NGMT Limited and ImaKOL Market Limited, together with their subsidiaries or affiliated companies (collectively referred to as "we," "us," "NGMT," or "our"), are committed to safeguarding the privacy of our Merchants, KOLs, Consumers, Guests, and their authorized representatives ("Subscribing Organizations" or "Members") in accordance with Hong Kong's Personal Data (Privacy) Ordinance (PDPO) and its subsidiary legislation and regulations, as amended from time to time ("Applicable Laws"). This Privacy Policy ("Policy") outlines our practices for collecting, using, processing, disclosing, and protecting Personal Data through our Platforms, which include the website (www.imakol.com), ImaKOL mobile application, ImaKOL mobile apps on iOS and Android, and related social media accounts on platforms such as Instagram, Facebook, TikTok, X, Threads, Pinterest, and YouTube (collectively, the "Platforms").

This Policy applies to all Personal Data we collect from you through our Platforms and is intended to help you make informed decisions about providing us with your Personal Data. By using our Platforms, clicking "Yes" or "Accept" on our Policy pop-up or any web form referencing this Policy, submitting Personal Data when signing up for an account, browsing our Platforms, ordering products or services, participating in competitions or promotions, enrolling in any NGMT programs, or otherwise engaging with our services, you agree to the terms of this Policy. We may also collect and process your Personal Data under exceptions to Applicable Laws not outlined in this Policy.

We may update this Policy to reflect changes in our practices, industry trends, or legal and regulatory requirements. Updates will be posted on the Platforms, and we will endeavor to notify you of material changes via email or in-app notices. Continued use of the Platforms or services after updates constitutes acceptance of the revised Policy.

For the purposes of this Policy, the following capitalized terms shall have the meanings below:

• Applicable Laws: Hong Kong's Personal Data (Privacy) Ordinance (Cap. 486) and its subsidiary legislation and regulations, as amended from time to time.
• Consumer: An individual or entity purchasing products or services from Merchants on the Platforms.
• KOL: An individual or entity, such as a Key Opinion Leader (KOL) or influencer, who creates and shares content on the Platforms or Social Media to promote products, services, or brands. KOLs may also utilize the Service's SaaS subscription features for managing marketing campaigns, analytics, and Sponsor connections.
• Guest: An individual or entity browsing the Platforms without registering an Account.
• Merchant: An entity or individual that (a) supplies goods or services listed on the Platforms, including but not limited to electronics, fashion, health and beauty, or other general merchandise, for sale to Consumers, and provides shipping or logistics for such products; (b) subscribes to SaaS Services to manage marketing campaigns, analytics, and KOL connections; and/or (c) sponsors marketing campaigns on the Platforms, engaging KOLs to promote their products or services.
• Personal Data: Any data, whether true or not, which is (a) about an individual who can be identified (i) from that data; or (ii) from that data and other information to which we have or are likely to have access, including data in our records as updated from time to time, or (b) defined as "personal data" or "personal information" under Applicable Laws. Examples include names, contact details, mailing and delivery addresses, email addresses, birthdays, payment information, network and device data, shopping or browsing behaviors, facial images, voice recordings (e.g., for customer service calls), and any other personally identifiable information.
• Your Content: KOL profiles, audience analytics, sponsored content, campaign data, and other user-generated content uploaded to the ImaKOL Platforms.
• Sponsors: Third-party brands or entities, including Merchants, collaborating with KOLs through the ImaKOL Platforms.
• Service: The SaaS subscription services provided by NGMT Limited for managing KOL marketing, campaigns, analytics, sponsor connections, and related activities, available to both Merchants and KOLs via the ImaKOL Platforms.
• Retail Goods and Services: Sales of goods or provision of services in categories such as electronics, home appliances, fashion, health and beauty, groceries, furniture, sports equipment, and other general merchandise, whether through physical or online channels or any media now known or available in the future, offered via the ImaKOL Platforms.
• Platforms: Collectively, the website (www.imakol.com), ImaKOL mobile application, ImaKOL mobile apps on iOS and Android, NGMT's social media accounts, and any other websites or applications we may own or operate from time to time.
• Social Media: NGMT's pages and accounts on third-party social media platforms such as Instagram, Facebook, TikTok, X, Threads, Pinterest, and YouTube.

If you provide us with Personal Data relating to a third party, you represent that you have obtained their consent to share their Personal Data with us for the relevant purposes.

