Success McMoore Privacy Policy

This “Privacy Policy” is a commitment from Success McMoore (“We” or “Us” or “Our” or the “Company”) to respect and protect Your Personal Data when accessing and using the services, and the websites https://www.successmcmoore.com/ along with its subpages and changes from time to time (hereinafter referred to as the “Platform”).

The Company will only collect relevant information and Personal Data necessary to conduct its business activities. Such in collection is carried out specifically to assist companies in Southeast Asia, particularly in Indonesia, to improve Your digital advertising performance, by providing Ads Management Services through the Advertising Platform.

In implementing this Privacy Policy, the Company refers to two laws governing the protection of personal data, the laws of the Republic of Indonesia and Hong Kong SAR, including but not limited to:

• Law No. 27 of 2022 concerning Personal Data Protection;
• Regulation of the Minister of Communication and Information Technology No. 20 of 2016 concerning Personal Data Protection in Electronic Systems;
• Government Regulation No. 71 of 2019 concerning the Implementation of Electronic Systems and Transactions;
• Government Regulation No. 17 of 2025 concerning Governance of Electronic System Implementation in Child Protection;
• Cap. 486 Personal Data (Privacy) Ordinance (“PDPO”); and
• other relevant regulations; along with derivative regulations, implementing regulations, and amendments from time to time

(collectively, “Data Protection Regulations”).

This Privacy Policy explains how the Company collects, obtains, stores, uses, processes, controls, discloses, and protects Your Personal Data in accordance with applicable laws and regulations, specifically those specified in the Data Protection Regulations.

A. DEFINITIONS

Capitalized terms used in this Privacy Policy, unless otherwise defined herein, shall have the meanings ascribed to in the Ads Management Service Terms and Conditions, which may be accessed via the following URL link https://www.successmcmoore.com/ (the “Terms and Conditions”). This Privacy Policy constitutes an integral and inseparable part of the Terms and Conditions.

B. COLLECTION OF PERSONAL DATA

The Company may collect Personal Data from Users, in accordance with the categories We have classified into several sections below.

1. Data Collected from You for Registration Processing and Account Management

When You register and create an Account on the Platform or in connection with the Ads Management Service, We may ask You to provide us with certain Personal Data, including but not limited to:

• full name;
• personal residential address;
• email address;
• mobile phone number;
• place and date of birth;
• gender;
• national identification number (ID card number);
• bank account information; and
• other information information related to Accounts, Platforms, and Ads Management Services.

(collectively, “User Identity”).

If You are a registered User, we may ask You to provide Your User Identity on the Platform and login credentials required to access Your Account.

In certain cases, We may ask You to provide government-issued documents as part of the Know Your Customer (KYC) process if required under applicable laws and/or Terms and Conditions to identify You and process your request and/or Ads Management Services

2. Personal Data Collected When You Use the Platform

Whenever You use the Platform, We may collect Personal Data in the form of technical data regarding Your device and device usage, including but not limited to:

• location data, whether real-time or approximate, such as IP address, Wi-Fi location, IMEI, information contained in cookies, and other similar data;
• time data related to each user activity, including registration, login, product ordering, and other activities;
• usage or preference data, including User interactions with the Platform, saved preferences, and selected settings;
• device data, including the type of device used to access the Platform, such as hardware model, operating system and its version, software, file names and versions, language preferences, unique device identifiers, advertising identifiers, serial numbers, device motion information, and/or mobile network information;
• log data, including records on servers that receive data such as device IP address, access date and time, Platform features or pages viewed, Platform workflow and other system activities, browser type, or third-party services You used prior to interacting with the Platform.

When You conduct transactions on the Platform, we may also collect certain Personal Data in connection with Your use of the Platform and Ads Management Services. Such Personal Data includes, but is not limited to: (i) User Identity; (ii) products transacted; and (iii) transaction history.

3. Personal Data Obtained from Other Sources
The Company may also collect Your Personal Data from other sources, including third parties that provide services to us or collaborate with Us. Such sources include, but are not limited to:

• partners who assist in developing and delivering Ads Management Service on the Platform to You;
• partners through whom You create or access Your Account, such as via social media services, or applications that use our APIs or are used by Us;
• financial service providers;
• marketing service providers; and
• publicly available sources.

