Better-than-Freehold® (BtF®) Privacy Policy

1. Introduction

This Privacy Policy describes how Venture Management Ltd. ("VM"), the creator and owner of the Better-than-Freehold® (BtF®) intellectual property ("IP"), including its associated legal persons, unincorporated organizations, and teams that provide Better-than-Freehold® Services (collectively, the "VM and/or Better-than-Freehold® Operators", "we", "our", and "us"), collect, use, process, disclose, share, transfer, and protect the information you provide on the Better-than-Freehold® website (https://betterthanfreehold.com) and the BtF® dashboard/portal. This Privacy Policy constitutes a part of the Terms of Use of the Better-than-Freehold® Platform (https://betterthanfreehold.com/terms/).

The defined terms used in this Privacy Policy shall bear the same meaning given to such terms as those stipulated in the Terms of Use, unless otherwise indicated herein. We respect and value your privacy as well as the integrity of the information you have provided and/or permitted us to collect. Thus, we endeavour to follow industry standards to ensure the security and confidentiality of your Personal Information (as defined below) when you access the Better-than-Freehold® Platform or use any of the Better-than-Freehold® Services. When accessing, registering, downloading, using, clicking, or engaging in any of the Better-than-Freehold® Services provided through the website or on the Better-than-Freehold® Platform, you are strongly advised to carefully read, acknowledge, understand, and accept all terms stipulated in this Privacy Policy. Unless upon providing you with a prior notification and obtaining your consent, we will not use your Personal Information, in any form, for any other purposes other than those indicated in this Privacy Policy or the Terms of Use.

This Privacy Policy has incorporated provisions from the General Data Protection Regulation ("GDPR") and from GDPR as it forms part of the law of the United Kingdom ("UK GDPR"), in particular with regard to the rules governing the processing of Personal Information within the European Economic Area (EEA) and the United Kingdom respectively, and in accordance with Thailand's Personal Data Protection Act B.E. 2562 (2019) ("Thai PDPA"), and other applicable global data protection standards.

This Privacy Policy shall inform you about the following matters among several others:

• Acceptance of the Privacy Policy
• Personal Information collected by us
• How we collect Personal Information
• How we use Personal Information
• How we store Personal Information
• How long we retain Personal Information
• Cookies, heatmaps, and session recording
• Sharing your Personal Information
• Third-Party collection of Personal Information
• Your legal rights
• Rights of the residents in EEA and the UK
• Limitations for age and data breaches
• Updates or amendments to the Privacy Policy
• Transferring your Personal Information outside the UK and the EEA or Thailand
• How to contact the Better-than-Freehold® Operators

2. Acceptance of the Privacy Policy

By accessing, using, or engaging in the Better-than-Freehold® Services, you indicate and confirm that you have agreed to the terms of this Privacy Policy. Unless upon providing you with a prior notification and obtaining your consent, we will not use your Personal Information for any purposes other than those indicated in this Privacy Policy or the Terms of Use unless we are entitled or required to do so by Applicable Laws. If you do not agree, either partially or wholly, to this Privacy Policy, you must immediately discontinue accessing, using, or engaging in the Better-than-Freehold® Services and the Better-than-Freehold® Platform.

3. Personal Information

For the purposes of this Privacy Policy, your Personal Information is information that can be used to identify, describe, relate, or associate with a particular individual and includes "personal data" as defined in GDPR, UK GDPR, and the Thai PDPA. The following are the types of information we collect and store when you use the Better-than-Freehold® Services (collectively, the "Personal Information"):

Information provided by you when registering on or using the Better-than-Freehold® Platform: When you first sign up to use the Better-than-Freehold® Services by contacting a Better-than-Freehold® agent, you may be required to provide us with your real name, date of birth, nationality, home address, email address, telephone number, signature, and other information which can be used to verify your identity. Generally, we will not collect nor process "Sensitive Information" (defined in GDPR, UK GDPR, and Thai PDPA as "special or sensitive categories of personal data"), such as racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data that uniquely identify specific persons, or any information concerning health or sexual orientation. However, if you are using biometric authentication methods to use the Better-than-Freehold® services and/or sign into a/your Better-than-Freehold® Account, you are required to provide us with your fingerprint data or facial recognition data; we shall need to seek your explicit consent to process such biometric data to comply with our legal obligations.

