TERMS OF SERVICE You are free to express your opinion however; we would not tolerate objectionable content or abusive users. Any comment or post with racist, insult or sexual-related, hate, etc will be immediately removed and the user’s account will be suspended.

TopAccolade is an international News Media Platform that brings both local and international news events and updates to our general audience. We pride ourselves in promoting the best talents in our community through our platforms including social media while we maintain the privacy of the information we hold for our users. If you do register or use our mobile apps and services, you trust us with your personal information in line with our privacy policies which we do take very seriously. In this privacy information, we explain our privacy policy in the clearest possible way about what information we collect and how we use it, including rights on how we use it. It is advisable you take some time to carefully read through it and if you find urge you to discontinue using the app, should you find any terms in this privacy policy that you do not agree with.

Our privacy policy applies to all the information collected through our mobile application and/or any associated services such as sales, marketing, or events (we refer to them collectively in this privacy policy as the "Sites"). Please read this privacy policy carefully as it will help you make informed decisions about sharing your personal information with us.

TABLE OF CONTENTS 1. WHAT INFORMATION DO WE COLLECT? 2. HOW DO WE USE YOUR INFORMATION? 3. WILL YOUR INFORMATION BE SHARED WITH ANYONE? 4. HOW DO WE HANDLE YOUR SOCIAL LOGINS? 5. WHAT IS OUR POSITION ON THIRD-PARTY WEBSITES? 6. HOW LONG DO WE STORE YOUR INFORMATION? 7. HOW SAFE IS YOUR INFORMATION WITH US? 8. DO WE COLLECT INFORMATION FROM MINORS? 9. WHAT ARE YOUR PRIVACY RIGHTS? 10. DO UK RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS? 11. DO WE UPDATE THIS POLICY? 12. HOW CAN YOU CONTACT US ABOUT THIS POLICY?

1. WHAT INFORMATION DO WE COLLECT?

The personal information you disclose to us We do collect personal information that you provide to us at the time of registering on the app, such as name, email or phone number, or address. Such information would be collected by expressing an interest in obtaining information about us or our products and services, when participating in activities on the Apps, such as when making a post, comment, or entering a competition, a contest, a giveaway, or when you contact us.

The personal information that we collect will always depend on the context of your enquiry or interest in our service and our Apps, the choices you make, and the products, services or App features you use. This personal information or data we collect can include the following: Name and Email. We would collect your name, email address, local city, and phone number.

Social Media Login. We provide you with the option to register using social logins. If you choose to register in this way, we will collect the information described in the section called "HOW DO WE HANDLE YOUR SOCIAL LOGINS" below. All personal information that you provide to us must be true, complete, and accurate, and we request that you notify us of any changes to such personal information.

Auto-collected Information Some information, such as IP Address and/or browser and device types are collected automatically when you visit or use our Apps. This information does not in any way reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser, and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Apps and other technical information. This information is primarily needed to maintain the security and operation of our Apps, and for our internal analytics and reporting purposes.

Device and Location Information

When you use our Apps, we may collect information regarding your geo-location, mobile device, and push notifications: • Geo-Location Information. We may request access or permission to know your mobile device information, either continuously or while you are using our mobile application, to provide location-based services such as local news. If you wish to change our access or permissions, you may do so in your device’s settings.

• Mobile Device Data. We may automatically collect device information (such as your mobile device ID, model, and manufacturer), operating system, version information, and IP Address.

• Push Notifications. We may request to send you to push notifications regarding your account or the mobile application. If you wish to opt out from receiving these types of communications, you may turn them off in your device’s settings.

Information collected from other sources We may collect limited data from public databases, marketing partners, social media platforms, and other outside sources.

We may obtain information about you from other sources, such as public databases, joint marketing partners, social media platforms, such as Facebook, Instagram, and Twitter as well as from other third parties. Examples of the information we receive from other sources include social media profile information which may be your name, gender, birthday, email, current city, state, and country, user identification numbers for your contacts, profile picture URL, and any other information that you choose to make public) ; marketing leads and search results and links, including paid listings, such as sponsored links.