4. Third-Party Data Provided by You to Us

You may provide Us, with Personal Data relating to other third parties. In such cases, You represent and warrant that You have obtained the consent of the third party for, and hereby consent on behalf of the third party to, the collection, storage, use, processing, control, and/or disclosure of the third party's Personal Data by Us.

In some cases, third parties may use separate service providers to receive and process such information.

5. Data Integrated with Third Parties

Third parties use business tools, integrations, and technologies to share information with Us. Third parties may collect Your information when You visit a third-party website or application, use its services, or through other businesses or organizations that work with third parties. We require third parties to have a legitimate right to collect, use, and share Your information before providing it to Us.

Integrated third parties manage the information You share with them in accordance with their own terms and policies, not those of the Company. You can review the privacy policies of third parties on their websites or applications to find out how they receive and process Your information.

We do not and will never sell Your information to anyone. We also require other third parties to comply with rules regarding how third parties may and may not use and disclose the information We provide.

C. USE OF PERSONAL DATA
We control, process, and store Your Personal Data in accordance with applicable consent, agreements, and legal provisions, as well as for legitimate interests while protecting Your rights. Your Personal Data may be shared with third parties, including other parties outside the country, as long as it is necessary and protected in accordance with protection standards. Your Personal Data will be stored for as long as necessary and can be deleted at your request in accordance with Data Protection Regulations, including but not limited to the following purposes:
1. Personal Data Provided by Users Includes Information Supplied When You:

• create or update an account on the Platform;
• using features that require access permissions for the device You are using;
• contact Us, including through customer service;
• complete surveys conducted by Us or related parties;
• interact through messaging features, reviews, ratings, and similar features;
• use product delivery services, including package data (type, size, weight, etc.), address, payment method, amount, and order details; and/or
• make payments, including bank account details, credit card information, virtual accounts, instant payments, internet banking, and retail outlets.

2. Provision of Features to Support Our Services, Including:

• providing or facilitating or offering services, insurance, financing, loans, and other products through the Platform;
• enabling customization and personalization of User Accounts; and/or
• performing internal operations to support Ads Management Services on the Platform.

3. Processing User requests, activities, and orders, including the processing and delivery of products through the Platform;

4. Contacting Users through various media (including email, postal mail, telephone, WhatsApp, and other communication channels) to support order processing or the resolution of issues;

5. Supporting User communication with Our customer service, including:

• checking, handling, and resolving issues arising in relation to Accounts, Advertising Management Services, and the Platform;
• directing Users questions or complaints to the appropriate personnel;
• monitoring and improving the quality of customer service providing services to Users.

6. Ensuring that the Ads Management Service and Platform function properly, including but not limited to handling and troubleshooting issues, as well as personalizing features, content, and recommendations for Users;

7. Using User information for research and analysis purposes to provide a personalized experience, customize content, improve product and service quality, analyze operations and markets, strengthen security, and activate and manage Ads Management Services;

8. Providing information related to products, services, promotions, surveys, news, events, and displaying relevant advertisements from Us and/or Our business partners through the Platform or other media;

9. Monitoring and investigating suspicious transactions or alleged violations of the Terms and Conditions and applicable laws, and taking further action as deemed necessary;

Under certain circumstances, We may use or disclose User Personal Data for law enforcement purposes or to comply with legal obligations under applicable laws and regulations, including in the event of a dispute or legal proceedings. You hereby agree that You will not file any claims regarding the use or disclosure of such Personal Data, as long as it is done in accordance with applicable laws.

The Platform We provide may provide links to third-party websites or applications that are beyond Our control to facilitate Your access to additional information. You understand and agree that we are not responsible for the use or disclosure of Your Personal Data by such third parties.

D. USE OF COOKIES ON THE PLATFORM

To ensure that Our Platform functions optimally, We use cookies, which are small data files that are automatically stored on Your device to save Your preferences and configurations during Your visit. These cookies are not used to access other data on Your device besides Personal Data, without Your prior consent. You have the right to refuse or delete cookies through the settings of Your device or browser; however, doing so may affect Your optimal experience when using the Platform.

