In this Privacy Policy, "Personal Data" refers to any data, whether true or not, about an individual who can be identified (a) from that data; or (b) from that data and other information to which we have or are likely to have access.

We will obtain Personal Data about your authorised person(s), authorised user(s) (i.e. any individuals authorised to use your account on the Platform ("Account") and/or Services on your behalf) of our Platform, directors, officers, legal representatives, company secretaries, shareholders, beneficial owners, employees, personal guarantors, debtors, customers or counterparties or any other individuals in relation to which you provide information to us ("Relevant Individuals") ("your Personal Data").

Examples of Personal Data include but are not limited to:

• full name;
• NRIC, passport or other identification number;
• date of birth;
• bank account numbers;
• Account passwords; and
• contact information such as address, phone number and email address.

We will only collect your Personal Data in a lawful manner and when we have a valid reason to do so. The provision of your Personal Data is voluntary. If you do not provide such Personal Data to us, we may not be able to provide you with the Services or use of the Platform. We collect your Personal Data:

• when you enter into any agreement or provide documentation or information to us to be onboarded as our client;
• when you register or create an Account with, or use our Services via, our Platform;
• when you interact with us through our staff and/or automated systems, for example,
• via telephone calls, letters, text messages, fax, face-to-face meetings, and e-mail;
• when you enter into any agreement on our Platform, including offer letter, receivables purchase agreement, personal or corporate guarantee or any other documents ancillary to the Services;
• when you submit any documents containing Personal Data through our Platform, including invoices, notices of assignment, proof of delivery of goods,board resolutions, standing instruction letters, etc.;
• when you engage with us or our service providers in response to our marketing activities;
• where allowed under applicable law, when we seek information about you regarding your relationship with us and receive your Personal Data (for example, from business partners, public agencies and the relevant third parties);
• from third-party sources to which you or the Relevant Individuals have given consent or if the collection of the Personal Data is necessary to comply with applicable data protection laws (e.g. credit agencies or law enforcement agencies); and
• when you send your Personal Data to us for any other reason.

We may collect your information when you browse or use our website and Platform. Please see the section below on “Use of Cookies and Related Technologies” for more information.

If you provide us with any Personal Data of any Relevant Individual, you represent that you have obtained the consent and/or permission, as required under applicable laws and regulations, from such Relevant Individual, for you to provide us with their Personal Data for applicable purposes under this Privacy Policy and the Capata Platform Terms of Use.

You should ensure that all Personal Data sent to us is complete, accurate, true and correct. Failure to do so may prevent us from providing you with the Services. In the event of any change to the information provided to us, you should inform us immediately. Please see the section below on “Contact Us”.

We must be transparent in how your Personal Data is used so that you can trust us. Capata collects, uses and discloses your Personal Data for the following purposes:

• establishing and verifying your Relevant Individuals' identity, and conducting relevant due diligence checks on the Relevant Individuals to the extent necessary to onboard you as our client;
• opening, maintaining, managing, continuing or closing your Account(s) on the Platform;
• providing you with the Services, including:
• authenticating and verifying your identity at login;
• reviewing electronic legal agreements executed on the Platform;
• approving your funding application and disbursements;
• processing invoices uploaded to the Platform and processing, analysing and comparing information or data extracted from such invoices;
• integrating with and enabling the Connected Account Services (as defined in the Capata Platform Terms of Use); and
• facilitating the transfer of funds or payment settlement, and responding to requests from banks, payment intermediaries or our service provider(s) relevant to this purpose;
• providing, personalising, facilitating, and improving your use of the Platform;
• reaching out to and managing our relationship with you, and managing and responding to your queries, requests and feedback;
• data analytics, visualisation of data, report generation for our internal use and your reference, as the case may be;
• managing our administrative and business operations, and preparing internal reporting and audits;
• facilitating corporate restructuring processes and business asset transactions (which may extend to any mergers, acquisitions or asset sales) involving any of the Companies;
• conducting marketing and promotional events, competitions, campaigns and offers;
• requesting feedback or participation in surveys, conducting market research or analysis for statistical, profiling, reconciliation or other similar purposes;
• preventing, detecting, and investigating crime (including fraud, money-laundering and terrorist financing);
• analysing and managing risks, including taking out, maintaining, complying with and/or making any claim under any insurance;
• collecting receivables from and/or enforcing payment obligations of any debtors, or enforcing any security made available to us (including any personal guarantee);
• in connection with any claims, actions or proceedings (including drafting and reviewing documents, obtaining legal advice, and facilitating dispute resolution), and in protecting and enforcing our contractual and legal rights and obligations;
• training our employees to provide better products and services to you;
• complying with (a) any applicable rules, laws, regulations, notices, codes of practice or guidelines issued by any legal or regulatory bodies which are binding on us, or which we have been advised, recommended or informed that we are expected to comply with (including (i) making disclosures to regulatory bodies, (ii) conducting audit checks, surveillance and investigations, and (iii) assisting law enforcement or investigations by relevant authorities); and (b) internal policies;
• understanding customer behaviour, preferences, and market trends, and personalising your experience;
• to market Capata, the Companies, and our Services, events and products;
• developing and enhancing existing and future products and services; and
• any other reasonable purpose relating to the above.

