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PRIVACY POLICY

Last Updated on November 28, 2022

Rario is owned and operated by Digital Collectibles Pte. Ltd. ("Rario” “we” “us” “our” which
shall include its affiliates, employees, directors, group companies, parent, and subsidiary).
This privacy policy (“Privacy Policy”) applies to the site https://www.rario.com (“Site”) and
as well as to any other media forms, media channels, mobile websites, or mobile
applications related to the Site (“Services”). This Privacy Policy shall always be read with the
terms of use, which are available at https://www.rario.com/terms-of-use, (“Terms of Use”)
and governs the collection, processing, and usage of personal data ("Personal Data”) of the
user (“you” or “your”) in compliance with applicable data protection laws (including all
guidelines, regulations, notices, circulars of relevant governmental authorities) of Singapore
including but not limited to the Personal Data Protection Act 2012 (No. 26 of 2012)
(“PDPA”), all such laws collectively being the “Data Protection Laws”.
"Personal Data" means data, whether true or not, about an individual who can be identified
from that data, or from that data and other information to which an organisation has or is
likely to have access.
If the Personal Data, we collect includes sensitive information we will ask for your consent.
If collected, the sensitive information will be used by us only: (a) for the primary purpose for
which it was obtained; (b) for a secondary purpose that is directly related to the primary
purpose; and (c) with your consent; or where required or authorised by law.
Please read the entirety of this Privacy Policy carefully before using the Services. By using or
accessing any of the Services through any channel or method, and/or by accepting the
Terms of Use, you agree and consent to the use, collection, disclosure, and other processing
of your Personal Data by us under this Privacy Policy. IF YOU DO NOT CONSENT TO THE
PROCESSING OF YOUR PERSONAL DATA AS DESCRIBED IN THIS PRIVACY POLICY, PLEASE DO
NOT USE OUR SERVICES OR ACCESS OUR SITE.
This Privacy Policy applies in conjunction with any other notices, contractual clauses, and
consent clauses that apply in relation to the collection, use, and disclosure of your Personal
Data by us. Capitalised terms used in this Privacy Policy and not otherwise defined shall
have the meaning ascribed to such term under the Terms of Use.
The Services may contain links to or information about third-party websites that are not
within our control. We are not responsible for the privacy practices of any external website
or mobile application.
THIRD-PARTY SERVICE PROVIDERS
We may engage third-party service providers to assist with the provision of the Services.
Accordingly, your Personal Data may also be collected, used, and processed by our third-
party service providers. This Privacy Policy, therefore, applies to your Personal Data
collected directly by these service providers in connection with Services. However, this

Privacy Policy does not apply to Personal Data collected by third-party vendors for their own
purposes that are not shared with us. For example, if you submit Personal Data to create an
account to access a website operated by the service provider, your Personal Data will be
subject to the privacy policy of that particular service provider and not this Privacy Policy.
This Privacy Policy sets out the principles, Rario follows when collecting, using, disclosing,
retaining, and removing Personal Data, and describes other important topics relating to an
individual’s privacy.
INFORMATION COLLECTED FROM ALL VISITORS TO OUR SITE
We will obtain Personal Data about you when you visit us. When you visit us, we may
monitor the use of the Site through the use of cookies and similar tracking devices. For
example, we may monitor the number of times you visit the Site or which pages you go to.
This information helps us to build a profile of our users. Some of this data will be aggregated
or statistical, which means that we will not be able to identify you individually. This Privacy
Policy applies to all visitors to our Site.
ADDITIONAL PERSONAL DATA THAT MAY BE COLLECTED
Rario may collect and receive information from you when you register for an account with
us, when you use the features and functions of our Services, when you connect your
account to an external third-party service/application or when you contact us. The following
information may be collected and processed:
● name;
● gender;
● date of birth;
● address;
● e-mail address;
● phone number;
● transaction information (e.g. credit or debit card details, bank account information);
● username, password, and other identifiers or credentials used to access the
Services; and
● any other information required by us as determined in our sole discretion and any
information provided by you when you contact us or otherwise share with us before,
during, or after the termination of your account with us.
Please note that in using the Services we may also automatically collect the following
information about your computer hardware and software when you use our Site. The
information can include:
● your IP address;
● your locations;
● browser type;
● domain names;
● referring/exit pages;
● the files viewed on the Site (e.g., HTML pages, graphics, etc.);
● operating system;