Information collected by us for compliance purposes: In order to comply with domestic and international industry standards, government rules and regulations, in particular the Anti-Money Laundering (AML) regulations, Know Your Customer (KYC) rules, and Counter-Terrorist Financing (CTF) regulations, the Better-than-Freehold® Operators and Third-Party Service Providers are required to collect and retain your Personal Information from identification documents, such as your passport, national identification card, driver's license, tax identification, and visa. Other documents which we may use include, but are not limited to, your proof of address, source of funds declaration, purpose and source of wealth.

Information collected by us during your usage of the Better-than-Freehold® Services: When you engage or use the Better-than-Freehold® Services, we will monitor and track your Personal Information in relation to your usage of the Better-than-Freehold® Services such as your IP address, phone number, the type of device you use to access the Better-than-Freehold® Platform, device information, operating system and hardware settings, browser type, and network operator. This information shall either be directly obtained by the Better-than-Freehold® Operators or through Third-Party Service Providers. We collect this type of information to ensure that the Better-than-Freehold® website and/or Platform is seamlessly accessible for all permitted Users around the world and in order to provide you with the Better-than-Freehold® Services.

Communication of Personal Information: You hereby agree that we are entitled to collect and use the Personal Information you have provided through the website or Better-than-Freehold® Platform or generated through your usage of the Better-than-Freehold® Services for the purpose of communicating with you through messages, requests, emails, telephone conversations, voicemails, and live chats. Such information will include file attachments in connection with your transactions on the Better-than-Freehold® Platform, or any other information related to your contact with the Better-than-Freehold® Operators.

Financial Information: You hereby agree that, for the purposes stipulated in this Privacy Policy, we are entitled to collect and use the information contained in or related to your financial information as provided by you during the usage of the Better-than-Freehold® Services. This includes, without limitation, your real estate and property holdings, transaction history, withdrawal requests, digital wallet/blockchain address(es), bank name, bank account information, and payment card number/s. We also collect and process this financial information to monitor any suspicious financial activities in order to protect Users from fraud, resolution of legal cases, as well as any other purposes as disclosed in this Privacy Policy.

4. How we collect Personal Information

We will automatically collect and process Personal Information provided by you under the following situations:

• When you register for a Better-than-Freehold® Account, log in, or visit the Better-than-Freehold® Platform.
• When you voluntarily complete any user survey or provide feedback to us via emails or any other electronic channels.
• When you use browser cookies, heatmaps, session recording, or any other relevant software upon visiting the Better-than-Freehold® website or Platform.
• Other situations where we may automatically collect your information as described in this Privacy Policy or our Terms of Use.

Where we ask you for your Personal Information which you are obliged to provide to us, you may decline to provide it to us, but if you do so, we may not be able to enter into or to perform our contract with you to provide the Better-than-Freehold® Services, and we may have to terminate our relationship. For other Personal Information which you may not be under an obligation to provide to us but which we seek from you, if you do not provide it, then we may not be able to properly perform our arrangements with you.

Information collected by third-parties: We shall collect your Personal Information from third parties as required or to the extent permitted under any Applicable Laws. Information from third-party sources shall include, but not be limited to, public databases, credit bureaus, ID verification partners, blockchain data, marketing partners and resellers, advertising partners, and analytics providers.

Anonymised and Aggregated Data: We will also process other Personal Information to convert it into the form of anonymized and aggregated information, where all information shall be combined and then anonymized, making it unusable for the identification of a specific individual. We use anonymized or aggregated Users' information for the purposes stipulated in this Privacy Policy at any time, including gaining a better understanding of Users' needs and behaviours, conducting business intelligence and marketing initiatives, and detecting security threats. In this regard, we reserve the right to implement innovative technologies as they become available to be used for strategic planning and operational processes.

