurisdictions in which we operate. This Privacy Policy ("Policy") applies to all visitors to our website at www.growthops.asia ("Website"). By using our website, you consent to the data practices described in this Policy.

This Privacy Policy describes the manner in which GrowthOps collects, holds, uses and discloses Personal Information in accordance with applicable data protection laws.

Modifications

GrowthOps reserves the right to review, modify and/or update this Policy from time to time, including to take into account new laws, regulations and technology and therefore, we encourage you to periodically review the latest version of this Policy. All Personal Information held by GrowthOps will be governed by our most recent Privacy Policy, posted on our website.

WHAT IS "PERSONAL INFORMATION"?

"Personal Information" means information about an identified individual, or an individual who is reasonably identifiable, whether the information is true or not, and whether recorded in a material form or not.

WHAT PERSONAL INFORMATION DO WE COLLECT AND HOLD?

GrowthOps collects and holds Personal Information such as your name, gender, date of birth, age, contact details (including your address, phone number and email, whether personal or for work), financial information, payment details, bank account details, passport number, tax identification number and/or products and services information and preferences and any other data that you provide voluntarily.

WHY DO WE COLLECT PERSONAL INFORMATION?

GrowthOps collects Personal Information from customers, officers, employees, contractors, consultants, service providers, agents, shareholders and other individuals that is reasonably necessary for one or more of our functions or services, including in order to allow us to conduct our business functions, to market and sell our products and services, to conduct officer, employee, contractor, consultant, service provider, agent or shareholder related activities and to conduct product and market research related activities, and for such reasonable purposes as described in the “How GrowthOps Uses Personal Information” section below.

If you choose not to provide your Personal Information to GrowthOps, we may not be able to undertake certain activities for you such as providing you with requested information, products or services.

WHEN AND HOW DO WE COLLECT PERSONAL INFORMATION?

GrowthOps collects Personal Information when you: become an officer, employee, contractor, consultant, service provider or agent of GrowthOps, visit our website, supply, use, or buy products or services, request information about us or our products or services, provide feedback, contract with us, become or apply to become a shareholder, fill in a form on our website, fill in one of our surveys, or contact us by telephone, facsimile, email, post or in person.

By submitting your information to us, you hereby give your consent to the collection and processing of your Personal Information for the purposes set out herein. You hereby warrant and represent to us that (a) Personal Information which you disclose to us is accurate and complete; and (b) where you volunteer Personal Information of another person to us, that you are authorized by such other person to disclose such Personal Information to us, and that such Personal Information is accurate and complete.

Our website and our related services are not intended for those under 18, and we do not knowingly collect information from those under the age of 18. Those under 18 should not submit any personal information without the permission of their parents or guardians. By using the website and our related services, you are representing that you are at least 18 years old.

GrowthOps may also collect Personal Information about you via third parties including our suppliers, merchants, survey providers or marketers.

In some circumstances we may receive Personal Information that we have not requested. If this occurs, we will comply with our obligations under applicable data protection laws. If we retain any Personal Information we have not requested, we will treat it in accordance with this Policy.

You acknowledge that we may de-identify and/or destroy this information unless we are required to keep it by law.

INFORMATION COLLECTED VIA OUR WEBSITE

When you visit our website, GrowthOps collects some Personal Information that you knowingly provide, and also collects certain information automatically through cookies, analytics tools, web beacons and server logs, as described below. Where information collected automatically (such as your IP address or other online identifiers) can be used, alone or in combination with other information, to identify you, we treat it as Personal Information and handle it in accordance with this Policy. For example, GrowthOps may collect Personal Information from users when they:

(a) complete an online form on our website; and/or

(b) complete one or more of our surveys; and/or

(c) otherwise correspond with GrowthOps.

Click Stream Data

When you visit and browse our website, our website host may collect Personal Information for statistical, reporting and maintenance purposes. The Personal Information collected by our website host will not be used to identify you unless permitted under this Policy. The information may include:

(a) the number of users visiting our Website and the number of pages viewed;

(b) the date, time and duration of a visit;

(c) the IP address of your computer; or

(d) the path taken through our Website.