● date/time stamp;
● clickstream data;
● access times;
● device information (hardware model and serial number);
● referring website addresses; and
● any communications between you and another user of our Services.
This information is used by Rario for the operation of the Services, to maintain the quality of
the Services, and to provide general statistics regarding the use of the Site.
USE OF COOKIES
Please note that we use “cookies” to help you personalize your online experience. A cookie
is a text file that is placed on your hard drive by a web page server. Cookies cannot be used
to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you,
and can only be read by a web server in the domain that issued the cookie to you.
Cookies on the Site may be used to ensure a smooth user experience, perform analytics, and
for showing relevant advertisements. Please note that third parties (such as analytics
software) may also use cookies, over which we have no control. These cookies are likely to
be analytical/performance cookies or targeting cookies.
Most web browsers automatically accept cookies, but you can usually modify your browser
setting to disable, block or deactivate cookies if you prefer. If you choose to decline cookies,
you may not be able to access all or parts of our Site or to fully experience the interactive
features of the Services or the Site.
THIRD-PARTY INFORMATION
In the event that you provide information relating to a third party to us, you represent and
warrant that you have validly obtained the consent, license, and permission of such third
party to share and transfer his/her Personal Data to us, and for us to collect, store, use and
disclose that data in accordance with this Privacy Policy.
USE OF PERSONAL DATA
Rario only collects, uses, and discloses Personal Data with an individual’s consent or deemed
consent or as otherwise permitted under the Data Protection Laws or other applicable laws
and regulations. Personal Data will, generally, only be collected and used for the following
primary purposes:
● to operate the Site and deliver the Services;
● to process, and where necessary, respond to your application, inquiry, or request;
● to gather customer feedback;
● to inform or update you of other services available from Rario, where you have
consented to be contacted for such purposes;
● to monitor, improve and administer the Site and Services, and to provide general
statistics regarding users of the Site;
● to update you on changes to the Site and/or Services;
● enabling transactions and sending transaction-related communications;

● identification and verification purposes in connection with any of the Services;
● to facilitate, confirm and/or provide updates or notifications in relation to any
transactions;
● to verify and process transactions (including payment, collecting, and managing the
proceeds of the Services) and to arrange for delivery of items;
● to contact you in cases of emergency;
● to outsource some operations including the provision of the Services and the
collection of service fees;
● to notify you of updates or changes to this Privacy Policy or the Terms of Use, or any
aspect of the Services (including to inform you of any additional terms and
conditions applicable to the Services);
● to protect and ensure the technical functionality, security, and integrity of the
Services including conducting data analysis, testing, monitoring and analyzing usage
and activities, and performing network or service enhancement;
● for accounting, risk management and record-keeping purposes;
● to comply with applicable legal obligations and other rules, regulations, codes of
practice, and orders and directions of the relevant governmental authorities;
● to prevent, detect, investigate or monitor any frauds, threats, misconduct, or other
prohibited content, businesses, or activities;
● to process or resolve any disputes arising from or in connection with the Services;
● to protect our rights and property and the rights, property, and safety of others;
● transmitting to any unaffiliated third parties including our third-party service
providers and agents, and relevant governmental and/or regulatory authorities,
whether in Singapore or abroad, for the aforementioned purposes; and
any other incidental business purposes related to or in connection with the above.
(collectively, the “Purposes”)
The Purposes listed may continue to apply even in situations where your relationship with
us has been terminated or altered in any way, for a reasonable period thereafter (including,
where applicable, a period to enable us to enforce our rights under any contract with you).
We may use and disclose automatically collected information (including aggregated
information), which is not Personal Data, for any purpose, except where we are restricted
by applicable law. If we combine any automatically-collected information with Personal
Data or other information which may be used to identify an individual, the combined
information will be treated by us as Personal Data in accordance with this Privacy Policy.
DISCLOSURE OF PERSONAL DATA
Rario will disclose or share your Personal Data, without notice, for the primary Purposes for
which it was collected (including use of or access to the Site/Services);
● for purposes that a reasonable person will consider appropriate in the
circumstances;
● where the individual has consented;
● where permitted under the Data Protection Laws; or

● only if required to do so by law or in the good faith belief that any such action is
necessary to:
▪ comply with any legal requirements or comply with legal process served on Rario
or the Site;
▪ protect and defend the rights or property of Rario; or
▪ act under exigent circumstances to protect the personal safety of users of the
Site, or the general public visiting the Site.