5. How we use Personal Information

Your Personal Information shall be made available to the Better-than-Freehold® Operators, our affiliates and service providers, and/or within our group of companies. This will include, but not be limited to, the employees and/or any persons or Third-Party Service Providers working with the Better-than-Freehold® Operators who are responsible for using and protecting your Personal Information. Where it is necessary (e.g., to protect the vital interest of the users or other natural persons, to fulfill the purpose of public interest, or to pursue our legitimate interest without overriding your rights and freedoms), we may use and process your Personal Information without obtaining your consent.

We use and process your Personal Information for the following purposes or in the following manners:

• To provide the Better-than-Freehold® Services: We use your Personal Information, either collected or delivered, in order to maintain and provide efficient Better-than-Freehold® Services in accordance with our contractual obligations owed to you (including, but not limited to, processing transactions) and, for our and your legitimate interests, to improve the efficiency of day-to-day Better-than-Freehold® Services and, to comply with our legal obligations.
• To verify your identity: We use IP addresses and unique identifiers stored in your device's cookies to help us authenticate your identity and activities and provide the Better-than-Freehold® Services.
• To protect Users as part of the provision of Better-than-Freehold® Services: In order to comply with our legal obligations, we use the information collected to protect the Better-than-Freehold® Platform, Users' Better-than-Freehold® Accounts, and archives. We also use IP addresses and cookies to detect any suspicious activities and to protect against automated abuse, such as spam, phishing, and Distributed Denial of Service (DDoS) attacks.
• To comply with the relevant legal rules and regulations: For our legitimate interests and to comply with our legal obligations, we shall use the Personal Information in compliance with our legal obligations, global and local industry standards, government requests, and our AML/KYC/CTF procedures.
• For measurement, research, and development purposes: For our and your legitimate interests, we actively measure and analyse your Personal Information to understand the way you use and interact with the Better-than-Freehold® website and Services. This review is continuously conducted by our operational teams to continuously improve the Better-than-Freehold® website and/or Platform's performance and to resolve issues with User experience. In addition, for the same reasons, we use such information to customize, measure, and improve the Better-than-Freehold® Services, our administration, the content and layout of the Better-than-Freehold® website and Platform, and to develop new services for you.
• For communication purposes: We use your Personal Information, collected or derived from your communication devices or your email address, to interact with you directly, to provide you with necessary support, and/or to keep you informed of logins, transactions, your Better-than-Freehold® Account security details, as well as other aspects. All direct communications shall be appropriately maintained with the Better-than-Freehold® Operators or Third-Party Service Providers designated to be reviewed for accuracy, retained as evidence, or used to perform other statutory requirements or other obligations as stipulated in this Privacy Policy, the Terms of Use, or any other privacy policy of any relevant Third-Party Service Provider. This is in your and our legitimate interests and to enable us to perform the contract we have with you and to comply with our legal obligations.
• To enforce the Terms of Use: Personal Information is also used, for our legitimate interests, to continuously and actively enforce our Terms of Use among our Users. Activities in this regard include, but are not limited to, reviewing, investigating, and preventing any potentially prohibited or illegal activities that may violate preceding provisions, or disclose relevant information to third parties in accordance therewith. In light of this, we reserve the right to suspend or terminate any of the Better-than-Freehold® Services to any Users who are found to be engaged in any activities that violate our Terms of Use.
• For marketing and advertising: For our legitimate interests, we may share your Personal Information with our marketing partners for the purposes of targeting, modelling, and/or identifying analytics as well as marketing and advertising services which are the same as or similar to the Better-than-Freehold® Services. In any marketing communications which are sent to you, you will be advised as to how you can opt-out of receiving any further marketing communications from us or such partners.
• For rebates: For your referrer's and our legitimate interests, we shall share the Personal Information collected from you, including but not limited to, your identification information and transaction information, with your referrer for the purposes of rebates and other benefits.
• For other purposes: Save as provided in this Privacy Policy and the Terms of Use, unless upon providing you with a prior notification and obtaining your consent, we will not use your Personal Information for any other purposes other than those indicated in this Privacy Policy or the Terms of Use.

