Privacy

Moomoo Technologies Inc. Privacy Policy

Last Updated: May 31, 2023

Welcome to Moomoo Technologies Inc.!

1. Privacy generally

This privacy policy applies to the handling of personal information by Moomoo Technologies Inc. (Moomoo, we, us, our).

Moomoo understands the importance of protecting an individual’s personal information. This privacy policy sets out how Moomoo aims to protect your personal information, your rights in relation to your personal information held by Moomoo and how Moomoo collects, holds, uses, discloses, and otherwise manages, your personal information when we provide you with our products and services, and when you access our websites, applications and social media accounts.

In collecting, holding, using, disclosing and otherwise managing your personal information, Moomoo will comply with the Privacy Act 1988 (Cth) (Privacy Act) and the Australian Privacy Principles (APPs) in the Privacy Act.

Moomoo will regularly review its policies and procedures regarding personal information and may therefore update and amend this privacy policy from time to time. Any updated privacy policy will be made available on the Moomoo website, https://www.moomoo.com/au, or can otherwise be obtained by contacting us and requesting a copy.

2. Kinds of personal information collected

Personal information is information or an opinion about an identified, or reasonably identifiable, individual.

Moomoo operates the online trading platform called "moomoo" to offer a financial markets information and trading platform. In conducting this business, or as a result of our other interactions or dealings with you, Moomoo may collect your personal information.

The kinds of personal information that Moomoo collects will vary depending on our particular interaction or dealing with you. However, generally speaking, the kinds of personal information Moomoo collects may include:

1. your contact information such as your name, date of birth, postal address, telephone number, email address;
2. your account data such as username (moomoo ID or other identifiers), password, profile picture;
3. your device identifiers such as Apple's Identifier for Advertisers (IDFA) and Google Advertising ID (ADID);
4. your IP address;
5. your location data such as determined through GPS (with your permission), WiFi network, wireless network triangulation;
6. your device information such as device type, OS name and version, screen resolution, platform type, device manufacturer and model, language settings, browser type and version, software name and version, list of installed applications and information about installed applications;
7. the usage information such as interactions with the Services (including photos or media uploaded);
8. the customer service data such as your account identifier, log data, email address (if you choose to disclose your email), details of request;
9. the social media data such as your social account ID, name, email address, photo, contacts, and any other information that may be or that you make accessible to us when you connect your social media account to your account; and
10. the forum data such as messages, images and videos posted by you.

Moomoo may also hold other kinds of personal information as permitted or required by laws and regulations or other kinds of personal information that we notify you of at or about the time of collection.

Generally, we do not collect sensitive information about individuals. Information about your health, racial or ethnic origin, political persuasions, criminal record and religious or philosophical beliefs are all examples of sensitive information. If we do need to collect sensitive information about you, we will only do so with your consent or where we are required to do so by law.

3. How we collect personal information

Generally, Moomoo collects your personal information directly from you. For example, Moomoo may collect your personal information:

• when you register or apply for an account with us, request information or services from us, or otherwise provide us with your details;
• where you use our websites, applications, products or other online services or otherwise interact with us; or
• if you post information to our website, application or any of our social media sites or otherwise interact with us.

There may be occasions when Moomoo collects your personal information from someone other than you, for example:

• from our other service providers that help us provide our services;
• from related entities of Moomoo, including but not limited to holding companies or affiliated companies;
• from third parties you authorise to disclose your information to us;
• from a publicly maintained record or other publicly available sources of information including social media and similar websites; or
• from third parties if you connect to our services or register an account with us using an external third-party application, such as Facebook or Google.

Generally, Moomoo will only collect your personal information from sources other than you if it is unreasonable or impracticable to collect that personal information from you.

4. Purposes for which personal information is used

Generally speaking, Moomoo collects, holds, uses or discloses personal information so that we can maintain, improve and provide you with our products and services.

Some examples of the purposes for which Moomoo collects, holds, uses and discloses your personal information include to:

• contact you regarding your account;
• facilitate advertisement attribution as part of our marketing campaigns;
• determine your approximate location;
• monitor the integrity of our services and products to ensure such provision is secure and lawful;
• ensure the integrity and consistent operation of our services;
• protect our services against cyberattacks, criminal activity, identity theft, or investigation of suspicious activity;
• comply with our legal obligations, including as part of conducting routine audits of our services;
• enforce obligations owed to us;
• determine the effectiveness of features and campaigns;
• conduct our business and facilitate the supply of our services to you;
• contact you to obtain your feedback regarding our products or services or to conduct other market research;
• conduct investigations in cases of fraud, credit or data security risks;
• analyse the information we collect so that we can administer, support, improve and develop our business and the services we offer (including by monitoring or recording our interactions with you for training purposes);
• respond to your support request;
• connect your account with your social media handle, and facilitate sharing on your social media account;
• facilitate your use of the forum to communicate with the community;
• establish, exercise or defend a legal right or to participate in any legal or administrative proceedings; and
• comply with the obligations of Moomoo under any applicable laws, regulations, rules, directives, orders, instructions, guidance and requests from any local or foreign authorities, including regulatory, governmental, tax and law enforcement authorities.