We also utilize Ads Management Services from Advertising Platforms to record User activity in connection with the use of the Platform, including but not limited to the use of push notifications, remarketing, and other advertising services. Based on this activity, third parties may display relevant online advertisements to Users.

The Company uses cookies to:

• analyzing website traffic and User behavior;
• improving quality and experience of Users in using the Platform; and
• presenting relevant advertisements through the Advertising Platform that can be accessed by Users using the Ads Management Service.

By using the Platform, Users acknowledge and agree that the Advertising Platform and/or other third parties may use cookies to display advertisements based on Users' previous visits to the Platform or other websites.

Our Platform provides push notification and website notification subscription options that can be enabled or disabled at any time according to User preferences, in order to receive the latest information, service updates, and product promotions.

E. PROCESSING AND DISCLOSURE OF PERSONAL DATA
We will only process your Personal Data if the processing is based on one of the following reasons:

• Your valid and explicit consent;
• the exercise of Our rights and obligations under an agreement with You;
• the fulfillment of legal obligations in accordance with the provisions of laws and regulations or orders from competent authorities;
• the fulfillment of Your vital interests, public interest, the provisions of public services, or other legitimate interests, while taking into account the balance between those interests and Your rights and freedoms as a User.

Your Personal Data may be shared with companies, affiliates, or third parties involved in the provision of services, including:

• service providers and partners who assist in enhancing services and improving user experience;
• legal authorities in accordance with applicable laws and regulations; and
• relevant parties in connection with any reorganization, merger, acquisition, or sale of assets.

Please note that We may disclose Your Personal Data under the following conditions:

• by using the Ads Management and Platform Services, You acknowledge that you have read, understood, and agreed to be bound by the applicable Privacy Policy, Terms of Service, and Terms and Conditions. In addition to contractual obligations, We may process and share your Personal Data based on other legal grounds in accordance with the provisions of laws and regulations; and
• We will only share Your Personal Data with Your consent, unless otherwise specified by applicable laws and regulations.

In addition to these provisions, based on Our policies and considerations, your Personal Data may be shared with third parties, including but not limited to Advertising Platforms, government agencies, law enforcement agencies, legal advisors, and professional consultants, if deemed necessary to: (i) fulfill legal obligations or comply with applicable laws and regulations; (ii) investigate suspected fraud, violations, or other unlawful acts; and/or (iii) protect Our brand, reputation, assets, or legal interests.

We store Personal Data and other information only for as long as necessary for the purposes of providing Ads Management Services, using Accounts and Platforms, complying with applicable legal obligations, and protecting Our legitimate interests. The storage period is determined based on operational needs, the type of services and features used, regulatory requirements, and legitimate processing purposes.

Under certain circumstances, Personal Data may be stored for a longer period of time as required or permitted by law, or if necessary for the purposes of evidence, dispute resolution, or enforcement of Our legal rights and obligations.

F. CONTROL AND TRANSFER OF PERSONAL DATA
In managing and processing your Personal Data, We may engage third parties acting as joint controllers and/or data processors, both within and outside Indonesia. In such cases, we ensure that the involvement of these third parties is based on adequate agreements and in accordance with applicable laws and regulations.

We are committed to protecting your Personal Data by implementing reasonable protection measures in accordance with applicable security standards and legal provisions, including but not limited to the Data Protection Regulations.

Transfer of Personal Data Overseas.

We will not transfer Personal Data collected, stored, processed, or used in Hong Kong to any place outside Hong Kong SAR, except and only to the extent that such transfer is permitted under the PDPO.

Only where applicable, and where a transfer of Personal Data outside the Hong Kong SAR is made, We will ensure that at least one of the following conditions is met:

(i) the country or region of destination has laws and regulations that provide a level of protection for Personal Data that is substantially similar to, or has objectives that are consistent with, the PDPO;

(ii) You have given Your prior written consent to the transfer;

(iii) the transfer is necessary to prevent or mitigate harm to you and it is not practicable to obtain Your consent;

(iv) the transfer is exempted under the provisions of the PDPO; or

(v) We have taken reasonable steps and exercised due diligence to ensure that Your Personal Data will be protected in a manner comparable to the requirements of the PDPO.