6. How we store your Personal Information

We shall take great care in implementing and maintaining the security of the Better-than-Freehold® Services as well as that of your Personal Information. We employ procedures and policies that incorporate industry best practices to ensure the integrity of your Personal Information and to prevent instances of unauthorized use. The Better-than-Freehold® Platform's security is fully integrated into reputable cloud service providers' database facilities and third-party service technology providers such as ActiveCampaign, Moxo, AWS, Google Cloud & DigitalOcean Cloud Infrastructure etc., covering all aspects of security such as identity management, connection security, application security, and database security for User's interactions with the Better-than-Freehold® Platform. Please note that it is impossible to fully guarantee the security of your Personal Information. While we take reasonable steps to safeguard your Personal Information, we disclaim any liability for the acts committed by those who gain unauthorised access or abuse your information and services unless caused by our gross negligence. Thus, you are recommended to understand this responsibility and to independently take the necessary safety precautions to protect your Personal Information, in particular your credential information, such as your username and password. You hereby agree that we shall not be liable for any information leakage and/or other losses not caused by our gross negligence, including but not limited to, hacker attacks, power interruptions, or unavoidable technical failures.

7. How long we retain your Personal Information

We may be required by Applicable Laws to retain certain information, including Personal Information of Users, Users' profiles, identification verification materials, information relevant to AML/KYC/CTF procedures, account information, account agreements, and other agreements between us and third-parties, account statements, and other records. Such records shall generally be retained as required by law for the minimum amount of time necessary to accomplish the purpose for which it is collected and thereafter no longer than is permitted under Better-than-Freehold® Operators' Information Retention Policy. However, even after you have deactivated your Better-than-Freehold® Account, we may retain copies of information about you and any transactions or services which you may have participated in for a period of time in accordance with the applicable laws, statute of limitations, or as we believe as reasonably necessary to comply with the applicable laws, regulations, legal procedures, or governmental requests in order to detect or prevent fraud, outstanding fees, resolve disputes, address problems with the Better-than-Freehold® Services, assist with investigations, enforce any of our Terms of Use or other applicable agreements or policies, or to take any other actions consistent with Applicable Laws.

8. Cookies, Heatmaps, and Session Recording

We shall use cookies, heatmaps, session recording, and other technologies or methods of web and mobile analysis to gather, store, and track certain information related to your access to and activities through the Better-than-Freehold® Services, including when you visit the Better-than-Freehold® Platform. This includes, but is not limited to, mouse movements, clicks, scrolling behaviour, and other non-personally identifiable information. This data helps us understand user interaction, improve user experience, and optimize our services. By using the Site and dashboard/portal, you acknowledge and consent to such data collection and analysis.

9. Sharing your Personal Information

We shall not rent, sell, or disclose your Personal Information to any third parties, except as set out in this Privacy Policy, to those who require access to the Personal Information to perform their tasks and duties, and to share with third parties who have a legitimate interest in accessing it. We may share, transfer, disclose, or allow access to your Personal Information to the following third parties for the purposes described below:

• We may disclose Personal Information to third parties in order to administer or process a transaction, to provide the Better-than-Freehold® Services you have authorized or requested, or in the context of facilitating the execution of a transaction.
• We may be required to validate your identity by Applicable Laws and rely on third-party services to perform these validations. Personal Information that you provide to us during the account opening process is passed to these services at account opening and on an ongoing basis thereafter.
• We provide Personal Information that you provide during the account opening process, as required by the Applicable Laws and regulatory requirements, to carry out or aid in certain functions, including, but not limited to, account processing, surveillance, reconciliation, execution, document retention requirements, and document dissemination.
• We share your Personal Information with financial institutions with which we partner to process payments which you have authorized.
• We may share analysis based on anonymous User information or behaviour with our affiliate companies in order to operate and improve our products and services.
• We may disclose or transfer your Personal Information to a purchaser or potential purchaser of our business, to our investors in and lenders to our business, and to our financial and professional advisors.
• We may disclose or transfer information we collect upon account closing.
• We may disclose your Personal Information for certain promotions and special offers when the nature of the promotion or special offer requires us to gather and share your Personal Information (such as your email address) with a third-party for delivery of goods or services. Please note that, should you choose to purchase a product or service offered by another company by way of a promotion or special offer, any Personal Information you share with that company would no longer be governed by this Privacy Policy.
• We may disclose Personal Information to third parties that provide services to us to enable us to provide the Better-than-Freehold® Services, including but not limited to, consulting, sales, client support operations, payment processing, authentication services, and technical support or services.
• We may share your Personal Information with law enforcement and government officials, or any other third parties where we are required to do so under any applicable law, regulation or by order of any court of competent jurisdiction or any competent judicial governmental or regulatory body or exchange rule, or when we believe in good faith that the disclosure of Personal Information is necessary to prevent physical harm or financial loss, to report suspected illegal activity, or to investigate violations of any of our Terms of Use or any other applicable policies.

