Introduction

1.1. Trovio Group Ltd, via its subsidiaries, including TCM&T Pte Ltd, TCM Capital AM Pty Ltd and Trovio Operating Pty Ltd (collectively referred to as 'Trovio', 'Company', 'we', 'us' or 'our'), respects the privacy rights of our clients and other organisations with whom we deal. Trovio is committed to complying with all applicable privacy laws including Singapore’s Personal Data Protection Act 2012 (the ‘PDPA’), Australia’s Privacy Act 1988 (Cth) (the 'Privacy Act') and the Australian Privacy Principles (the 'APPs').

1.2. The Company is related to other companies and entities ('related entities'). This Privacy Policy applies to all Personal Information collected by the Company and those related entities. Those related entities may also have their own privacy policies which set out additional detail or differences in their privacy practices. To the extent that those privacy policies are inconsistent with this Privacy Policy, those privacy policies will prevail over this Privacy Policy in relation to the actions of those related entities. A reference in this Privacy Policy to 'Trovio', 'Company', 'we', 'us' or 'our' is also a reference to those related entities.

1.3. Personal Information may be collected by us and by our third party service providers who assist us in operating our website, including its subdomains and any other website we operate from time to time (collectively, the 'Website'). We also provide software as a service which enables our clients to digitise commodity inventories and supply them to their customers (the 'Services').

1.4. All natural persons or other entities who view or log on to this Website are considered users of the Website. For convenience, the users and clients who use the Services are referred to as 'you'.

Personal information

2.1. 'Personal Information' is information or an opinion, whether true or not, and whether recorded in a material form or not, about an identified individual or an individual who is reasonably identifiable.

Purposes of this Privacy Policy

3.1. The purpose of this Privacy Policy is to inform you about the kinds of Personal Information that we may collect and retain about you by your use of this Website and/or the Services, how we collect, retain, use and disclose that Personal Information, choices you have regarding our use of that Personal Information, and your ability to access or correct that Personal Information.

Your consent

4.1. To ensure that you have full confidence in our handling of Personal Information, you are advised to read and understand the terms of this Privacy Policy in detail. In particular, when you read, browse or download information from our Website or use the Services, regardless of whether you register with the Website, you will be deemed to have provided your consent to the following:

• you consent to us using your Personal Information as set out in this Privacy Policy;
• you consent to the collection, use, storage and processing of your Personal Information through the use of our Website, your registration with the Website, and your use of the Services offered by us;
• you agree to any changes and modifications that we may make to our Privacy Policy in the future; and
• you consent to our branches, affiliates and employees using your Personal Information for sending you information, including promotional material, and that they may contact you in connection with our products and services that you may be interested in, now and in the future (unless you have indicated that you do not want to receive such information). You also consent to us sending you such information by means of direct mail, email, SMS and MMS messages.

What Personal Information do we collect?

5.1. We only collect Personal Information necessary to manage our relationship with you, administer the products and services you request, notify you about our products and services and to comply with applicable laws. Information collected is only used and disclosed in a manner consistent with applicable laws and this Privacy Policy.

5.2. The Personal Information we may collect, hold and/or use about you will depend on the type of product and service you request. Examples of Personal Information we may collect include, but are not limited to:

• your contact details, including your name, postal or street address, email address, telephone numbers and other contact details;
• your identification information, including age or date of birth, gender, tax file number;
• your financial information, including bank account numbers, credit card information  or other information about your financial circumstances;
• details relating to your employment history;
• details relating to your investment profile;
• other identity verification information, including driver’s licence number, copy of driver’s licence, motor vehicle registration number, vehicle plate number, birth or citizenship certificate, passport number, and photographs;
• your device ID, device type, geo-location information, computer and connection information, statistics on page views, traffic to and from the sites, ad data, IP address and standard web log information;
• details of the products and services we have provided to you or that you have enquired about, including any additional information necessary to deliver those products and services and respond to your enquiries;
• any additional information relating to you that you provide to us directly through our website or indirectly through your use of our website or online presence or through other websites or accounts from which you permit us to collect information;
• your IP address, location, analytics and remarketing collected through the use of our Website;
• any other information that we deem necessary in your dealings with us.

5.3. We will only collect, maintain and use Personal Information about you if it is necessary for us to adequately provide you the Services you have requested, provide you with information about other products and services offered by related entities or to meet our obligations under applicable Laws (e.g. the Anti-Money Laundering and Counter-Terrorism Financing Act (2006) (Cth) (the 'AML Act')).

5.4. We will at all times take reasonable steps to ensure that the Personal Information collected and held by us is protected from misuse, loss, unauthorised access and disclosure. You have the right, where it is lawful and practicable, of remaining anonymous when entering into transactions with Trovio. However, should you wish to remain anonymous, we may not be able to provide you with our Services.