We may disclose your Personal Data with the following categories of third parties:
● Our business partners, service providers, professional advisers, vendors, and agents
who assist us in performing certain aspects of the Services (including processing
transactions, carrying out compliance checks, data storage, management and
analysis, maintenance of the Services, legal, audit, insurance and marketing
services). These parties will only have access to your Personal Data to the extent
necessary to perform their functions.
● Our potential investors, purchasers, and commercial counterparties. We may share
your Personal Data with any person who wishes to invest in Rario or whom we
intend to enter into a business combination with (such as a purchase, sale, lease,
merger or amalgamation, or any other acquisition, disposal, or financing).
● Any third-party claimants or potential third-party claimants.
● Financial institutions, your card issuing bank, or payment service provider in respect
of any issues arising from or in connection with a transaction through the Services.
● We may share your Personal Data with relevant governmental and regulatory
agencies in Singapore or other countries, including investigating officers and judicial
authorities in the relevant jurisdictions.
We may also share your Personal Data with other third parties if you have separately
consented to such disclosure. In such case, any information which we share with such third
parties shall be used for the purposes described when we obtained your consent.
We may disclose your Personal Data if required to do so by law or if we believe that such
action is necessary to prevent fraud or crime or to protect the Services or the rights,
property or personal safety of any person. We may be prevented from obtaining your
consent for, or informing you of, such disclosure. Any information which we share in this
circumstance shall be used for the purposes required or permitted under the applicable
laws or regulations.
STORAGE OF PERSONAL DATA
Personal Data collected by Rario may be stored and/or processed in Singapore or in any
other country where Rario or its service providers maintain facilities. Rario will also be
entitled to use service providers such as Amazon Web Services, Freshdesk (for customer risk
management), Clevertap (for customer journey management), Onfido (for KYC), and such
other service providers as we may deem fit or add by updating this Privacy Policy for
processing and/or storing your Personal Data. The storage location(s) are chosen in order to
operate efficiently, improve performance, and create a probability of errors in order to
protect Personal Data in the event of an outage or other problems. We take steps to ensure

that the Personal Data we collect is processed according to the provisions of this Privacy
Policy and the requirements of applicable law wherever the Personal Data is located.
TRANSFER OF PERSONAL DATA
Your Personal Data may be transferred to other countries for processing, and by using any
part of the Services, you consent to the transfer, use, and processing of your Personal Data
to countries outside of Singapore that may have different Personal Data protection rules
than in Singapore. However, the level of protection that will be applied to the transferred
Personal Data will be at least comparable to the protection provided under this Privacy
Policy and the applicable law.
RETENTION OF PERSONAL DATA
We may retain your Personal Data for as long as it is necessary to fulfil the purpose for
which it was collected, or as required or permitted by applicable laws. We will cease to
retain your Personal Data or remove the means by which the data can be associated with
you, as soon as it is reasonable to assume that such retention no longer serves the purpose
for which the Personal Data was collected, and is no longer necessary for legal or business
purposes.
NON-DISCLOSURE
Rario does not sell, rent, lease, or release your Personal Data to third parties unless your
consent has been given or if so permitted or required under the Data Protection Laws or
other applicable laws and regulations. Rario may, from time to time, contact you on behalf
of external business partners about a particular offering that may be of interest to you. In
those cases, your unique Personal Data is not transferred to the third party without your
explicit consent. In addition, Rario may share data with trusted partners to help us perform
statistical analysis, send you emails or provide customer support. All such third parties are
prohibited from using your Personal Data except to provide these identified services to
Rario, and they are required to maintain the confidentiality of your Personal Data.
There may be other situations where we may collect and use Personal Data, which is outside
a person’s reasonable expectation. When this occurs, Rario is committed to providing the
individual with an explanation for the possible use of the Personal Data when asking for the
individual’s consent.
ACCESS TO, CORRECTION OF, AND DELETION OF PERSONAL DATA
Subject to the exceptions referred to in section 21(2) of PDPA, if you wish to make an access
request for access to a copy of the Personal Data that we hold about you or information
about the ways in which we use or disclose your Personal Data, or a correction request to
correct or update any of your Personal Data that we hold about you, you may submit your
request via email to our Data Protection Officer at dpo@rario.com.
Please note that a reasonable fee may be charged for an access request. If so, we will inform
you of the fee before processing your request.
We want to ensure that your Personal Data is accurate and up to date. If any of the
information that you have provided to Rario changes, for example, if you change your email