Other circumstances under which we may disclose your Personal Information are as follows:

• Comply, as necessary, with any relevant Applicable Laws.
• In order to perform our contractual obligations to you.
• Respond to mandatory legal or governmental requests or demands for information.
• Meet national security requirements.
• Enforce our agreements, policies, procedures, and/or Terms of Use.
• Where it is in our legitimate interests to do so and our right to do so is not overridden by your rights and freedoms.
• Protect ourselves, our affiliates, our Users, our counterparties, or the general public from illegal activities.
• Respond to a vital emergency that requires disclosure of specified information.

Save as provided in this Privacy Policy or in the Terms of Use, we will not disclose to third parties your Personal Information, such as details of your Better-than-Freehold® Account or the transactions you made including usage of the website. You are entitled to opt-out of having your Personal Information shared with third parties, or from allowing us to use your Personal Information for any purposes which are incompatible with the purposes for which we have originally collected or subsequently obtained your authorization as stipulated in this Privacy Policy. All independent affiliates and third parties with whom we share your Personal Information have their own privacy policies. However, we expect them to protect your Personal Information in accordance with provisions which are substantially similar to those provided in this Privacy Policy.

10. Third-Party Collection of Personal Information

This Privacy Policy only addresses the use and disclosure of the Personal Information we collect from you. To the extent that you disclose your information to other parties through the use of the Better-than-Freehold® Services, such as by clicking on a link to any other websites, different rules regarding privacy policies may apply to their use or disclosure of the Personal Information you disclose to them. We recommend that you read the privacy policies of such third parties before disclosing any Personal Information to them. You hereby acknowledge that we shall not be responsible for the products, services, or descriptions of products or services that you receive from the third-party websites or for the content or privacy practices of those websites. Also, this Privacy Policy shall not be applied to any such third-party products and services that you access through the Better-than-Freehold® Platform. You knowingly and voluntarily assume all risks of using third-party websites to purchase products and services, and you agree that we shall have no liability whatsoever concerning such third-party websites and your usage of them.

11. Your Legal Rights

Under certain circumstances, you have the rights under the data protection laws in relation to your Personal Information. These rights include but are not limited to the following:

• Right to be informed: You have the right to be informed about the collection, use, and processing of your Personal Information. This Privacy Policy is intended to provide this information, but please contact us as set out below if you require any further information.
• Right of access: You have the right to obtain access to the Personal Information we hold about you and specific information regarding our processing of this information.
• Right to rectify: You have the right to require us to rectify your Personal Information that is inaccurate. You can check your account details at any time by signing into your Better-than-Freehold® Account and clicking the profile.
• Right to erasure: You may require us to have your Personal Information deleted from our records where certain conditions are met. In order to deter fraudulent activities by ensuring that those who try to commit fraud shall not be able to avoid detection simply by closing their Better-than-Freehold® Accounts and opening new accounts, we shall mark your Better-than-Freehold® Account in our database as "Closed," but shall keep certain account information, including your request to erase your Personal Information in our database for a period of time. However, if you close your Better-than-Freehold® Account, your Personal Information shall not be used by us for any further purposes, nor shared with third parties, except as necessary to prevent fraud and to assist law enforcement as required by Applicable Laws or in accordance with this Privacy Policy.
• Right to data portability: You reserve the right to request to transfer a machine-readable copy of your Personal Information to you or the third-party of your choice. We shall provide you, or the third-party, your Personal Information in a machine-readable format. This right only applies to Personal Information you have provided to us to use.
• Right to restrict processing: You may request us to restrict or suppress the processing of your Personal Information under certain circumstances, including to establish the accuracy of the Personal Information; when the processing is considered unlawful, but you do not wish to have your Personal Information erased; where we no longer need to process your Personal Information, but the information must be retained for legal reasons; or where you have objected to our processing your Personal Information, but we need to determine whether our legitimate interest overrides your objection.
• Right to object: You may object to our reliance on our legitimate interests as the basis of us processing your Personal Information which may impact your personal rights. You may also object to our processing of your Personal Information for any direct marketing purposes.
• Right to withdraw consent ("Opt-out"): You reserve the right to withdraw your consent at any time where we are relying on it to process your Personal Information. Withdrawing your consent does not affect the lawfulness of our processing of your Personal Information prior to withdrawing, and we are entitled to continue processing your Personal Information where we have other legal bases for doing so. If you wish to exercise these rights as aforementioned, please inform and contact us via the Better-than-Freehold® Platform as set out below.
• Right to lodge a complaint: You have the right to make a complaint to your local privacy regulator. If you reside in an EEA Member State, you have the right to make a complaint about the way we process your personal data to the supervisory authority in the EEA Member State of your habitual residence, place of work, or place of the alleged infringement. You can also contact your local privacy regulatory if you have any concerns regarding your rights under local law. If you wish to make a complaint, we would ask that you contact us before you contact the regulator so that we may see if the issue can be resolved first.

