Introduction

This Privacy Policy ("Policy") is an integral part of the Terms of Use (the "ToU") for the iorUp website and mobile application (collectively, the "Platform"). This Policy shall be read together with the Terms, and any capitalized terms used herein but not defined shall have the same meaning ascribed to them in the Terms.

This Policy explains how iorUp, our Platform, collects, uses, discloses, and protects your information. By using the Platform, you agree to the practices described in this Policy.

We encourage you to read this Policy carefully to understand how we handle your information and your rights regarding it. If you have any questions or concerns, please contact us using the information provided below.

1. Information Collected

1.1 When you register for an account and use the Platform, we collect and use the information you provide. This information may include but not limited to:

• a. Personal Information: Examples include your name, email address, phone number, and any other information you choose to share when creating your profile or using the Platform, such as details for job applications (e.g., resume/CV, work history, education, skills, desired roles) or property listings (e.g., property type, size, rental price, detailed location, availability dates).
• b. Device Information: We automatically collect certain information about your device, such as the model, operating system version, unique identifiers, IP address, and mobile network information.
• c. Usage Data: We may collect information about how you interact with the Platform, such as the pages you visit, features you use, content you access (including news articles), actions you take (e.g., saving listings, applying for jobs, sending messages, uploading news), and your browsing behavior and preferences.
• d. Cookies and Similar Technologies: We may use cookies, web beacons, and other tracking technologies to collect information about your browsing behavior and preferences. This information helps us store your preferences, analyze trends, personalize your experience with the Platform, and deliver relevant content and advertisements.
• e. User-Generated Content: This includes content you create and upload to the Platform, such as property descriptions, job advertisements, news articles, photos, and videos. This information is essential for the functionality of our services, including our fact-checking process for news content.

2. How We Collect Information

2.1 Information Collection Methods

We collect your information in two ways to help improve the performance of the system and to provide you better service:

• a. Directly from you: You provide certain information when you register for an account, use the Platform's services, participate in activities or events, or communicate with us (by phone, email, etc.).
• b. Automatically: The Platform automatically collects certain information about your device and usage, such as IP address, location (with your consent for precise location), device identifiers, browser information, and usage data (pages visited, features used, etc.). This information helps us improve the App's performance and provide better service.

2.2 Personal Information Collection

We collect your personal information when you:

• a. Register as a User: This includes creating your profile for purposes such as establishing a tenant, landlord, job seeker, recruiter, or news publisher account.
• b. Log in to your account: Accessing our Platform services.
• c. Use our services on the Platform: This encompasses, but is not limited to, posting real estate listings, applying for jobs, creating job advertisements, uploading news content, sending direct messages, and engaging with our fact-checking services.
• d. Engage with us: This includes participating in Platform activities or events, or communicating with us for support, inquiries, or feedback.

2.3 Transaction Information

When you make payments or conduct transactions through the Platform related to our services (e.g., premium advertising, enhanced listings, subscription fees), we collect and store your transaction-related information. This may include payment method details, transaction amounts, and the date and time of the transaction. We may also collect your current location (with your consent) at the time of the transaction for security and service delivery purposes.

2.4 Camera and Microphone Access (Optional)

We may request access to your camera and microphone with your prior permission. These permissions can be used for:

• a. QR code scanning for transactions
• b. User profile verification (if applicable)

3. Use of information/Data

3.1 We may use your information/data for the following purposes;

• a. Account Management: (i) Verify your identity and (ii) Create and manage your User profile;
• b. Communication: Send you announcements, updates, or offers through the Platform, SMS, Phone call or email;
• c. Customer Support: Respond to your inquiries and fulfill your requests;
• d. Platform Improvement: (i) Analyse your usage to operate and improve the Platform and our services; and (ii) facilitate marketing efforts;
• e. Personalised Content: Personalise content on the Platform, websites and social media platforms based on your preferences;
• f. Business Operations: Operate, evaluate, and improve our business, products and services;
• g. Marketing: Promote and market products and services we believe may interest you;
• h. Legal Compliance: Comply with the laws of Myanmar and Japan, and enforce legal rights;
• i. Security and Risk Management: Manage risks, detect, investigate and prevent misuse of accounts, money laundering, and fraudulent, illegal, or harmful actions.

