Smart Digital Payment Co including its subsidiaries (hereinafter   referred to as “TIQMO”) is committed to protecting and respecting your   privacy in accordance with TIQMO Wallet Privacy Policy (the “Privacy   Policy”).

This Privacy Policy sets out how TIQMO collects, uses, processes,   shares, protects, and retains Personal Data (as defined below) about you, and   the choices you have about your Personal Data, in conformance with the   Privacy Policy in connection with the Services to be provided by TIQMO in the   Territory.

1.    Definitions:

“App” means a mobile application made available by or on behalf   of TIQMO, from time to time, or accessible at its website, where your   personal information will be requested from you or obtained through   government portals and additional information may be required from you to   apply for the Services.

“Cookies” means a small bit of record-keeping information that   App site or websites often store on a user's computer. TIQMO’s cookies do not   include Personal Data and are typically used to quickly identify your device   and to “remember” you.

“Personal Data” means any information of any type in particular   personal information such as identity data; contact data; financial data;   transaction data; device data; content data; profile data; usage data;   marketing and communication data; location data, irrespective of the type of   medium involved, including sound and image, relating to an identified or   identifiable natural person (“data subject”); an identifiable person is one   who can be identified, directly or indirectly, in particular by reference to   an indication number or to one or more factors specific to his physical,   physiological, mental, economic, cultural or social identity.

“Territory” means the Kingdom of Saudi Arabia or any other   country where TIQMO is providing Services.

2.    Scope of the Privacy   Policy

2.1  This Privacy Policy   applies to TIQMO’ provision of Services (as defined in TIQMO Wallet User   Agreement (“Agreement”)) in relation to your use of App, which we here   collectively call the Services. The Privacy Policy applies to information we   collect through:

·           App

·           On the App site or other sites of ours.

·           In email, text, and other electronic messages between you and our   App and/or website.

·           Through mobile and desktop applications you download from our App   and/or website, which provide dedicated non-browser-based interaction between   you and our website.

·           Government portals such as Elm.

·           Compliance and anti-fraud systems.

·           When you interact with our advertising and applications on   third-party websites and services if those applications or advertising   include links to this Privacy Policy.

2.2  Any changes we may make   to this Privacy Policy in the future will be posted on the App and, where   appropriate, notified to you. By continuing to use the App and/or not   objecting to the changes within thirty (30) days, you will be deemed to   accept the changes to this Privacy Policy.

2.3  Our Services are   governed by this Privacy Policy and by using or accessing our Services you   hereby give your consent to the processing, use and disclosure of your data   (where required) for provision of the Services. This Privacy Policy   constitutes an integral part of TIQMO Wallet User Agreement. Therefore,   please do not use the Services if you do not agree to this Privacy Policy.

3.    Collection of Personal   Data

3.1  TIQMO collects Personal   Data from you only where necessary for the fulfilment of the reasonable,   legitimate, and proper business purposes of TIQMO. All collection of Personal   Data is carried out in a fair, lawful and secure manner.

3.2  TIQMO collects Personal   Data:

·           that you have voluntarily provided to TIQMO or its agents;

·           from your use of Services provided by TIQMO;

·           from your use of our App and/or website; and

·           By your consent to collect your Personal Data from government   portals.

3.3  This Personal Data   enables TIQMO to provide you with the Services that you require, to source   supply of Services and/or products from you or to proceed with the purposes   for which such Personal Data is collected, or if it is able to, there may be   delays in the provision (or will not be able to), sourcing or processing   thereof, for which TIQMO shall not be held liable nor responsible for.