5.5. Where you provide us with unsolicited Personal Information which we do not require to deliver the Services to you, such information will be subject to our normal security arrangements for client information. Where reasonable to do so, we will not hold unsolicited Personal Information we do not require, however often we are unable to delete such information, particularly where it forms part of correspondence or other interactions that we do need to retain. Deletion in such circumstances is generally not reasonable or practicable.

5.6. Personal Information records are held for a period considered appropriate to provide you with the Services you require and consistent with applicable laws, including PDPA and the Privacy Act.

5.7. Should you cease to be a client of Trovio, any Personal Information which we hold about you will be maintained for the relevant periods required by applicable laws.

Information collected via our Website

6.1. We may use various technological methods from time to time to track the visiting patterns of individuals accessing our Website, including but not limited to the methods set out below.

Click Stream Data

6.2. When you visit our Website, our Website host and other third parties engaged by us may collect Personal Information for statistical, reporting and maintenance purposes.

6.3. The information collected may include:

• the number of users visiting our Website and the number of pages viewed;
• the date, time and duration of a visit;
• the IP address of your computer; or
• the path taken through our Website.

6.4. Our Website host uses this information to administer and improve the performance of our Website.

Cookies

6.5. If you access our Website, we may collect Personal Information electronically. For example, we may collect information about your visits by using ‘cookies’. A cookie is a packet of information which is sent by our Website to your computer to track your use of our Website and to allow you to efficiently access your account information. Generally, we use cookies for security purposes and to assess the usage and improve the functionality of our website.

6.6. We use both session cookies and persistent cookies. A session cookie is temporary and is automatically destroyed once your web browser is closed. All of the transaction functions of our Website rely on session cookies. These web pages will not work if session cookies are explicitly blocked or disabled within a web browser. A persistent cookie is a small text file stored on the user’s computer for an extended period of time.

6.7. You can opt to set your browser to reject cookies, or to notify you as soon as possible if you are loaded on cookies. If you reject persistent cookies you will still be able to access our Website, but may not be able to use certain features or the web service may not recognise you.

6.8. We take care to ensure that the Personal Information you give us on our Website is protected. Trovio uses a range of security measures to help ensure this security. Our Website contains more detailed information on specific privacy and security procedures.

Google Analytics

6.9. We may use Google Analytics to help analyse how you use our Website. Google Analytics generates statistical and other information about website use by means of cookies, which are stored on users' computers. The information generated is used to create reports about the use of our Website. Google will store this information.

6.10. If you do not want our Website visit data reported by Google Analytics, you can install the Google Analytics opt-out browser add-on. For more details on installing and uninstalling the add-on, please visit the Google Analytics opt-out page at http://tools.google.com/dlpage/gaoptout.

Third party content (e.g. social media links)

6.11. Some of the content used on our Website includes applications made available by third parties, such as social media buttons or links that allow you to share content or links to our Website through the relevant third party platforms. These third party applications themselves may facilitate collection of information by those third parties, through your interactions with the applications and sometimes even if you do not interact directly with them. We are not responsible for the technical operation of these applications or the collection and use practices of the relevant third parties. Please visit the relevant third party websites to understand their privacy practices and options they may make available to you in relation to their collection of your Personal Information.

How do we collect and hold your Personal Information?

7.1. In most cases, we collect your Personal Information directly from you, face to face meetings, application forms or correspondence (written and verbal). However, if this is not practical, we may collect information about you from another person or entity – for example, receiving information from a person to whom you have granted a delegated authority or power of attorney.

7.2. When you use the Website or the Services, we may collect more information necessary in any manner that we consider as in compliance with relevant requirements, for the purpose of improving the functions of the Website or the Services, enhancing your experience of using the Website and the Services as well as the security thereof, or as is required by any court order, any applicable law, administrative regulation or any order of any other competent government agency.

How do we use your Personal Information?

8.1. We use your Personal Information that we collect about you to primarily manage, deliver and administer the Services to you. Personal Information may also be used so that we can offer products and services to you including special offers (with your consent, and subject to your right to unsubscribe or opt-out, as described in paragraph 12.2 below) to extend our relationship with you and to develop products and services better suited to your needs.