We will take reasonable and appropriate contractual, technical, and organizational measures to protect Your Personal Data in the event of a transfer of Personal Data outside the Hong Kong SAR, in accordance with applicable laws and regulations, including but not limited to the Data Protection Regulations.

We are committed to maintaining the transparency and security of Your Personal Data, and will always strive to protect and respect your rights at every stage of the management and processing of Personal Data.

G. ACCESS TO AND CORRECTION OF PERSONAL DATA
When you provide your Personal Data to Us, please ensure that it is accurate, complete, and up to date. If there are any errors or omissions in Your Personal Data, You can correct them yourself through Your Account on the Platform. You are also expected to update Your Personal Data immediately if there are any changes.

If the Personal Data cannot be corrected through Your Account, You can submit a correction request directly to Us through the available communication channels.

In accordance with the provisions of applicable laws and regulations, You have the right to request access to and/or obtain a copy of the Personal Data You have provided to Us, in a structured, commonly used, and machine-readable format.

H. CONSENT
By accepting this Privacy Policy, You acknowledge that You have read, understood, and agreed to all of its terms and conditions and consequences. Thus, You give Us Your consent to collect, store, use, process, manage, and disclose Your Personal Data in accordance with this Privacy Policy and applicable laws and regulations, including but not limited to laws and regulations in the field of Personal Data protection. You also declare and guarantee that the Personal Data you provide is Your own, true, accurate, and up to date.
If there are changes to Your Personal Data, You are obliged to immediately notify Us and submit a request to update or correct the Personal Data. You are fully responsible for any losses, both material and immaterial, arising from negligence, intent, or actions of other parties to whom You have given authority.

We may make changes or adjustments to Your Personal Data if required by applicable laws and regulations, instructions from regulators or authorities, and in order to protect Your interests and/or our legitimate interests.

After giving Your consent, You have the right to withdraw it by submitting a written request to Us. Upon receiving Your request to withdraw consent, We will stop collecting, using, and/or disclosing your Personal Data, unless required by law or there is another legal basis for continuing to process such Personal Data.

Please note that withdrawal of consent may affect Our ability to provide some or all of the Ads Management Services and/or access to Your Account on the Platform. In such cases, We are not responsible for any losses arising from the termination of the Ads Management Services and/or access to your Account on the Platform.

I. PERSONAL DATA PROTECTION
We implement reasonable and appropriate preventive measures, both technically, physically, and internally, to protect Your Personal Data from unauthorized access, disclosure, use, alteration, damage, or loss. To strengthen this protection, We are committed to implementing and complying with the ISO/IEC 27001:2022 international standard as an information security management framework.

However, We cannot guarantee that the security systems implemented will be completely free from errors, disruptions, or hacking risks. Therefore, We continuously evaluate, monitor, and improve our security systems and procedures to address developments in information security threats, so that the level of protection of Personal Data remains optimally maintained.

Users hereby declare their full compliance and commitment to comply with all applicable laws and regulations regarding

J. COMPLIANCE WITH CHILD PROTECTION
If You are under the age of 18 (eighteen) years of age, You declare that You have obtained the consent and permission of Your parents or legal guardian. Such consent includes acceptance of this Privacy Policy and consent to the collection, processing, and use of Your Personal Data in accordance with the provisions of applicable laws and regulations regarding the protection of Personal Data, including but not limited to the Data Protection Regulations.

The Ads Management and Platform Services do not contain features or content specifically intended for children and are not designed for use by children under the age of 18 (eighteen). Our products and services are organized in accordance with the provisions on child protection as stipulated in Government Regulation of the Republic of Indonesia Number 17 of 2025 concerning Governance of Electronic System Implementation in Child Protection.

We regularly monitor the use of the Services and any features that are suspicious or indicate a violation of these child protection provisions, to ensure compliance and protection for children as Users.