3.2 Disclosure of Information

We may disclose your information in the following limited circumstances:

• a. Legal Requirements: To law enforcement, government authorities, or as required by law or regulation.
• b. Professional Services: To our legal and professional advisors for legal matters.
• c. Safety and Security: When we believe disclosure is necessary to protect the safety or security of individuals or to investigate suspected illegal activity.
• d. Service Providers: To trusted service providers, agents, business partners, and subcontractors who work on our behalf, subject to strict confidentiality agreements and solely for internal administrative and operational purposes.

4. Security Measures and User Control

We take the security of your information seriously and employ a variety of physical, electronic, and other security measures to protect its confidentiality, integrity, and security. However, no internet or electronic storage method is completely foolproof. While we strive to use commercially reasonable methods to protect your information, we cannot guarantee its absolute security. We are not responsible for unauthorized access, unlawful interceptions, or loss of information that occurs despite our security measures.

We will not use your email address or other information to send you unsolicited messages or share it with any third party for such purposes. We may only share your information as described in this Policy, such as with trusted service providers who work on our behalf.

5. Data Retention and Account Termination

5.1 We will remove your User profile from our system upon termination of your account. However, we may retain your personal information and transaction data for the following purposes, unless otherwise prohibited by law as described in this Policy.

5.2 We will retain your transaction data for at least five years, or for any longer period required by law.

5.3 We may retain your personal information for as long as your account is active and for a five (5) years thereafter as needed to fulfill the purposes described in this Policy or comply with legal requirements.

6. Children's Privacy

6.1 iorUp is intended for a general audience and is not directed towards children. We do not knowingly collect personal information from children under the age of 18.

6.2 If you are a parent or guardian and believe your child under 18 has provided us with personal information without your consent, please contact us immediately so we can take appropriate action. This may include deleting the child's information from our servers.

6.3 We encourage parents and guardians to:

• a. Monitor their children’s online activities;
• b. Use parental controls to prevent children from disclosing personal information online;
• c. Discuss responsible online behaviour with their children.

6.4 In some jurisdictions, the age of majority may be higher than 18. We recommend that minors over 18 but under the age of majority in their jurisdiction seek parental consent before using our application or providing any personal information.

7. Cookies and Tracking Technologies

7.1 iorUp and our affiliates may use cookies, web beacons, and other tracking technologies to collect information about your interactions with our application and website. This information helps us:

• a. Analyse trends;
• b. Administer the Platform;
• c. Track User behaviour within the Platform;
• d. Gather Demographic information about our User base.

7.2 Cookies are small data files stored on your device by websites or applications you visit. They can be used to:

• a. Remember your preferences;
• b. Enhance your User experience;
• c. Deliver personalised content and advertisements.

7.3 You can control cookies through your browser settings. Disabling cookies may limit some functionalities of our application.

7.4 We may use third-party services like Google Analytics to collect and analyze information about your app usage. These services may use cookies and similar technologies to gather information across websites and online services.

7.5 By using our application, you consent to the use of cookies and tracking technologies as described in this policy.

7.6 If you don't want to accept cookies, you can adjust your browser settings to either reject cookies or notify you when a cookie is placed on your device. Be aware that some app features may not function properly if cookies are disabled.

8. Modifications of Policy

8.1 We may update this Policy from time to time to reflect changes in our practices or comply with legal requirements. We will notify you of any material changes to this Policy by posting a notice on the application's home page and/or sending you an email notification (if you have provided your email address).

9. Contact Details

9.1 If you have any questions, concerns, or requests regarding your personal data, you can contact us using the following methods:

• a. Email: contact@iorup.com