(e) GrowthOps' Website host uses this information to administer and improve the performance of our Website.

Cookies

In operating this website, we may monitor the use of our website through the use a technology called "cookies". Cookies are small text files that are transferred to a user's computer hard drive by a website for the purpose of storing information about a user's identity, browser type or website visiting patterns.

Cookies involve the collection of information about you (which may or may not be Personal Information) in a way which may not be obvious to you. Generally, the information collected through cookies relates to a device used to access online content, such as an IP address or location data about the device. Cookies may also collect information about the behaviors of the use of the device, such as the websites visited by the user and their activity on the website. In some circumstances, the information collected through cookies may be combined with information that identifies the end use of the relevant device. Any Personal Information we collect in this way is handled in accordance with this Privacy Policy.

If you access our website, a cookie is downloaded onto your computer's hard drive when you first log on to our website. You can adjust your internet browser to disable cookies, however GrowthOps may not be able to provide you with all the service or functionality you require on our website if you choose to do so.

Cookies Policy

You are entitled to your choices regarding Cookies. If you prefer to avoid the use of Cookies on the website, first you must disable the use of Cookies in your browser and then delete the Cookies saved in your browser associated with this website. You may use this option for preventing the use of Cookies at any time.

If you do not accept our Cookies, you may experience some inconvenience in your use of the Website, and some features may not function properly.

If you'd like to delete Cookies or instruct your web browser to delete or refuse Cookies, please visit the help pages of your web browser.

For the Chrome web browser, please visit this page from Google: https://support.google.com/accounts/answer/32050

For the Internet Explorer web browser, please visit this page from Microsoft: https://support.microsoft.com/en-us/edge/manage-cookies-in-microsoft-edge-view-allow-block-delete-and-use

For the Firefox web browser, please visit this page from Mozilla: https://support.mozilla.org/en-US/kb/delete-cookies-remove-info-websites-stored

For the Safari web browser, please visit this page from Apple: https://support.apple.com/guide/safari/manage-cookies-and-website-data-sfri11471/mac

For any other web browser, please visit your web browser's official web pages.

Web Beacons

Web beacons are images that originate from a third-party site to track visitor activities. GrowthOps may use web beacons to collect aggregate data and provide this information to our website host to administer and improve the performance of our website.

HOW GROWTHOPS USES THE PERSONAL INFORMATION IT COLLECTS ABOUT YOU

GrowthOps uses the Personal Information it collects about you for our business functions and activities, which may include the following purposes:

to provide you with information, products or services you have requested; to promote and market our products and services to you; to personalise and customise your experiences on our website; to help GrowthOps research the needs of its customers; to conduct research for the purposes of improving existing products or services or creating new products or services; to provide you with ongoing information about GrowthOps and its activities; to allow us to provide third party information and offers in which we believe you may be interested; to comply with regulatory or other legal requirements; for purposes related to the employment of our personnel and providing internal services to our staff; if you are a shareholder or apply to become a shareholder, to process your application, service your needs as a shareholder, provide facilities or services that you request, and administer your shareholding; and for any other purpose communicated to you at the time that the Personal Information was collected or for which you provided your consent. GrowthOps may use your Personal Information for a secondary purpose if that secondary purpose is related to those purposes in this clause, if we have your consent or if otherwise provided for under the applicable data law.

Direct Marketing

You are hereby informed that GrowthOps may use your Personal Information to provide you with direct, targeted, or other marketing materials on an ongoing basis. GrowthOps may provide you with these materials by telephone, electronic messages (e.g. email), our digital services and other means. GrowthOps will only provide you with direct marketing materials where you would reasonably expect us to, or if you consent to receive direct marketing materials. We will seek your consent to provide you with direct marketing materials if we obtain your Personal Information from a third party. Direct marketing communications may include promotional material about GrowthOps or may relate to the products and services of GrowthOps, and our related entities, which we provide, and other products and services which may be of interest to you.

Where required by law, we will comply with applicable do-not-call or marketing preference registers before sending marketing messages, unless you have given clear and unambiguous consent.

