Privacy Agreement

Between:

Octo for Trade and Distribution SAE, Commercial Registration No: 170061

Located at Unit 016, Greek Building, Greek Campus, Tahrir Square, Cairo.

(referred to as "the First Party" or "the Company")

Mr/Mrs. “Application User” (referred to as "the Second Party" or "the Client")

(referred to collectively as "the Parties" or individually as "the Party")

Introduction:

• The First Party is a company specialized in general trade and distribution. It provides technological and electronic payment services and financing operations for goods and services through a dedicated mobile application developed by the Company.

• The Client wishes to benefit from the electronic payment and installment services provided by the Company and receive an early portion of their salary through the Company's electronic application.

• Providing these services requires the Company to obtain information and data from the Client for the purpose of completing payment and/or financing operations and/or services on behalf of the Client.

• Based on the above, and after both Parties have acknowledged their full eligibility to contract and assume obligations, they have agreed as follows: The above introduction is an integral and complementary part of this agreement and complements all its terms.

Article 1: Definitions

The following terms shall have the meanings ascribed to them in this agreement unless the context requires otherwise:

• Confidential Client Data: The personal data and information provided by the Client to the Company for the purpose of providing the service between the Parties. This includes, but is not limited to, the name, phone number, address, occupation, monthly income, regardless of whether it is physical or electronic media, and all information disclosed by the Client or its representatives to the Company or its representatives. It does not include Client data that was publicly available or became available for reasons unrelated to any breach by either Party of its obligations or due to disclosure by a third party not bound by confidentiality obligations or by written agreement between the Parties to waive its confidentiality.

• Data Processing: Any electronic or technological process of writing, collecting, recording, storing, merging, displaying, transmitting, receiving, circulating, publishing, erasing, altering, modifying, retrieving, or analyzing personal data using any media, electronic devices, or technology, whether partially or completely.

• Electronic Application: The application developed, designed, and owned by the Company for the purpose of facilitating consumer financing operations for goods and services in accordance with the law.

Article 2: Data Processing, Confidentiality, and Data Security

2.1 The Company, its representatives, or employees undertake to collect, store, and process confidential client data for the purpose of providing the service following recognized technical and secure practices in the field of information technology.

2.2 The Company undertakes not to collect confidential client data for processing except through disclosure or disclosure by the client or its representatives.

2.3 The Company undertakes to ensure that its employees, officials, representatives, advisors, and affiliates who have access to this confidential client data are aware of its confidential nature and the Company's obligation to maintain its security and confidentiality.

2.4 Without prejudice to cases where the law requires the disclosure of confidential client data, the Company's employees, officials, representatives, advisors, and affiliates who have access to the confidential client data are prohibited from disclosing this data to third parties without written consent from the client.

2.5 The Company may process confidential client data for third parties, with or without consideration, without the explicit consent of the client or as permitted by law.

2.6 The client acknowledges the Company's right to use confidential client data for market research, econometrics, macroeconomics, quantitative economics, and the development of electronic application services and financing products provided through it.

2.7 The client agrees to the processing of confidential client data for the purpose of the service provided by the Company and/or its representatives.

2.8 The Company undertakes to erase confidential client data immediately upon the client's withdrawal of their previous consent for data processing by the Company. However, the Company may retain this data after the specified purpose of the service expires, in accordance with the law, while ensuring the confidentiality and non-disclosure to third parties after the termination of the contract or consumer financing agreement.

2.9 The obligations stated in this article (2) do not apply to confidential client data if it becomes public knowledge in any manner other than the fault of the Company or its employees and/or officials and/or representatives and/or advisors and/or affiliates who have been disclosed to confidential client data, as well as information that was already known to the Company before the disclosure by the client, and information disclosed by a third party not bound by data confidentiality obligations.

2.10 The Company undertakes, when processing confidential client data, to take necessary technical and organizational measures to maintain the privacy, confidentiality, integrity, completeness, and consistency of personal data, in order to reduce the risks of processing that may result in a breach of personal client data.

