1. Introduction

We understand the importance of protecting the personal information received from each individual customer
and confidential data from corporate client. This Data Privacy Policy provides information on our obligations.
This Privacy Policy sets out how we collect, use, disclose, share, transfer and store personal data about
employees, workers, contractor, subcontractors, job applicants, customers and corporate. We pledge to meet
fully, internationally recognised standards of personal information privacy protection, under the regulatory
system and in accordance with the General Data Protection Regulation (EU) 2016/279 (“GDPR”) and any
data protection laws where we operates businesses. In doing so, we shall ensure compliance by our personnel
with the strictest standards of security and confidentiality.

2. What personal information do we collect?

In this Privacy Policy, “personal information” is any information that identifies or can be used to personally
identify an individual. We collect, process and use personal information in order to provide our services and
solutions, manage and administer our business, improve our services and best adapt our business processes
to our clients’ need. The types of personal information we collect or receive during service provisioning may
include:

• name, title or position;
• correspondence address and/or billing address;
• contact details, including contact name and telephone number or email address;
• information for the verification of identity, including identification type and identification number;
• information regarding physical, physiological, genetic, mental, economic, cultural or social identity of an
  individual,

3. How does LTG collect personal information?

We may collect personal information in the following circumstances:

• when you purchase our solutions and services;
• when you trade-in your device to us;
• during communications (either orally or in writing via email or fax etc.) between you and our
  representatives;
• when we obtain feedback from you about our services and solutions;
• when you register for our events and seminars or subscribe to our mailing lists and newsletters;
• when we market our services and solutions to you;
• when we respond to your inquiries and requests; and
• through your access and use of our website.

4. For what purposes does LTG collect, hold, use and disclose personal information?

We collect, hold, use and disclose on a need to know basis personal information for the following purposes:

• respond to inquiries and requests;
• develop, provide, and improve our services and solutions;
• inform you about our services and solutions;
• obtain feedback from you on our services and solutions;
• update our records and keep contact details up to date;
• enable you to subscribe to our website, newsletters and mailing lists and to register for events and
  seminars;
• assess and review the performance of our website and to improve its operation;
• process and respond to privacy complaints;
• comply with any law, rule, regulation, lawful and binding determination, decision or direction of a
  regulator; to co-operate with any governmental authority of any country; or as we otherwise believe to
  be necessary or appropriate under applicable law; or
• any other purposes that we obtain your authorisation in a separation notification.

5. To whom do we disclose personal information?

We shall take all practicable steps to keep your personal information confidenital but we may disclose your
personal information to our direct and indirect subsidiaries for the original purpose for which your personal
information was collected and for other purposes set out in paragraph 4 above. We may also disclose your
personal information on a need to know basis to:

• any contractor, supplier, agent or other third party who provides business, marketing, and other services
  to us and under a duty of confidentiality to us;
• a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other
  disposition of all or any portion of our business, assets or stock; and
• any court, tribunal, or other governmental authorities of any country, or other third party to whom we are
  under an obligation to make disclosure under the requirement of any law, or for the purposes of any
  guidelines or codes of practice issued by any regulatory or other authorises with which we are expected
  to comply.

We do not provide your personal information to any other third parties for their third-party direct marketing
purposes.

6. Do we disclose personal information to recipients in other countries?

We may store, process or transfer your personal information to a place outside the country in which you are
located, such as in any place where our direct and indirect subsidiaries situate, where we have facilities or
where we engage third party service providers, which provide adequate level of protection to your personal
information. We assure you that the purpose of any transfer of your personal information is compatible with
the original purpose for which your personal information was initially collected and possessed.

7. How does LTG store and secure personal information?

We seek to take reasonable precautions to protect personal information from misuse, loss, unauthorised
access, modification or disclosure using a combination of physical, administrative and technical safeguards.
We only allow authorised peronnel and/or personnel of our contractor to access to your personal information
on a “need-to-know” basis.

Our website is linked to the internet, and as the internet is inherently insecure, no data transmission or storage
system can be guaranteed to be 100% secure. We cannot provide any assurance regarding the security of
transmission of personal information you communicate to us online though we shall take commercially
practicable precautions to keep it on the secured servier with password-protected if it is stored electronically.

Information collected by us will only be retained as long as necessary to fulfil the purpose for which it was
collected.

8. How can you access and correct personal information?

You may at any time (subject to various exceptions and in accordance with data protection legislation in
governing jurisdiction) request access to, correction or deletion of your personal information that has been
previously provided to us. To exercise any of your rights, please send us a written request marking confidenital
to the postal or email address set out below. In response, we may ask you to provide certain information about
yourself so that we can be sure you are the person to whom the data refers.