4.    Use of Personal Data

4.1  TIQMO collects, uses,   processes and retains Personal Data for its legitimate functions:

a.         to facilitate account creation and login process;

b.         to post testimonials;

c.         request feedback;

d.         to protect our Services;

e.         to send administrative information to you;

f.          to enforce our terms, conditions and policies for business   purposes, to comply with legal and regulatory requirements or in connection   with our agreement;

g.         providing, monitoring and improving TIQMO’s Services;

h.         managing and administering your account with TIQMO;

i.          where we need to perform a contract, we are about to enter or   have entered with you;

j.          where it is necessary for our legitimate interests (or those of a   third party) and your interests and fundamental rights do not override those   interests;

k.         where we need to company with a legal or regulatory obligation;

l.          advertising products and Services provided by TIQMO and other   services which are ancillary to the aforesaid (core) Services of TIQMO;

m.       advertising products and services for environmental conservation   and charitable purposes;

n.         sourcing of supply of Services and/or products to TIQMO;

o.         staff recruitment; and

p.         such other purposes as may be required for the running of TIQMO’s   Services and businesses or by applicable laws or regulations.

4.2  TIQMO follows generally   accepted industry standards and maintains reasonable safeguards to attempt to   ensure the security, integrity and privacy of the information in TIQMO’   possession.

5.    Direct marketing

5.1  Any use of your   Personal Data by TIQMO for direct marketing or any directly related purposes   would be in accordance with this Privacy Policy. TIQMO will only use your   Personal Data for direct marketing of the Services of TIQMO and our business   partners after we have obtained your consent by accepting this Privacy   Policy, and you have the right to withdraw such consent at any time.

6.    Opting out

6.1  You can unsubscribe or   opt out from our marketing email list at any time by clicking on the   unsubscribe link in the emails that we send or by contacting us using the   details provided below. You will then be removed from the marketing email   list – however, we may still communicate with you, for example to send you   service-related emails that are necessary for the administration and use of   your account, to respond to service requests, or for other non-marketing   purposes. To otherwise opt-out, you may:

o     Contact us using the contact information provided; and/or

o     Access your account settings and update your preferences.

7.    Disclosure of Personal   Data

7.1  TIQMO may disclose   Personal Data collected to TIQMO’s subsidiaries and/or group of companies and   to TIQMO’s business associates that provide related services who are involved   in the fulfilment of your request, or the Services contracted for.

7.2  TIQMO may also disclose   your Personal Data with third parties who assist TIQMO, among others, with   its internal functions, such as invoicing and the mailing of account   statements, credit reference check, and information technology services.   These third parties are bound to abide by TIQMO’s practices and policies   relating to the usage, processing, and retention of your Personal Data. Your   Personal Data is only accessible by our own personnel or the personnel of the   third parties collaborating and/or facilitating TIQMO for the provision of   the Services. Our own personnel and the personnel of the third parties will   be instructed to observe confidentiality and the terms of this Privacy Policy   when accessing your Personal Data.

7.3  Other than in the   instances stated herein and for any other legitimate and proper purposes, TIQMO   will not share, sell, rent, trade and/or disclose your Personal Data to any   other third party unless your consent has been obtained.

7.4  TIQMO may use third   parties to collect and process Personal Data on behalf of TIQMO and according   to TIQMO instructions. TIQMO is not liable for the acts and omissions of   these third parties, except as provided by mandatory/applicable laws.

7.5  TIQMO may also disclose   your Personal Data to third parties when TIQMO has a reason to believe that a   disclosure is necessary to address potential or actual injury or interference   with TIQMO’ rights, property, operations, users or others who may be harmed or   may suffer loss or damage, or TIQMO believes that such disclosure is   necessary to protect TIQMO rights, combat fraud and/or comply with a judicial   proceeding, court order, or legal process served on TIQMO. To the extent   permitted by applicable laws, TIQMO will make reasonable efforts to notify   you of such disclosure through the App, or in another reasonable manner   possible.

8.    Retention of Personal   Data and correctness

8.1  TIQMO retains the   collected data for the period necessary to fulfill the purposes outlined in   this Privacy Policy unless a longer retention period is required or permitted   by applicable laws (such as tax, accounting, or other legal requirements).   Thereafter, TIQMO deletes all data in its possession within a reasonable   timeframe. TIQMO does not verify the correctness of Personal Data.