K. USERS RIGHTS AS THE OWNER OF PERSONAL DATA
1. Right to Information and Access

You have the right to obtain information regarding the party requesting your Personal Data, the purpose of the request, and to obtain access to a copy of Your Personal Data. We will provide this access through official channels in accordance with applicable laws and regulations, including but not limited to the Data Protection Regulations and the Company's internal policies.

Please note that requests for copies of Personal Data may be subject to administrative fees in accordance with applicable regulations.

2. Rights to Data Correction

You have the right to complete, update, and/or correct Your Personal Data that is incorrect, incomplete, or inaccurate.

3. Right to Terminate Processing, Delete and Destroy Personal Data

You have the right to terminate the processing of Your Personal Data and request the deletion and/or destruction of such Personal Data. Requests can be submitted in writing through the official channels listed in this Privacy Policy.

It should be understood that exercising this right may affect our ability to provide products, services, or goods to You, including contractual relationships with You and third parties. This may result in the termination of services and/or the termination of part or all of your agreement with Us, and may potentially result in a breach of obligations under the applicable agreement.

Any losses, whether material or immaterial, arising from the exercise of this right are entirely your responsibility.

The obligation to delete and destroy Personal Data does not apply if the Personal Data is necessary for:

• national defense and security interests;
• law enforcement interests;
• public interests in the administration of the state; or
• supervision of the financial services sector, monetary system, payment systems, and financial system stability for the purpose of state administration.

4. Right to Withdraw Consent

You have the right to withdraw Your consent to the processing of Personal Data that You have provided to Us. In this case, You understand and agree that We need time to process the termination of such processing appropriately. Requests for withdrawal of consent can be submitted through Our official communication channels.

Please note that withdrawal of consent may affect Our ability to provide products, services, and/or services to You, including contractual relationships that have been established between You and Us or third parties. This may result in the termination of services and/or the termination of part or all of the agreement, as well as potential breaches of obligations under the applicable agreement.

Any losses, whether material or immaterial, arising from the withdrawal of consent are entirely your responsibility.

5. Right to Object to Automated Processing

You have the right to object to the automated processing of Personal Data that may have legal or significant impact on You.

Objections may be submitted through the official channels listed in this Privacy Policy, and we will review such objections in accordance with applicable laws and regulations, including but not limited to the Data Protection Regulation.

6. Right to Delay or Restrict Processing

You have the right to request a delay or restriction of the processing of Personal Data in proportion to the purpose of the processing. Such requests may be submitted through Our official communication channels listed in this Privacy Policy.

Please note that the implementation of this request may affect the provision of services, products, or services, as well as contractual relationships with You, including the possibility of termination of services and/or termination of part or all of the agreement.

Any losses, whether material or immaterial, arising from the exercise of this right are entirely your responsibility.

7. Right to Obtain, Use, and Transfer Personal Data to Third Parties

You have the right to obtain, use, and transfer Your Personal Data stored on the Platform to third parties. The transfer or transfer of such Personal Data is carried out with the provision that the communication systems and transfer mechanisms used by Us and third parties are guaranteed to be secure and in accordance with applicable data protection standards.

8. Other Rights in Accordance with Laws and Regulations

In addition to the rights mentioned above, You also have other rights governed by applicable laws and regulations related to the processing of Personal Data. We are committed to respecting and facilitating the exercise of these rights in accordance with applicable laws. You have other rights governed by laws and regulations related to the processing of Personal Data, including but not limited to the Data Protection Regulations.

L. PRIVACY POLICY UPDATES
This Privacy Policy may be changed and/or updated from time to time. All changes will be announced on this page, with the latest revision date always displayed at the top.

We recommend that You periodically read and review this Privacy Policy page to stay informed of any changes. By continuing to access and use the Platform's services, You are deemed to have read, understood, and agreed to all changes made.

M. CONTACT US

If You have any questions, requests, or complaints regarding this Privacy Policy, please contact Us through one of the following official channels:

Success McMoore Pte Ltd.
Email: business@successmcmoore.com