We collect Personal Data from you in the following circumstances:

• Account Registration: When you register an account on the website (www.imakol.com) or ImaKOL/ImaKOL apps.
• Subscriptions and Updates: When you sign up for newsletters, product notifications, or updates.
• Transactions: When you make a transaction for products or services on our Platforms or through third-party service providers.
• Payment Functions: When you use payment-related functions on our Platforms, such as credit card payments, bank transfers, or e-wallet payments.
• Program Enrollment: When you enroll in NGMT programs, such as merchant, affiliate, loyalty, or point redemption programs.
• Browsing and Interaction: When you browse our products, interact with our Platforms, or accept cookies on your device.
• Customer Service: When you interact with our Customer Service Team or representatives via chatbot, chat apps, messaging platforms, web forms, emails, telephone calls, video calls, letters, or face-to-face meetings.
• Social Media Engagement: When you engage with us on Social Media by liking, commenting, or messaging us, or interact with our livestream channels.
• Promotions and Surveys: When you participate in promotions, competitions, lucky draws, or customer surveys.
• Referrals: When we receive referrals from business partners or third parties, such as joint promotions or voucher redemptions.
• Authorized Submissions: When you or your authorized representative submit Personal Data for purposes you authorize, such as purchasing products for delivery or as a gift.
• Third-Party Providers: When third-party analytics or service providers share your Personal Data with us, collected under their privacy policies.
• Voluntary Submission: When you voluntarily submit Personal Data to us for any reason.
• IP Addresses: We use IP addresses to diagnose server issues, administer the Platforms, provide technical support, and track page requests for Service optimization.
• KOL and Campaign Data: For ImaKOL users, we collect Your Content, including KOL profiles (e.g., social media metrics, audience demographics), campaign data (e.g., performance metrics, sponsored content), and payment details for subscriptions or sponsorship payments.
• Demographic Information: We collect demographic data (e.g., industry, organization size, KOL audience demographics) to customize user experiences, develop features, and improve services.

We will notify you when providing Personal Data is mandatory. Failure to provide mandatory Personal Data may prevent us from delivering our services to you. We may also request voluntary Personal Data to improve our Platforms and services, which you are not obligated to provide. We may collect Personal Data in circumstances where consent is not required under Applicable Laws.

Please ensure that all Personal Data submitted to us is complete, accurate, true, and correct. Failure to do so may prevent us from providing the requested products or services.

We may use and disclose your Personal Data for purposes necessary to provide our products and services (collectively, the "Purposes"), including to:

• Register and maintain your user account and verify your identity or age.
• Process orders, payments, and deliveries, including couriers contacting you for delivery instructions.
• Verify and process payment transactions (e.g., credit card, bank transfers, or e-wallet payments) through third-party payment providers.
• Facilitate payment-related services, subscriptions, or sponsorship payments.
• Process returns or refunds per our Terms and Conditions.
• Address inquiries, resolve complaints, and respond to your queries, requests, feedback, or account-related matters.
• Provide supporting services, such as saved items, wish lists, product notifications, or KOL selection and campaign management.
• Administer loyalty, referral, or point redemption programs.
• Manage competitions, communicate related terms, requirements, or winner announcements, and process participation in promotions or surveys.
• Notify you of material changes to our Terms of Service or this Policy.
• Personalize and enhance your experience on our Platforms, such as prioritizing products in search results or customizing content based on preferences.
• Monitor and enforce compliance with our Terms and Conditions, including dispute resolution and advertising disclosure laws (e.g., requiring #ad or #sponsored in sponsored content).
• Comply with internal risk controls, payment processing terms, or Applicable Laws.
• Ensure Platform functionality and improve performance through debugging, statistical analyses, and Service optimization.
• Facilitate communication between KOLs and Sponsors for campaign purposes on the ImaKOL Platforms.

We may also use and disclose your Personal Data for additional purposes (collectively, the "Additional Purposes"), including to:

• Send marketing communications about our Retail Goods and Services, Service, promotions, events, competitions, or loyalty programs.
• Send marketing communications about business partners' Retail Goods and Services or promotions.
• Deliver targeted ads for our Retail Goods and Services or Service on our Platforms or other websites, apps, or online platforms.
• Enable business partners to deliver targeted ads for their Retail Goods and Services.
• Provide premium services, such as VIP programs or premium KOL features.
• Invite you to exclusive customer events.
• Conduct market and customer research, analysis, or tracking.
• Promote our products, services, or Service on our Platforms.
• Manage administrative and business operations and comply with internal policies.
• Improve customer experience and train our Customer Service Team, including recording and monitoring calls.
• Develop features, premium services, and content relevant to users.
• Process specific purposes related to particular products or services, as notified on the product or service page.

We may also use your Personal Data (a) for purposes reasonably related to the Purposes or Additional Purposes with your consent, or (b) where consent is not required under Applicable Laws. We will not use your Personal Data for marketing communications without your consent.

For the Purposes or Additional Purposes, we may disclose your Personal Data to:

• NGMT's affiliated entities.
• Employees, consultants, or temporary workers.
• ImaKOL Merchants who supply and deliver your ordered products or services or sponsor marketing campaigns.
• Payment processors handling payments on the Platforms.
• Third-party payment service providers offering payment-related services.
• Third-party logistics providers, such as couriers delivering your orders.
• Business partners maintaining accounts for loyalty, referral, or point redemption programs.
• Business partners or vendors processing promotions, competitions, or loyalty programs.
• Sponsors, including Merchants, collaborating with KOLs on the ImaKOL Platforms, with KOL consent.
• Professional advisers and consultants providing legal or advisory services.
• Agents, contractors, or service providers offering operational services, such as cloud storage, marketing optimization, IT, telecommunications, or security.
• Any party you authorize us to share your Personal Data with.