2. HOW DO WE USE YOUR INFORMATION? We process your information for purposes based on legitimate business interests, the accomplishment of our contract with you, compliance with our legal obligations, and/or your consent. We use personal information collected via our Apps for a variety of business purposes described below. We process your personal information for these purposes in compliance with our legitimate business or marketing interests. In order to enter into or perform a contractual agreement with your consent and/or for compliance with our legal obligations, we indicate the specific processing grounds we rely on next to each purpose listed below. We may use the information we collect or receive:

• To facilitate account creation and login process with your Consent. If you choose to link your account with us to a third-party account, such as your Google or Facebook account, we use the information you allowed us to collect from those third parties to facilitate the account creation and login process. See the section below headed "HOW DO WE HANDLE YOUR SOCIAL LOGINS" for further information.

• To display marketing and promotional communications for Business Purposes and/or with your Consent. We and/or our third-party marketing partners may use the personal information you send to us for our marketing purposes if this is in accordance with your marketing preferences. (see the "WHAT ARE YOUR PRIVACY RIGHTS" below).

• To send administrative information to you for Business Purposes, Legal Reasons, and/or possibly Contractual Purposes. We may use your personal information to send you the product, service, and new feature information and/or information about changes to our terms, conditions, and policies.

• Deliver targeted advertising to you for our Business Purposes and/or with your Consent. We may use your information to develop and display content and advertising (and work with third parties who do so) tailored to your interests and/or location and to measure its effectiveness.

• To enable user-to-user communications with your Consent. We may use your information in order to enable user-to-user communications with each user's consent.

• To enforce our terms, conditions, and policies for Business Purposes, Legal Reasons, and/or possibly Contractual Agreements.

• To respond to legal requests and prevent harm for Legal Reasons. If we receive a court warrant or other legal request, we may need to inspect the data we hold to determine how to respond.

• For other Business Purposes. We may use your information for other Business Purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns, and evaluating and improving our Apps, products, services, marketing, and your experience.

3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?

We do not share your personal information such as Name, Email, and Phone number with anyone. But we may share other non-personal information, such as your local city to display local ads, with your consent, to comply with laws, to protect your rights, or to fulfill business obligations.

We would only share and disclose your information in the following situations:

• Compliance with Laws. We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal processes, such as in response to a court order or a subpoena, including in response to public authorities to meet national security or law enforcement requirements.

• Vital Interests and Legal Rights. We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved. v • Vendors, Consultants, and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors, or agents who perform services for us or on our behalf and require access to such information to do that work. Examples include data analysis, email delivery, hosting services, customer service, and marketing efforts. We may allow selected third parties to use tracking technology on the Apps, which will enable them to collect data about how you interact with the Apps over time. This information may be used to, among other things, analyse and track data, determine the popularity of certain content, and better understand online activity. Unless described in this Policy, we do not share, sell, rent, or trade any of your information with third parties for their promotional purposes.

• Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

• Third-Party Advertisers. We may use third-party advertising companies to serve ads when you visit the Apps. These companies may use information about your visits to our Website(s) and other websites that are contained in web cookies and other tracking technologies in order to provide advertisements about goods and services of interest to you.

• With your Consent. We may disclose your personal information for any other purpose with your consent.

• Other Users. When you share personal information for example, by posting comments, contributions, or other content to the Apps or otherwise interacting with public areas of the Apps, such personal information may be viewed by all users and may be publicly distributed outside the Apps in perpetuity. If you interact with other users of our Apps and register through a social network, such as Facebook, your contacts on the social network will see your name, profile photo, and descriptions of your activity. Similarly, other users will be able to view descriptions of your activity, communicate with you within our Apps, and view your profile.

4. HOW DO WE HANDLE YOUR SOCIAL LOGINS?

If you choose to register or log in to our websites using a social media account, we may have access to certain information about you.

Our Apps offer you the ability to register and login using your third-party social media account details such as Facebook or Google login. Where you choose to do this, we will receive certain profile information about you from your social media provider. The profile information we receive may vary depending on the social media provider concerned, but will often include your name, e-mail address, friends list, profile picture as well as other information you choose to make public.