You may opt out of receiving direct marketing material by contacting us in any of the ways specified in the direct marketing materials or as set out in the “How to Contact Us” section below. Generally, we will only collect and use your Personal Information in accordance with this Policy. In the event that we collect or use Personal Information in ways other than as stated in this Policy, we will ensure that we do so in accordance with applicable data protection laws.

WHO DO WE DISCLOSE YOUR PERSONAL INFORMATION TO?

Depending on the nature of your engagement with GrowthOps, we may disclose your Personal Information to shareholders, officers, employees, contractors, consultants, agents of GrowthOps, third parties that provide products and services to or through GrowthOps or our website, directly to you (at your request), suppliers and other third parties, or otherwise as required by law.

GrowthOps may also disclose your Personal Information to our website host or software application providers in certain limited circumstances, for example when our website experiences a technical problem or to ensure that it operates in an effective and secure manner.

We may also share non-personal, de-identified and aggregated information for research or promotional purposes. We will not sell your Personal Information to third parties for marketing purposes.

Unless otherwise specified in this Privacy Policy, GrowthOps or GrowthOps' Website host will not disclose any of your Personal Information to any other organisation unless the disclosure is required by law or is otherwise permitted under applicable data protection laws.

TRANSFER OR DISCLOSURE OF YOUR PERSONAL INFORMATION OVERSEAS

Your Personal Information may be disclosed outside of your country to a GrowthOps group entity in a foreign country, including entities in which GrowthOps has an ownership interest or to a service provider in the business of providing data storage and processing services (which commonly involve diverse geographic locations which change from time to time, which means it is not practical for us to notify you of which country your Personal Information may be located in). It is possible that entities with whom we share your information outside your country may be subject to foreign laws that do not provide the same level of protection of Personal Information as in your country. We will however ensure that any party to whom we transfer your Personal Information outside your country provides to such personal data a standard of protection at least comparable to the protection under the data protection laws of your country.

By providing your Personal Information, you acknowledge that you understand the risks associated with the disclosure of your Personal Information overseas and expressly consent to the disclosure of your Personal Information to an overseas entity.

STORAGE AND SECURITY OF PERSONAL INFORMATION HELD BY GROWTHOPS

GrowthOps views the protection of privacy as a serious matter. GrowthOps will take reasonable steps by implementing generally accepted standards of technology and operational security to protect your Personal Information from misuse, interference and loss and from unauthorised access, modification or disclosure.

GrowthOps aims to keep your Personal Information secure and up to date. We will comply with our obligations under applicable data protection laws in relation to any Personal Information that we handle, including information which is held on GrowthOps' computer systems. Personal Information that is held by GrowthOps in hard copy is stored securely on its premises and is only disclosed or used for the purposes described in this Policy. Although we will do our best to protect your Personal Information, we cannot guarantee the security of your data transmitted to our Website or that hackers or unauthorised personnel will not gain access to your Personal Information despite our efforts. You should note that in using the Website and our related services, this information will travel through third party infrastructures which are not under our control. Hence, we cannot be held responsible for unauthorised or unintended use, access or disclosure that is beyond our control and you acknowledge that any transmission of data to our Website is done at your own risk.

All GrowthOps personnel follow a strict internal security policy. Only authorized GrowthOps personnel are provided access to personally identifiable information and these personnel have agreed to ensure confidentiality of this information.

DATA BREACH NOTIFICATION

In the event of a data breach involving your Personal Information that is likely to result in significant harm or is otherwise notifiable under applicable law, we will notify the relevant regulator and, where required, affected individuals, in accordance with the timeframes and thresholds prescribed under applicable data protection laws.

HOW LONG WILL GROWTHOPS KEEP YOUR PERSONAL INFORMATION?

We will keep your Personal Information only for as long as required for our business purposes and otherwise as required by any applicable law.

Where we no longer need to keep your Personal Information, we will take reasonable steps to destroy or de-identify your Personal Information. If you wish to have your Personal Information destroyed or de-identified, please let us know by contacting GrowthOps using the contact details in the “How to Contact Us” section below and we will take reasonable steps to do so (unless we need to keep it for legal, auditing or internal risk management reasons).