We may also disclose your Personal Data (a) for purposes reasonably related to the Purposes or Additional Purposes with your consent, or (b) where consent is not required under Applicable Laws. We minimize disclosure to only the information necessary for the related Purpose or Additional Purpose.

We do not sell or rent Personal Data or Your Content to third parties. We will only disclose Personal Data outside NGMT without your consent if we have a good-faith belief that disclosure is reasonably necessary to:

• Comply with Applicable Laws, regulations, legal processes, or enforceable governmental requests (e.g., court orders, subpoenas).
• Enforce our Terms and Conditions, including investigating potential violations.
• Detect, prevent, investigate, or address fraud, harmful or illegal activity, or security issues.
• Protect the rights, property, or safety of NGMT, our users, third parties, or the public, as required or permitted by law.

In such cases, we will notify you where feasible and safeguard your data to the extent possible. We may also share aggregated, anonymized data (e.g., Service usage statistics) with partners or advertisers to describe our Platforms or improve offerings. Personal Data or Your Content shared with third parties (e.g., Sponsors or Merchants) at your request is subject to their privacy policies, and NGMT is not responsible for their practices. We minimize disclosure to only the information necessary for the related Purpose or Additional Purpose.

We use cookies to personalize the Platforms, troubleshoot issues, and enhance user experiences. Cookies are small data files stored on your device for record-keeping, identifying your device but not you personally, and are active only during browser sessions. Third-party partners (e.g., analytics providers, advertisers) may use their own cookies or trackers to collect data, such as browsing behavior or ad views, which are subject to their privacy policies and not under our control. Disabling cookies or rejecting third-party cookies through browser or app settings may prevent access to certain Platform features or affect functionality. See our Cookie Policy on the Platforms for details.

Your account, Personal Data, and Your Content are password-protected, accessible only by you or authorized users. We recommend not sharing your password and logging out after use, especially on shared or public devices. NGMT implements reasonable security measures, including:

• Limited employee access to Personal Data.
• Secure cloud storage with reputable third-party providers.
• Encryption and security software where appropriate.

As a global service, your Personal Data may be stored or processed on servers outside Hong Kong (e.g., in the United States). We ensure PDPO-compliant safeguards for cross-border transfers, such as obtaining your consent unless an exception applies and ensuring foreign recipients meet comparable protection standards. No internet transmission is 100% secure, and while we take commercially reasonable steps to secure your data once received, we cannot guarantee absolute security, and you use the Platforms at your own risk.

When Personal Data is no longer needed for its original purpose or legal/business requirements, we will destroy or anonymize it.

You may opt out of non-essential data collection or use, including:

• Newsletters and marketing communications (via unsubscribe links or account settings).
• Sharing Your Content with Sponsors (via account settings on ImaKOL Platforms).
• Third-party cookies (via browser or app settings, though this may limit functionality).

To withdraw consent for the collection, use, or disclosure of your Personal Data, or to request deletion, use the "Delete Account" option in the ImaKOL or ImaKOL app settings or email us. We will process requests within 30 days, retaining only data required for compliance, regulatory, or legal purposes. Deleting your account may remove Your Content from our servers, except in aggregated form or for record-keeping.

You may access or correct your Personal Data (e.g., name, email address, birthday, shipping and billing addresses, contact numbers, payment details) by logging into your user account or editing account settings on the Platforms. We make reasonable efforts to ensure Personal Data used or disclosed is accurate and complete. You should update us on any changes, as we are not responsible for relying on inaccurate or incomplete Personal Data if you fail to update us.

KOLs on the ImaKOL Platforms must comply with applicable advertising disclosure laws (e.g., including #ad or #sponsored in sponsored content). We may collect data to monitor compliance but are not liable for your failure to meet these requirements.

The Platforms may link to or frame third-party websites, applications, or services (e.g., social media platforms, Sponsor or Merchant websites). These are subject to their own privacy policies, and NGMT is not responsible for their content, security, or practices. Your use of third-party services is at your own risk, and queries or complaints should be directed to the relevant provider. Review their terms before use.

This Policy and your use of the Platforms are governed by the laws of Hong Kong. Any disputes arising out of or in connection with this Policy or your use of the Platforms shall be resolved through good-faith negotiations. If unresolved within 30 days, disputes will be referred to arbitration at the Hong Kong International Arbitration Centre (HKIAC) under its Administered Arbitration Rules. The arbitration will be conducted in English by a single arbitrator in Hong Kong, and the decision shall be final and binding.

We will review and update this Policy to align with industry trends and legal or regulatory changes. We reserve the right to amend this Policy at our discretion. Updates will be posted on the Platforms, and you are encouraged to check periodically for the latest version.

Nothing in this Policy limits your rights under Applicable Laws.

If any provision of this Policy is deemed illegal, invalid, or unenforceable, the remaining provisions will continue in full force.

All communications and notices must be in English. In case of translation discrepancies, the English version prevails.

We are not liable for delays or failures due to force majeure events (e.g., natural disasters, government actions).

This Policy is available in English and Chinese. In case of inconsistency, the English version prevails.