8.2. We also use your Personal Information for the purpose of:

• conducting identity verification and customer due diligence;
• preventing and detecting money laundering and terrorism financing;
• determining whether you have any history of defaulting on payment or delivery of securities;
• handling/routing your customer service or technical support questions or issues;
• helping us manage our business operations;
• for business support purposes, including maintenance, backup and audit;
• providing you with products, services or information in accordance with your requests or reasonable expectations;
• administering any accounts you hold with Trovio or any of its affiliates worldwide;
• enabling Trovio or any of its affiliates worldwide to ascertain whether or not they have other services or products which may foreseeably meet your needs or may be of interest to you, and to notify you about these services or products;
• conducting research, planning, product development, risk assessment, risk modelling and marketing  by Trovio or any of its affiliates worldwide;
• sending you marketing, promotional messages and other information  that may be of interest to you;
• considering your employment application and verifying your suitability to work with us;
• complying with our legal obligations  including but not limited to our obligations under the applicable and relevant regulations and legislation;
• resolving any disputes that we may have with any of our users, and enforce our agreements with third parties;
• improving our customer service; or
• collecting and processing payments.
• any other purpose to which you have consented; or
• disclosure where required or authorised by law;

8.3. We may also use and analyse your information to meet our obligations, and our service providers' obligations (if applicable), under applicable laws, for example the Know Your Customer requirements of the AML Act.

8.4. We reserve the right at all times to monitor, review, retain or disclose any information as necessary to satisfy any applicable law, but we have no obligation to monitor the use of the Website or to retain the content of any user session.

8.5. We may occasionally hire other companies to provide services on our behalf, including but not limited to handling customer support enquiries and processing transactions. Those companies will be permitted to obtain only the Personal Information they need to deliver the Services. We take reasonable steps to ensure that these organisations are bound by confidentiality and privacy obligations in relation to the protection of your Personal Information.

8.6. We do not sell, trade or rent your Personal Information to others. We may share generic aggregated demographic information not linked to any Personal Information regarding visitors and users with our business partners, trusted affiliates and advertisers for the purposes outlined in paragraph 9.1 below.

8.7. We may otherwise collect, use or disclose your Personal Information where the collection, use or disclosure is in accordance with this Privacy Policy or any agreement you enter into with us, or required or authorised by law, including without limitation PDPA and the APPs under the Privacy Act.

Who do we disclose information to?

9.1. Trovio will only disclose Personal Information to third parties for the purposes of managing, delivering and administering the Service you require and in accordance with this Privacy Policy and applicable laws. For example, we may disclose relevant Personal Information to:

• agents and brokers (intermediaries) to enable them to efficiently answer enquiries and process transactions;
• for legal reasons, disclosure may need to be made to law enforcement agencies, government agencies, courts or external advisers, for example to meet our obligations under the AML Act;
• a person acting on your behalf including a financial adviser, trustee, attorney or person to whom you have granted a delegated authority;
• service providers engaged to carry out functions on our behalf (e.g. other financial institutions as required, solicitors, software or IT service vendors and auditors/investigators);
• some of these service providers may be located overseas, including in The Netherlands and Germany. Your Personal Information will only be disclosed to one of our service providers, or stored overseas in accordance with this Privacy Policy (as set out in section 11 below entitled 'Disclosure of Personal Information overseas') and applicable laws;
• if you have acquired a product or service through a related entity, your Personal Information may be shared with that related entity on a confidential basis;
• your financial adviser/consultant who in turn may disclose information to superannuation funds, trustees, insurance providers and product issuers for the purpose of giving effect to your financial plan/strategy and recommendations made by them;
• if a financial adviser/consultant has referred you to our products and services then your details (including ongoing investment and transaction details) may be provided to that financial adviser/consultant, the dealer group, the broker or the organisation for whom they work; and
• other third parties with your consent or direction to do so.

Third party websites

10.1. You may find advertising or other content on our Website that link to the websites of our partners, suppliers, advertisers, sponsors, licensors and other third parties. We do not control the content or links that appear on these websites and are not responsible for the practices employed by websites linked to or from our Website. In addition, these websites or services, including their content and links, may be constantly changing. These websites and services may have their own privacy policies and customer service policies. Browsing and interacting on any other website, including websites which have a link to our Website, is subject to that website's own terms and policies.

Disclosure of Personal Information overseas

11.1. Some of your Personal Information may be disclosed, transferred, stored, processed or used overseas by us, or by third party service providers. This may happen if:

our offices are or related entities are located overseas;

we outsource certain activities overseas;

transactions, information, services or products have an overseas connection; or

our computer systems including IT services are located overseas.

11.2. You consent to the collection, use storage, and processing of Personal Information outside of Australia as set out in this Privacy Policy.

11.3. In particular, your Personal Information may be disclosed to third parties in The Netherlands or Germany, and such other countries in which those parties or their, or our, computer systems may be located from time to time, where it may be used for the purposes described in this Privacy Policy. In these circumstances, you consent to the collection, use, storage and processing of your Personal Information in those countries, without us being responsible under PDPA and the Privacy Act for such use (or for any breach). Where such parties are located overseas, you may have rights to enforce such parties' compliance with the applicable data protection laws, but you might not have recourse against those parties under PDPA and the Privacy Act in relation to how those parties treat your Personal Information.