In addition to the purposes listed above, Moomoo may use your personal information for purposes related to the above purposes, other purposes which we notify you of when we collect the information and for purposes otherwise permitted or required by law.

Where personal information is used or disclosed, Moomoo takes steps reasonable in the circumstances to ensure it is relevant to the purpose for which it is to be used or disclosed. You are under no obligation to provide your personal information to Moomoo. However, without certain information from you, Moomoo may not be able to provide services or products to you or may be limited in how we can interact with you.

5. Use of personal information for marketing purposes

In addition to the purposes outlined in paragraph 4 above, Moomoo may use and disclose your personal information in order to inform you of promotions, competitions, giveaways, events, goods or services that may be of interest to you. This may include Moomoo disclosing the information to related companies of Moomoo or other entities with which Moomoo has a commercial relationship or arrangement for the purpose of the other entity contacting you for such marketing purposes. We may also use your personal data to invite you to participate in marketing research, surveys and other similar activities. Your mobile information (including name and mobile phone numbers) that is used for a 10DLC campaign will not be shared or sold to third parties (other than any affiliates of the Moomoo) for their marketing/promotional purposes.

You can choose to receive marketing and other promotional materials through various modes including but not limited to email, direct mailers, short message service, telephone calls, facsimile and other mobile messaging services. In respect of sending telemarketing messages to your Australia telephone number via short message service, telephone calls (voice or video), facsimile and other mobile messaging services, we will do so only if You have provided your clear and unambiguous consent in writing or other recorded form for us to do so.

If you do not wish to receive such communications, you can opt-out by contacting Moomoo via the contact details set out in paragraph 12 of this privacy policy or through the opt-out mechanism contained in a marketing communication to you.

6. Disclosure of personal information

Moomoo discloses your personal information for the purpose for which Moomoo collects it. As a result, generally, Moomoo may disclose your personal information for a purpose set out in paragraphs 4 and 5 of this privacy policy, to the following persons (whether in Australia or overseas). This may include disclosing your personal information to:

• related companies of Moomoo including but not limited to holding companies or affiliated companies located in Australia or overseas;
• service providers and contractors and other third parties and their respective officers, employees, agents or subcontractors who provide goods or services to us (including our technology service providers, our business consultants, risk, credit, compliance and identification verification companies, legal and accounting firms, auditors, insurers and other professional advisers or administration service providers);
• other third parties that are integral to the provision of our services;
• people or entities considering acquiring an interest in Moomoo or any business or assets of Moomoo;
• other parties who invest in or acquire an interest in Moomoo or any business or assets of Moomoo;
• relevant regulatory bodies, government, tax authorities, law enforcement agencies or other administrative, self-regulatory or statutory agencies, or stock exchange or clearing house where required by law; and
• any other party to whom you authorise us to disclose your personal data to.

Moomoo may also disclose your personal information for other purposes if we notify you of the disclosure at or about the time of collecting the information, we have otherwise received your consent or the disclosure is required or authorised by law.

If you post information or other content to public sections of our websites or to our social media sites, you acknowledge that the information or content may be viewed by the public and/or users of the relevant website or social media site.

7. Overseas disclosures

Moomoo may transfer your personal information to countries/territories outside Australia where any of our related companies or service providers may be located. This includes, but is not limited to, the People's Republic of China (including Hong Kong Special Administrative Region), Singapore and the United States. To the extent that we may need to transfer your personal information overseas, we will protect the personal information so transferred and ensure that we provide a standard of protection that is comparable to the protection under the Privacy Act and the APPs.

We take reasonable steps to ensure that any such overseas recipients do not hold, use or disclose your personal information in a way that is inconsistent with the obligations imposed under the Privacy Act and the APPs.

8. Links to other websites

When you access our websites or other online services, we may provide as a convenience to you links to other websites, including websites operated by our partners, associates, or independent third parties. These links are provided as a convenience to you. Each website has its own privacy practices, as described in that website’s privacy policy. Those practices may be different than the practices described in this privacy policy, and we encourage you to read each website’s privacy policy carefully before you use or submit information to that website. Additionally, to the extent that you follow a link to a website operated by an independent third party, please be aware that we exercise no authority or control over that third party, and cannot be and are not responsible for any information that you may submit to that website.

9. Cookies

When you visit our websites or other online services, we will generally leave a ‘Cookie’ in the memory of your web browser. The website or other online service may only function properly if Cookies are enabled. Our websites and online services may use persistent Cookies to authenticate you as a user and display content that is relevant and specific to you.