8.2  Some data may be   further retained if necessary, to resolve disputes, enforce TIQMO Wallet User   Agreement, and comply with technical and legal requirements and constraints   related to the security, integrity, and operation of Services.

9.    Third Party Terms and   Conditions

9.1  Please note that your   use of the Services may be subject to certain third-party terms and   conditions and TIQMO is not liable for any such third-party terms and   conditions and their use of your Personal Data.

9.2  TIQMO may disclose your   Personal Data to third parties in connection with a corporate merger,   consolidation, restructuring, the sale of substantially or all TIQMO stock   and/or assets or other corporate change, including, without limitation,   during any due diligence process provided, however, that this Privacy Policy   shall continue to govern such Personal Data.

9.3  TIQMO follows generally   accepted industry standards and maintains reasonable safeguards to attempt to   ensure the security, integrity, and privacy of the information in TIQMO’s   possession.

10.  Protection and storage   of Personal Data

10.1 TIQMO has also   implemented reasonable and practical security measures designed to protect   against loss, misuse and/or alteration of your Personal Data under its   control. TIQMO may store and/or transfer your Personal Data to its   subsidiaries, affiliates, and partners in the Territory in accordance with   mandatory legislation and this Privacy Policy.

11.  Use of Cookies

11.1 We use Cookies and/or   other tracking technologies (like web beacons and pixels), or pieces of code   that record your preferences, on our App and/or website to access or store   information, but we will ask for your consent to their use when you first   visit us. This helps us to provide you with a good experience when you use   the App or browse our website, and also allows us to improve the App and/or   website. When you browse App and/or our website, Cookies will be stored in   your computer's hard drive and/or MOBILE device and will be used in   accordance with your consent. You have a choice not to accept the Cookies,   but if you do, certain functionalities may not be available.

12.  Accuracy of Personal   Data

12.1 TIQMO shall take   reasonable steps to keep your Personal Data as accurate, complete, and up to   date as is necessary for the purposes for which it is to be used. Personal   Data that is used on an ongoing basis, including information that is   disclosed to third parties, will generally be kept accurate and up to date.   Where you inform us of Personal Data, which is inaccurate, incomplete,   misleading or not up to date, we will update it in compliance with the   applicable laws and Privacy Policy, subject always to TIQMO’s other statutory   rights and obligations.

13.  Information from Minors

13.1 We do not knowingly   solicit data from or market to children under 18 years of age. By using the   Services, you represent that you are at least 18 or that you are the parent   or guardian of such a minor and consent to such minor dependent’s use of the   Services. If we learn that personal information from users less than 18 years   of age has been collected, we will deactivate the account and take reasonable   measures to promptly delete such data from our records. If you become aware   of any data, we may have collected from children under age 18, please contact   us through TIQMO Contact Centre.

14.  Access to information   and contact

14.1 Under and in accordance   with this Privacy Policy, you have the right to seek access to and correction   of your Personal Data held by us. In addition, subject to applicable data   retention laws, you may request us to delete your Personal Data that is no   longer required for the relevant purposes to which you have given consent.   Such rights may be exercised by you at any time. If you wish to exercise such   rights, or if you have any question regarding your Personal Data or this   Privacy Policy, please contact us through the TIQMO Contact Centre.

14.2 TIQMO makes good faith   efforts to enable you to review, update or correct your Personal Data in TIQMO’s   possession. TIQMO will need sufficient information from you to establish your   identity and to verify your access request, and to assist us in handling your   request. TIQMO reserves the right to charge you a reasonable fee for   complying with a data access request as permitted by applicable laws.

14.3 This Privacy Policy is   governed by the laws of the Kingdom of Saudi Arabia.

Contact details: CustomerCare.KSA@TIQMO.com

Smart Digital Payment Co.

Name of data privacy manager:

Telephone number:  8001110800