address, name, or contact number, please let us know the correct details by sending an
email to dpo@rario.com. You may ask us, or we may ask you, to correct information you or
we think is inaccurate, and you may also ask us to remove information that is inaccurate.
We will respond to your request as soon as reasonably possible. In general, our response
will be within thirty (30) business days. If we are not able to respond to your request within
thirty (30) business days after receiving your request, we will inform you in writing of the
time by which we will be able to respond to your request. If we are unable to provide you
with any personal data or to make a correction requested by you, we shall generally inform
you of the reasons why we are unable to do so (except where we are not required to do so
under the PDPA or the applicable law).
You have the right to ask us not to collect, use, process, or disclose your Personal Data in
any manner described herein. We will usually inform you (before collecting your Personal
Data) if we intend to use your Personal Data for such purposes or if we intend to disclose
your Personal Data to any third party for such purposes. You can give us notice of your
intention to halt the collection, use, processing, or disclosure of your Personal Data at any
time by contacting us at dpo@rario.com.
You may request Rario to delete your Personal Data by contacting us at dpo@rario.com and
including "Please delete my Personal Data" in the subject line. Rario will verify your ability to
access that email, and then delete the Personal Data associated with your email address.
We will use reasonable efforts to respond to your request within thirty (30) days of our
receipt of the request.
We do not intentionally gather Personal Data from visitors who are under the age of
thirteen (13). If a child aged under thirteen (13) submits Personal Data to Rario and we learn
that the Personal Data is the information of a child under the age of thirteen (13), we will
attempt to delete the Personal Data as soon as possible. If you believe that we might have
any Personal Data from a child aged under thirteen (13) years, please contact us at
dpo@rario.com.
WITHDRAWAL OF CONSENT
You may withdraw your consent for the collection, use, or disclosure of Personal Data by
giving Rario reasonable notice by sending a written request (a) by email to the Data
Protection Officer at dpo@rario.com. Rario shall inform the individual of the likely
consequences of the withdrawal of the consent.
Upon receipt of the written request to withdraw the consent, we may require reasonable
time (depending on the complexity of the request and its impact on our relationship with
you) for your request to be processed and for us to notify you of the consequences of us
acceding to the same, including any legal consequences which may affect your rights and
liabilities to us. In general, we shall seek to process your request within ten (10) business
days of receiving it.

We will cease to collect, use or disclose the Personal Data upon such withdrawal unless
otherwise permitted or required by the PDPA or Data Protection Laws or other applicable
laws and regulations.
Please note that withdrawing consent does not affect our right to continue to collect, use
and disclose Personal Data where such collection, use, and disclosure without consent is
permitted or required under applicable laws (including Data Protection Laws).
SECURITY OF YOUR PERSONAL DATA
We strive to maintain the safety of your Personal Data. Once we have received your
information, we will use strict procedures and security features as per industry standards
and the Data Protection Laws to try to prevent unauthorised access.
While we strive to protect your Personal Data, we cannot completely guarantee the security
of any Personal Data we may have collected from or about you, or that no harmful code will
enter the Site (for example viruses, bugs, trojan horses, spyware, or adware). You should be
aware of the risks associated with disclosing any information or transacting over the
internet or when using online portals, and we urge you to take every precaution when using
the internet to disclose your Personal Data to us, including using strong passwords,
changing your password regularly and using a secure browser.
If applicable, you undertake to keep your username and password secure and confidential
and shall not disclose or permit it to be disclosed to any unauthorised person, and to inform
us as soon as reasonably practicable if you know or suspect that someone else knows your
username and password or believe the confidentiality of your username and password has
been lost, stolen or compromised in any way or that actual or possible unauthorised
transactions have taken place. We are not liable for any loss or damage resulting from your
act or omission to safe-keep your username and password from unauthorised use.
Please also refer to the Terms of Use in this regard.
CHANGES TO THIS POLICY
We reserve the right to update, modify, delete or otherwise make changes to this Privacy
Policy at any time. Any changes to this Privacy Policy will be posted to the Site. A notification
may also be sent to your email address.
Any changes to this Privacy Policy will take effect and be binding on you from the time of
posting the changes to the Site. If you continue to use any Services following any changes to
this Privacy Policy, you will be deemed to have accepted the changes and the updated
version of this Privacy Policy.
If you do not agree with the changes, you are not allowed to use any part of the Services.
Please ensure that you refer to this Privacy Policy on a regular basis to check for any
changes. It is your responsibility to regularly review this Privacy Policy (and the applicable
conditions).

If any provision of this Privacy Policy shall be held to be invalid, illegal, or unenforceable for
any reason whatsoever, the validity, illegality, and enforceability of the remaining provision
of this Privacy Policy shall not in any way be affected or impaired thereby.
DATA PROTECTION OFFICER
You may contact our Data Protection Officer if you have any enquiries or feedback on our
personal data protection policies and procedures, or if you wish to make any request, in the
following manner:
DPO: Mr. Sameer Deval
Email Address: dpo@rario.com
CONTACT INFORMATION
Rario welcomes your comments regarding this Privacy Policy. If you believe that the Site has
not adhered to this Privacy Policy, please contact us at dpo@rario.com.
GOVERNING LAW
This Privacy Policy and your use of this website shall be governed in all respects by the laws
of Singapore.

Our Address:
DIGITAL COLLECTIBLES PTE. LTD.
68 CIRCULAR ROAD, #02-01
SINGAPORE 049422

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