Cookies are very small files that store information about your visit to and use of a website. Most major commercial Internet sites use them and they make your Internet-surfing more useful and less time-consuming because they store information that is reusable each time you visit our website, such as birthday and other preferences you have chosen to share with us.

Cookies cannot access and read the files on your hard drive. They do allow us to provide information and products that are more meaningful to you without asking you the same questions every time you visit us. You may get Cookies from our advertisers. We cannot pre-screen these Cookies since they come directly to you from other sites. We hope you will want the better service that Cookies allow, but if you prefer, you can set your browser to refuse Cookies. However, by doing that, your access to our website, https://www.moomoo.com/au, may be compromised or limited. This may also affect the provision of certain services through our website.

10. Security of personal information

Moomoo takes steps reasonable in the circumstances to ensure that the personal information it holds is protected from misuse, interference and loss and from unauthorised access, modification or disclosure.

Moomoo holds personal information in electronic forms in secure databases on secure premises, accessible only with the appropriate passwords by authorised staff, contractors or agents on a "need to know" basis and is disclosed or shared using secured methods (personal information is encrypted when necessary). Where personal information is held in hard copy, it will be held in controlled, access restricted premises which only authorised personnel or contractors will be permitted to access.

The processes and systems we use to secure your personal information include:

1. the use of identity and access management technologies to control access to systems on which information is processed and stored;
2. the implementation of strict internal security standards and confidentiality policies when sharing of personal information between related companies of Moomoo;
3. requiring all employees to comply with internal information security policies and keep information secure;
4. requiring all employees to complete training about information security; and
5. monitoring and regularly reviewing our practise against our own policies and against industry best practice.

We have in place procedures for training our employees about their obligations under this privacy policy, disciplining them for failure to follow this privacy policy. We also have in place internal procedures to confirm general company compliance with this privacy policy.

Moomoo will destroy or de-identify personal information in circumstances where it is no longer required, unless Moomoo is otherwise required or authorised by law to retain the information.

11. Access and correction

Moomoo takes steps reasonable in the circumstances to ensure any personal information it holds is accurate, up-to-date, complete, relevant and not misleading.

In addition, under the Privacy Act, you have a right to seek access to and correction of your personal information that is collected and held by Moomoo. If at any time you would like to access or correct the personal information that Moomoo holds about you, or you would like more information on Moomoo’s approach to privacy, please contact Moomoo using the details set out in paragraph 12 below. Moomoo will grant access to the extent required or authorised by the Privacy Act or other laws and take steps reasonable in the circumstances to correct personal information where necessary and appropriate.

To obtain access to your personal information:

• you will have to provide proof of identity to ensure that personal information is provided only to the correct individuals and that the privacy of others is protected;
• Moomoo requests that you be reasonably specific about the information you require; and
• Moomoo may charge you a reasonable administration fee, which reflects and will not exceed the cost to Moomoo for providing access in accordance with your request.

Moomoo will endeavour to respond to your request to access or correct your personal information within 30 business days from your request. If Moomoo refuses your request to access or correct your personal information, Moomoo will provide you with written reasons for the refusal and details of complaint mechanisms.

If you are dissatisfied with Moomoo’s refusal to grant access to, or correct, your personal information, you may make a complaint to the Office of the Australian Information Commissioner.

12. Deletion of account and/or personal information

You may delete your account at any time through Settings - Account & Security - Delete Account in the moomoo App, and your personal information will be deleted in the normal course of business pursuant to our current data retention practices. You may also request to have all your personal information deleted by contacting us. We will comply with deletion requests within a reasonable time to the extent permissible by law; however, we will not delete data that we are legally required to maintain, such as information regulators require for audit or substantiation purposes.

13. Contacting Moomoo

For further information or enquiries regarding your personal information, or if you would like to opt-out of receiving any promotional or marketing communications or make a privacy complaint, please contact Moomoo using any of the following contact details:

Email: support@moomoo.com

14. Privacy complaints

Please direct all privacy complaints to Moomoo. At all times, privacy complaints:

• will be treated seriously;
• will be dealt with promptly;
• will be dealt with in a confidential manner; and
• will not affect your existing obligations or affect the commercial arrangements between you and Moomoo.

Moomoo will acknowledge your complaint within 14 business days of receipt and endeavour to resolve it within 30 business days, unless Moomoo informs you otherwise and seeks your agreement in writing.

Moomoo will commence an investigation into your complaint. You will be informed of the outcome of your complaint following the completion of the investigation. In the event that you are dissatisfied with the outcome of your complaint, or an extension to the time in which Moomoo will resolve it, you may refer the complaint to the Office of the Australian Information Commissioner.