UPDATING AND CORRECTING YOUR PERSONAL INFORMATION

We will take reasonable steps to ensure that the Personal Information that we hold is accurate, up-to-date and complete. You have a right to request your Personal Information to be corrected. You can update your Personal Information at any time by contacting GrowthOps using the contact details in the “How to Contact Us” section below. GrowthOps welcomes any changes to your Personal Information so as to keep our records up to date.

FINDING OUT WHAT PERSONAL INFORMATION GROWTHOPS HOLDS ABOUT YOU

You are entitled to access Personal Information that GrowthOps holds about you. If you request access to your Personal Information, we will grant your request unless providing you with access would unreasonably impact upon the privacy of others or is not otherwise permitted at law. If we refuse your request to access your Personal Information, we will provide you with written reasons for the refusal. Subject to the provisions of the applicable data protection laws, we may charge for a request for access. In the event a fee is to be charged, we will inform you of the amount beforehand and respond to your request after payment is received.

A request for access can be made by contacting GrowthOps using the contact details in the “How to Contact Us” section below.

HOW TO CONTACT US ABOUT PRIVACY

If you have any questions, concerns or requests regarding this Policy or your Personal Information, please contact our legal department in any of the following ways:(a) Email: privacy@growthops.asia

(b) Write to: GrowthOps, 1 Neil Road, #02-02, Singapore 088804 or Unit 27.2, Menara 1MK, Kompleks 1 Mont Kiara, No. 1, Jalan Kiara, Mont Kiara, 50480 Kuala Lumpur Wilayah Persekutuan

You may withdraw your consent to our collection, use or disclosure of your Personal Information at any time by contacting our privacy department, subject to legal or contractual restrictions and reasonable notice.

As stated hereinabove, you may contact our privacy contact team for any of the following reasons:

(a) you wish to access your own Personal Information;

(b) you wish to update or correct your own Personal Information;

(c) you wish to withdraw consent in respect of our collection, use or disclosure of your Personal Information; and for any other reason listed hereinabove.

(d) for any other reason related to your Personal Information or this Policy.

GrowthOps will review and respond to your complaint as soon as possible, generally within 30 days of receiving it. If we do not resolve your complaint to your satisfaction and no other complaint resolution procedures are agreed or required by law, we will inform you that your complaint may be referred to the relevant data protection authority for further investigation and will provide you with the relevant contact details.

WHAT ARE YOUR DATA PROTECTION RIGHTS

GrowthOps undertakes to respect your Personal Information and we would like to make sure that you are fully aware of your data protection rights. Subject to applicable law, you may have the following rights:

(a) Right to access. You have the right to request copies of your Personal Information. We may charge a small fee for this service.

(b) Right to correction. You have the right to request that we correct or update any information that you believe is inaccurate, or complete information you believe is incomplete.

(c) Right to data portability. Where applicable, you have the right to request that we transfer the data we have collected from you to another organisation, or directly to you.

(d) Right to withdraw consent. You may withdraw consent previously given for the collection, use or disclosure of your Personal Information.

(e) Right to prevent direct marketing. You may require us to stop, or not begin, using your Personal Information for direct marketing purposes.

Disclaimer

Privacy Policy of other third-party websites. This Privacy Policy only applies to our website and not to any third-party sites. Our website may contain certain links to other websites which are maintained by third parties. When visiting other third-party websites, please ensure that you read their own privacy policies before disclosing your personal data to them. GrowthOps makes no representations as to accuracy or any other aspect of information contained in other third party websites.

In no event will GrowthOps, its related entities, partnerships or corporations, or the partners, agents, officers or employees thereof be liable to you or anyone else for any consequential, special, punitive, indirect, incidental or similar damages, or for any loss of reputation or goodwill, whether based in contract, tort (including negligence), equity, strict liability, statute or otherwise, even if advised of the possibility of such damages, as a result of unauthorised or unintended use, access or disclosure of your Personal Information.

Last updated: 25 September 2026