We will use the information we receive only for the purposes that are described in this privacy policy or that are otherwise made clear to you on the Apps. Please note that we do not control and are not responsible for other uses of your personal information by your third-party social media provider. We recommend that you review their privacy policy to understand how they collect, use and share your personal information, and how you can set your privacy preferences on their sites and apps.

5. WHAT IS OUR POSITION ON THIRD-PARTY WEBSITES?

We are not responsible for the safety of any information that you share with third-party providers who advertise, but are not affiliated with, our apps or websites.

The Apps may contain advertisements from third parties that are not affiliated with us and which may link to other websites, online services, or mobile applications. We cannot guarantee the safety and privacy of the data you provide to any third parties. Any data collected by third parties is not covered by this privacy policy. We are not responsible for the content or privacy and security practices and policies of any third parties, including other websites, services, or applications that may be linked to or from the Apps. You should review the policies of such third parties and contact them directly to respond to your questions.

6. HOW LONG DO WE KEEP YOUR INFORMATION?

We would keep your information for as long as you would want us to do while observing the government regulations on GDPR to fulfill the purposes outlined in this privacy policy.

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy policy unless a longer retention period is required or permitted by law, such as tax, accounting, or other legal requirements. No purpose in this policy will require us to keep your personal information for longer than the period in which users have an account with us.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible for example, because your personal information has been stored in backup archives, then we will securely store your personal information and isolate it from any further processing until deletion is possible.

7. HOW SAFE DO WE KEEP YOUR INFORMATION?

We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, please also remember that we cannot guarantee that the internet itself is 100% secure. Although we will do our best to protect your personal information, the transmission of personal information to and from our Apps is at your own risk. You should only access the services within a secure environment.

8. DO WE COLLECT INFORMATION FROM MINORS?

We would not collect data from children under 18 years of age.

We would never intentionally solicit data from or market to children under 18 years of age. When you use the Apps, you consent 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 Apps. 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 have collected from children under the age of 18, please contact us at [email protected].

9. WHAT ARE YOUR PRIVACY RIGHTS?

In European Economic Area, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.

In this mentioned region above, you have certain rights under applicable data protection laws. These may include the following:

(i) Right to request access and obtain a copy of your personal information.

(ii) Right to request rectification or erase your data.

(iii) Right to restrict the processing of your personal information.

(iv) Right if applicable, to data portability.

In certain circumstances, you may also have the right to object to the processing of your personal information. To make such a request, please use the contact details provided below. We will consider and act upon any request in accordance with applicable data protection laws.

If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. Please note however that this will not affect the lawfulness of the processing before its withdrawal.

If you are a resident of the European Economic Area and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm

Account Information If you would at any time like to review or change the information in your account or terminate your account, you can:

■ Contact us using the contact information provided.

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, some information may be retained in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms of Use, and/or comply with legal requirements. Opting out of email marketing: You can unsubscribe 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 will still need to send you service-related emails that are necessary for the administration and use of your account. To otherwise opt-out, you may:

■ Contact us using the contact information provided.

10. DO UK RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

Yes, if you are a resident of the United Kingdom, you are granted specific rights regarding access to your personal information.

General Data Protection Regulation was activated on the 25th of May 2018 and this permits our users who are UK residents to request the right of information to their data amongst other rights. If you are a UK resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.

If you are under 18 years of age, reside in the UK, and have mistakenly registered an account with the Apps, you have the right to request the removal of unwanted data that you publicly post on the Apps. To request the removal of such data, please contact us using the contact information provided below, and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Apps, but please be aware that the data may not be completely or comprehensively removed from our systems.

11. DO WE UPDATE THIS POLICY?

Yes, we will update this policy as necessary to stay compliant with relevant laws. We may update this privacy policy from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy policy, we may notify you either by posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy policy frequently to be informed of how we are protecting your information.

12. HOW CAN YOU CONTACT US ABOUT THIS POLICY?

If you have questions or comments about this policy, you may email us at [email protected]

If you have any further questions or comments about us or our policies, email us at [email protected]

HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Based on the laws of some countries, you may have the right to request access to the personal information we collect from you, change that information, or delete it in some circumstances. To request to review, update, or delete your personal information, please contact us at [email protected] We will respond to your request within 30 days.