Privacy Policy

PLEASE READ THIS PRIVACY POLICY CAREFULLY. Your privacy is very important to us. Jomee Jomaa Ltd (together with its subsidiaries and other affiliated entities, ("Jomee Jomaa") is committed to maintaining your privacy. This privacy policy (the "Privacy Policy") is intended to inform you of:

• The types of information we collect
• How we use information we collect
• How we share information we collect
• How we safeguard information we collect
• Other important privacy information

This Privacy Policy applies to you whenever you access or use any domains or subdomains of our website at http://www.jomeejomaa.com and our mobile application (the "Platform""), or when you access, use or download any products, services, features, content, widgets, materials or other tools offered by Jomee Jomaa (collectively, "Services"). This Privacy Policy does not govern information you choose to exchange directly with other users of the Platform, including communications or transactions with other individual users, as we have no direct control over the collection or use of this information. Please use appropriate precautions in sharing your information with these users.

Please note that your relationship with Jomee Jomaa is also governed by our Platform Terms & Conditions and the transaction documents that you may enter into in connection with making an investment through our Platform. Jomee Jomaa also has relationships with third parties for purposes of cookies served on our Platform, as detailed below. You are encouraged to carefully review these sections as well.

Types of Information We Collect

To provide our Services, and facilitate exchanges between users of the Platform, we obtain personal information directly from you and obtain information about you indirectly through electronic communications and third parties (collectively, "Personal Data").

User Supplied Membership Information

Depending on the Services you seek to access we may require that you provide some or all of the following types of Personal Data :

• Name
• Address
• Email
• Phone Number
• Entity Information
• NID (or equivalent)
• Financial Information
• Joint Owner Information
• Date of Birth
• Accreditation Status
• Employment
• Citizenship
• Payment Information
• Investment Experience
• Investment Suitability Information

Our membership registration process, surveys and questionnaires may request that you provide other information that you may, at your option, choose to provide or withhold. Any such information provided will be subject to this Privacy Policy.

Verification Information

If required to help us verify your identity, you may provide us a copy of your driver's license, passport or other government issued ID. If required to help us verify your residence, you may provide us with a utility bill, lease or other proof of residence. You may also provide us other verification documents, such as bank statements reflecting the source of funds, to meet anti-money laundering laws, Bangladesh Bank rules or regulations or other legal requirements. If you seek to invest through an entity or corporation, you may provide us with documentation relating to the entity's jurisdiction of formation, legal status and ownership. By providing the verification information and documents mentioned above, you also provide us information within those records, which may include characteristics of protected classifications like your sex, age, national origin, and citizenship.

Banking Information

In order to make an investment in land properties offered through our Platform, you must provide us and our third-party financial providers or partners with certain account and other payment information, such as information needed to make payment via credit card, MFS, bank transfer, or any other payment method accepted by us at such time. Our membership registration and buy flow process provides additional details on the types of payment information needed. For members who link or verify bank accounts over our Platform and/or one of these third-parties, you may further agree to your personal and financial information being transferred, stored, and processed by this third-party in accordance with their respective privacy policies.

Automatically or Passively Collected Information

In addition to information you directly provide, we automatically or passively collect information when you access or use our services, such as, but not limited to, your IP address, device identifiers, click path, use of our Platform and other electronic data. We may also record page views (hit counts) and other general statistical and tracking information, which will be aggregated with that of other users in order to understand how our Platform is being used, and for security and monitoring purposes. In order to determine whether your computer is supported by our system, we may collect additional technical information about your operating system and browser, as well as the presence of any software that our Platform may require to operate with your computer, or other third party software on your computer.

Cookies

Additionally, we may collect, store and use "cookies". A "cookie" is a small amount of data, often including an anonymous unique identifier, which is sent to your browser from a website's computers and stored on your computer's hard drive. Cookies can be used to provide you with a tailored user experience to make it easier for you to use a website upon a future visit, as well as to help you navigate between pages efficiently. We may include cookies on our Platform and use them to recognize you when you return to our Platform. You may set your browser so that it does not accept cookies. However, cookies must be enabled on your web browser if you wish to access certain personalized features of our Services. We encourage you to carefully review this section in order to learn more, and explore your opt-out options for certain cookies that are not necessary to become a member on our Platform.