We will seek your consent if we need to use your Personal Data for new purposes.

We take the confidentiality and disclosure of Personal Data seriously. We will only share your Personal Data with selected third parties. When we disclose your Personal Data to such third parties, we require them to ensure that such Personal Data is kept confidential and secure. Where applicable, your Personal Data may be disclosed for the purposes listed above to the following entities or parties, whether they are located overseas or in Singapore:

• the Companies, their respective employees, and our Representatives;
• current and potential third-party funder(s);
• any person or organisation providing services to us;
• counterparties and their respective banks concerning fund transfers, payments, and other transactions;
• companies providing services relating to insurance and reinsurance to Capata;
• any person or organisation (including agents, contractors, and third-party service providers) to which we outsource certain functions or activities, such as telecommunications, information technology, payment, training, market research, storage, archival, customer support and investigation services;
• analytics or other third-party service providers that help us deliver, improve and optimise our products, services,websites and platforms;
• credit reporting agencies;
• any business partner, investor, assignee or transferee (actual or prospective) to facilitate business asset transactions (which may extend to any merger, acquisition or any debt or asset sale) involving any of the Companies;
• other banks, financial institutions, credit agencies and their respective service providers;
• our professional advisors such as our auditors and lawyers;
• relevant government regulators, ministries, statutory boards or authorities, law enforcement agencies and public officers, whether local or overseas, including the Monetary Authority of Singapore (MAS), the Accounting and Corporate Regulatory Authority (ACRA), the Singapore Police Force (SPF), the Personal Data Protection Commission (PDPC) and the Ministry of Law;
• foreign embassies and foreign credit reporting agencies;
• any other party to whom you authorise us to disclose your information or Personal Data of your Relevant Individuals; and
• where necessary, to any person, organisation, corporation, firm, partnership, limited partnership, limited liability partnership, society, association, trade union, institution or other business concern, whether local or foreign.

Your Personal Data will be retained if a purpose for which it was collected remains valid, and for other legal or business purposes for which retention of such Personal Data may be necessary.

In addition to consent for the collection, use, and disclosure of your Personal Data, Capata may also, where permitted by applicable law, collect, use, and disclose such Personal Data without consent:

• for our or a third-party's legitimate interests such as:
• improving anti-money laundering and financial crime risk management;
• detection and prevention of fraud, financial crime, and other illegal activities;
• detection of threats to safety and security (including IT and network security); and
• prevention of misuse of products and services;
• to perform credit analysis and other necessary due diligence checks;
• to improve the Companies' products, services, processes or business, understand your preferences, and personalise experiences and recommendations; and
• pursuant to deemed consent, exceptions, or when required or authorised to under applicable laws.

Our Platform uses cookies, pixel tags and related technologies. Cookies are files stored on your web browser or electronic device. They are used to enable certain functions on our website, such as remembering your preferences and other information. Pixel tags are unobtrusive graphics that keep track of your interactions with our Platform. Our Platform may also use tracking links to help us understand your preferences.

We may employ cookies, pixel tags and related technologies for the following purposes:

• to understand activities and run our Platform, such as enabling you to login and navigate our Platform;
• understanding and remembering your settings and preferences;
• compiling statistical reports on Platform activity, and
• enhancing the use, effectiveness and performance of our Platform; and
• detecting irregular or suspicious activities, and ensuring our compliance with any applicable laws.

We are constantly innovating to enhance your user experience, ensuring that it is seamless and secure. Our use of various technologies, like artificial intelligence, facilitates our operation of the Platform and provision of the Services, actively guards against fraud, streamlines our communications with you, tailors our offerings to fit your needs and ensures that we offer you suitable products and services.

While we strive to protect your Personal Data, there are risks when electronic services are used. Capata is unable to guarantee the security of any Personal Data collected from or about you, including against any attacks from malicious programmes, or any security breach on the part of third parties whom we engage and disclose your Personal Data to in order to provide products or services to you or to carry out our obligations under applicable law.

You acknowledge that you play an important role in safeguarding your Personal Data. It is recommended that you choose a password of sufficient length and complexity when registering with and using the Platform. You are responsible for your own security when dealing with third parties, including third parties who may make themselves out to be Capata or related to Capata.

To contact us regarding your Personal Data, our Privacy Policy, withdrawal of your consent, or obtaining access and making corrections to your Personal Data, please contact compliance@capata.sg.

You may withdraw your consent for collecting, using and disclosing your Personal Data. If you withdraw your consent, Capata may not be able to continue to provide its products or services to you, administer any contractual relationship already in place, or perform or conclude an existing or prospective agreement. This may result in the termination of any agreements you have with Capata and your breach of contractual obligations or undertakings. In such an event, we reserve our legal rights and remedies.

Please note that if a third-party provided your Personal Data to us (e.g. The Central Depository (Pte) Limited), you should contact such third-party directly to make any queries, feedback, and access and correction requests to us on your behalf.

This Privacy Policy is governed by the laws of Singapore.