2.11 The Company undertakes to keep documents, records, or any other medium provided by the client, but the Company shall not be liable for the risks that may affect the confidentiality of client data if it is due to an external cause beyond the control of the Company and without negligence on its part.

2.12 The client agrees, confirms, and acknowledges the accuracy and correctness of the confidential client data provided to the Company and that the Company is not responsible for any errors, fraud, or manipulation in such data.

Article 3: Data Breach

3.1 The Company undertakes not to handle or access confidential client data in an unauthorized manner, or engage in any unauthorized action to copy, send, distribute, exchange, transfer, or manipulate personal data with the intention of disclosing, destroying, or modifying it during storage, transmission, or processing.

3.2 In the event of a violation, breach, or hacking of the client's account on the electronic application, the client shall immediately notify the Company with an accurate description of the nature of the breach or violation, its documentation, and the possible reasons for the incident of violation, breach, or hacking.

3.3 The client acknowledges that the Company is not responsible for any disclosure of confidential client data, whether intentional or unintentional, as long as the disclosed information provided to the Company is incorrect, misleading, inaccurate, or manipulated.

3.4 The Company undertakes to notify the client immediately in the event of a violation, breach, or hacking of the confidential client data being processed by the Company.

Article 4: Notifications and Correspondence

4.1 The parties have designated the addresses stated at the beginning of this contract as their chosen places for all notifications, correspondence, and documents between them, provided that notifications, correspondence, or documents sent via email shall be followed by sending the original copy by registered mail with acknowledgment of receipt or by hand delivery against a receipt stamped with the recipient's seal or signature.

4.2 In the event of a change in the chosen place of either party, the party making the change undertakes to notify the other party of this change within 24 hours from the date of the change, using the same means specified in the same clause. All notifications, correspondence, and documents sent to the addresses mentioned in this contract shall remain legally effective unless the change is notified.

Article 5: Assignment and Transfer of Rights

5.1 The company is entitled to assign all or part of the data processing tasks stipulated in this contract to a third party without the client's consent, provided that the assigned third party is bound by the provisions of this contract and the law.

5.2 The client is not entitled to assign or transfer their rights or delegate their obligations under this contract to a third party without obtaining prior express written consent from the company. In the event of a violation of this provision, such assignment or transfer shall not be effective against the company.

Article 6: Termination of the Contract

This contract shall terminate in the following cases:

• Termination of the service provided by the company.

• Death of the client.

• Dissolution, liquidation, suspension, bankruptcy, or expiration of the company.

Article 7: General Provisions

7.1 The client undertakes to notify the company immediately upon becoming aware of any error in the confidential client data.

7.2 The client undertakes to notify the company by registered letter with acknowledgment of receipt in the event of correction, amendment, addition, or update to any of the confidential client data.

7.3 The company's failure, delay, or silence in exercising the rights or authorities granted to it under this contract shall not be deemed as a waiver of such rights or authorities. Likewise, the company's use of a portion of the rights or authorities shall not be considered as a waiver of the remaining rights or authorities.

7.4 If any provision or term of the contract is found to be illegal, invalid, or unenforceable, it shall not affect the validity and enforceability of the remaining provisions of the contract. The parties shall consult in good faith to rectify and enforce those illegal, invalid, or unenforceable provisions and terms, taking into account the mutual good faith of the parties. Furthermore, the parties shall endeavor to replace any void or unenforceable obligation with a valid and enforceable obligation that reflects to the maximum extent possible the original intent of the parties.

7.5 Without prejudice to Article 6 above, the obligation to maintain the confidentiality of confidential client data continues even after the expiration of this contract and the consumer finance contract.

Article 8: Applicable Law and Dispute Resolution

8.1 This contract, in its conclusion, implementation, and interpretation, is subject to the provisions of the laws of the Arab Republic of Egypt, particularly Law No. 151 of the year 2020, the Personal Data Protection Law, and its executive regulations.

8.2 Any dispute arising out of the conclusion, implementation, or interpretation of this contract shall be settled through the courts of the Arab Republic of Egypt, regardless of their jurisdiction, in accordance with the applicable rules of Egyptian law.