Types of cookies being used on our site:

1. Session Cookies: These cookies are automatically erased whenever you exit the Platform. We use these cookies to grant users access to places on our Platform, and enable actions they must be logged on to do.
2. Persistent Cookies: Persistent cookies usually have an expiration date in the future, and remain in your browser until they expire, or you manually disable them. Persistent cookies are used in order to track member usage patterns of our Platform, and understand what you do on our Platform.
3. Third Party Cookies: We use third party cookies for most of our user tracking. We may use cookies to determine people logging in or if they signed up to web push notifications.

TYPE OF COOKIES	WHO SERVES THE COOKIES
Strictly Necessary Cookies	Jomee Jomaa
Performance and Functionality Cookies	Jomee Jomaa
Analytical Cookies	Jomee Jomaa, Mixpanel, Fullstory, etc.
Advertising Cookies	Adroll, Barometric, Bidswitch, Bing, Dianomi, Google Marketing Suite, Jeeng, Katz, Linkedin, Mountain, Outbrain, PandoraPippio, Quora, Taboola, Tapjoy, Twitter, Wisepops, Yahoo, etc.
Social Media Cookies	Facebook (Meta), Linkedin, Pinterest, TikTok, Twitter, etc.

How Do I Control Cookies

There are multiple ways to control how cookies are used on your Jomee Jomaa platform and your devices.

1. Cookies within the Jomee Jomaa Platform. By using the Jomee Jomaa Platform, you consent to the use of types of cookies detailed herein.
2. Advertising ID. You can customize your device settings to control advertising ID:
3. On Apple devices: enable "Limit Ad Tracking" in your device settings.
4. On Android devices: enable "Opt out of Ads Personalization" in device settings.
5. Third Party Cookies Opt-Outs. Many of the third-party and social media cookies as listed above also prove opt-outs on their own websites. You can find details on their own policies, as listed above in our cookies used.

Please note that removing or rejecting all cookies could affect the functionality of the Platform and its services.

Pixels

We may also use so-called "pixel tags" – small graphic images (also known as "web beacons" or "single-pixel GIFS") – to tell us what parts of our website have been visited, inform us of the reach and efficacy of our advertisements, or to measure the effectiveness of searches customers perform on our Site. Pixel tags also enable us to send email messages in a format customers can read, and they inform us whether emails have been opened, to help ensure that our messages are of interest to our users. Some web browsers transmit "do-not-track" signals to websites. At this time, our Services are not designed to respond to these signals or similar mechanisms from browsers. We may send email messages that use a "click-through URL" linked to content on our Platform. When you click one of these URLs, you pass through our web server before arriving at the destination web page. We track this click-through data to help determine interest in particular topics and measure the effectiveness of our communications. If you prefer not to be tracked, simply do not click text or graphic links in the email, or notify us here.

Usage Information

We collect certain information about you when you visit the Platform and interact with any of our Services. We collect information about when you use Services, the pages within the Platform you visit, the links you click on, the type, size and names of files you upload or download, and the search terms you use. If you invite others to use the Platform, we retain information about your referral.

We collect information in connection with the transactions you become a party to through our Services, including your participation in primary offerings via the Platform and secondary purchase and sale transactions through the secondary market bulletin board. Transaction data includes, without limitation, the terms on which you purchase or sell securities and information relating to price, size, volume, class of securities, offers, acceptances, transfer restrictions, and any derivative data related thereto.

Third-Party Information

We collect information about you from third-party sources with which we maintain various commercial relationships. We utilize a third-party identity verification service provider to help us confirm your identity, prevent fraud, money-laundering and other illegal activity, and to satisfy legal requirements relating to the Services. We also receive information about you and your activities from third-party service providers, such as Google, LinkedIn, Meta, and other advertising, social media and market research partners who provide us with information about you, and/or your engagement with and interest in our Services. We may also receive information about you from our third-party marketing partners, under referral programs, IRA service providers, partnership agreements and/or under joint marketing arrangements.