Marketing

12.1. Trovio may use your Personal Information for direct marketing purposes in accordance with paragraph 4.

12.2. If you do not want to receive marketing information from us, you can unsubscribe in any of the following ways:

• clicking on the 'Unsubscribe' or subscription preferences link in a direct marketing email that you have received from us;
• logging into your account on the Website and editing your communication preferences; or
• contacting us using the contact details specified in section 15 below.

How do we protect your Personal Information?

13.1. We have systems and processes in place designed to hold your information securely. Only authorised personnel are granted access to your information. We also have in place processes designed to identify you when you deal with us by phone, online or face to face. These processes are designed to ensure we only disclose your information to you, or someone properly authorised by you. You need to keep access details like user names and passwords confidential and not share them or leave them somewhere that is easy for others to access or find.

13.2. The platform for our Services is built on international security standards.

13.3. Despite the above-mentioned technical and security measures, we cannot guarantee that information transmitted via the Internet is absolutely safe, so we cannot absolutely guarantee that the Personal Information that you provide to us through our Website or the use of the Services will be safe at all times. We will not be held liable for any loss or damage arising from or caused by any event that may occur in connection with unauthorised access to your personal data, and we shall not be held liable in compensation for such loss or damage.

Access and Correction

14.1. You have the right to correct your Personal Information held by us if you believe it to be inaccurate or out of date. We will then amend your records accordingly. If we disagree with the correction, we will advise you of the reasons for doing so and will make a note on your record of this.

14.2. You are generally entitled to access your Personal Information. This can be arranged so by calling or writing to our Privacy Officer. The details of the Privacy Officer's contact information are listed in the section 15 entitled 'Privacy Enquiries and Complaints' below. Your request should include a detailed description of the information required. To ensure information is only disclosed to those entitled to it you may be asked for identification, or in the case of a telephone call asked to answer a series of questions to verify your identity.

14.3. In some circumstances, there may be some legal or administrative reasons to deny access to your Personal Information. If we are unable to provide you with access to your information, we will provide you with reasons for the refusal where we are required by law to give those reasons.

Privacy Enquiries and Complaints

15.1. If you have any requests, comments, enquiries or complaints about our information handling practices, please contact the Privacy Officer (either via email or via mail):

Privacy Officer

Trovio Group

privacy@trovio.io

No. 11, 259 George Street

Sydney NSW 2000, Australia

15.2. You can also contact us if you believe that the privacy of your Personal Information has been compromised or not adequately protected.

15.3. It is our intention to resolve any complaint as quickly as possible and to your satisfaction. If you are not satisfied with the response provided by us, please let us know and our Privacy Officer will investigate further and respond to you. If you are still not satisfied or if we do not respond to your complaint within 30 days, you can contact relevant external bodies that deal with privacy complaints.

If you are dealing with TCM Capital AM Pty Ltd, you may contact the Australian Financial Complaints Authority:

Australian Financial Complaints Authority

GPO Box 3

Melbourne VIC 3001

Tel: 1800 337 444

Fax: +61 3 9613 6399

Website: www.afca.org.au

Email: info@afca.org.au

If you are dealing other Trovio’s related entities or your dispute with the Australian Financial Complaints Authority fails to reach a satisfactory outcome, you may with to contact the Office of the Australian Information Commissioner. This body may forward your complaint to another external dispute resolution body if it considers the complaint would be better handled by that body.

Office of the Australian Information Commissioner

GPO Box 5218

Sydney NSW 2001

Telephone: 1300 363 992

Website: www.oaic.gov.au

15.4. This Privacy Policy is provided for the purposes of information only. While we have taken care to ensure that it is accurate and current, we provide no guarantee as to its accuracy or currency. We accept no liability for loss or damage suffered as a result of reliance on the information provided in this Privacy Policy.

Modification to the Privacy Policy

16.1. We reserve the right to amend the Privacy Policy from time to time and at any time. We will inform you of the modifications made to the Privacy Policy by updating and publishing the effective date of the release of new versions hereof. We may issue a notice to inform you of any modifications made to the Privacy Policy, but we are not obliged to do so.

16.2. You are required to regularly review the Privacy Policy and focus on its modifications, and if you do not agree to such modifications, you shall immediately stop accessing this Website. When an updated version of this Privacy Policy is released, your continued visit to this Website will indicate and show that you agree to the update and agree to comply with the updated Privacy Policy.

This Privacy Policy was last updated on 12th September 2022.