12. Rights of the residents of the EEA

If you are a resident of the EEA, United Kingdom, or Switzerland at the time your Personal Information is collected, you still reserve every legal right as stipulated in Clause 11 as mentioned above. Also, we shall specifically apply legal requirements under the GDPR and UK GDPR (as applicable) for collecting, using, or processing your Personal Information. In the case where some recipients are located outside the EEA, Switzerland, or the UK, we shall transfer your Personal Information only to such countries as approved by the European Commission or the UK's Information Commissioner (as relevant) as providing an adequate level of data protection or enter into legal agreements ensuring an adequate level of data protection in the jurisdiction of the party receiving the information.

13. Limitations for age and data breaches

The Better-than-Freehold® Services are not designed for individuals who are under the age of 18 or under the legal age to provide consent under the applicable laws of the country or jurisdiction where you are using the Better-than-Freehold® Services. If you are not over 18 or of the legal age of your country, you shall not provide any Personal Information to us, or to engage in the Better-than-Freehold® Services. We reserve the right to access and verify any Personal Information collected from you. If we become aware that you are under 18 or under the legal age and you have already shared your Personal Information with us, we shall then discard such information and terminate your Better-than-Freehold® Account immediately.

We cannot guarantee that any losses, misuses, unauthorised accession, or alteration of your Personal Information shall not occur. You hereby agree that you play a vital role in protecting your Personal Information, including your credentials. When registering with the Better-than-Freehold® Services, you are strongly recommended to choose a password with sufficient length and complexity and to not reveal this password to any third parties or unauthorized persons. Also, you agree that you shall immediately notify us if you become aware that unauthorized persons have accessed or might access your Better-than-Freehold® Account.

14. Transferring your Personal Information outside the UK and the EEA

Your Personal Information may be transferred to and stored in countries outside of the UK and the EEA. We will take all reasonable steps to ensure that your Personal Information is only used in accordance with this Privacy Policy and will put in place appropriate safeguards to protect your Personal Information when it is transferred to such countries.

15. The Better-than-Freehold® Operational Structure

The Better-than-Freehold® platform operates through a four-entity structure designed for legal compliance and operational efficiency. This structure includes TIN (Thai Investment Nominee), SPH Trustees (Singapore Private Trust Company), CBSA (Corporate & Business Services Asia), and SVC (Secured Venture Capital). Personal Information may be shared among these entities as necessary to provide the Better-than-Freehold® Services, ensure legal compliance, and for the purposes outlined in this Privacy Policy. Each entity is committed to upholding the privacy and security of your Personal Information in accordance with applicable laws and this Privacy Policy.

16. Contact Us

If you have any questions about this Privacy Policy, please contact us at:

Email: info@betterthanfreehold.com

Address: Unit 3a-2, Level 3a, Labuan Times Square, Jalan Merdeka, 87000, Federal Territory of Malaysia, Labuan