How We Use Information We Collect

We may use your information for the following commercial purposes:

• To administer, operate, facilitate and manage your relationship with Jomee Jomaa and deliver the Services.
• To facilitate our business operations, including fulfilling our legal and regulatory requirements such as identity verification, validation, anti-money laundering and "Know Your Customer" protocols.
• To determine your eligibility to invest.
• To enable you to subscribe for securities, make and receive payments and execute transactions.
• To satisfy our record keeping and transfer agency obligations under applicable laws, rules and regulations.
• To communicate with you about the Services and target our marketing, advertising and sales efforts to enhance your user experience and increase engagement. These communications may alert you to new Services, offerings, features, content and promotional events.
• To provide you with information about our current Services, including onboarding materials, the availability and terms of new investment opportunities, reminders, information about your previous investments.
• To verify your identity, accounts and activity, to monitor suspicious or fraudulent activity, and to identify violations of Service policies. We also use your information to debug, identify and correct errors;
• On a de-identified, aggregated basis, for research and development activities, including to analyze how you use the Services to help us understand usage patterns and know if there are problems with the Services or areas ripe for improvement;
• To contact you or, if applicable, your designated representative(s) by post, telephone, text message, electronic mail, facsimile, etc., in connection with your relationship with Jomee Jomaa, including with information and updates about our Services.

In addition, if we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, creation of a trust or other affiliated entity, receivership or sale of Jomee Jomaa’s assets, or other corporate transaction affecting Jomee Jomaa, your information may be shared, transferred or sold under a duty of confidentiality as part of a transaction as permitted by law or by contract.

By using the Services, you consent to receiving calls and messages, including auto-dialed and pre-recorded message calls, and SMS messages (including text messages) from us, at any telephone numbers that you have provided or may provide in the future (including any cellular telephone numbers). Your cellular or mobile telephone provider will charge you according to the type of plan you carry. You can "opt-out" of receiving these types of communications from us by following the directions provided elsewhere in this policy.

If your relationship with Jomee Jomaa ends, we will continue to treat your Personal Data, to the extent we retain it, as described in this policy.

How We Share Information We Collect

We do not buy, sell or share personal identifying information from, to or with third parties for their direct marketing or similar purposes without your consent. We also do not offer financial incentives, preferential service agreements, or any other differences in our prices or Services in exchange for your information.

The manner in which partners, service providers and others with whom we share and/or disclose your information is governed by the policies of such parties, and we shall have no liability or responsibility for the privacy practices or other actions of any such parties. Generally, you can easily recognize when one of our partners is associated with a service. However, certain parties may provide services anonymously, and, in this case, we will only share information that is directly related to the applicable service(s). This may include the incorporation of your Personal Data into databases maintained to validate information for identity verification, including verification for anti-money laundering and "Know Your Customer" protocols.

The primary situations in which we share your data are as follows:

1. Partnering Arrangements: We employ other companies to perform functions on our behalf, such as a broker dealer that underwrites and solicits investment in our offerings, service providers that assist in the administration of our Platform and our advertising and marketing efforts, identity verification services, data analytics companies that help us target our offerings, marketing partners, payment gateway such as SSL Commerz, PortPos, Ekpay, MFS services such as Bkash, Nagad, and PSP such as Pathao Pay, Sheba Pay, etc. We may need to share your information with these companies. These users may access this information so long as you are a member of the Platform.

2. Potential Business Combination: We may also transfer your Personal Data to a third party as a result of a business combination, merger, asset sale, reorganization or similar transaction or to governmental authorities when we reasonably believe it is required by law or appropriate to respond to legal process. We will also share your information with third-party companies, organizations or individuals if we have a good faith belief that access, use, preservation or disclosure of your information is reasonably necessary to detect or protect against fraud or security issues, enforce our terms of use, meet any enforceable government request, defend against legal claims or protect against harming our legal rights or safety. In any such event, and to the extent legally permitted, we will notify you and, if there are material changes in relation to the processing of your Personal Data, give you an opportunity to consent to such changes. Any third party with whom we share your data with will be required to provide the same or equal protection of such data as stated in our Privacy Policy.

3. Service Providers: To operate the Services we share information about you as needed with our service providers, including financial institutions, broker-dealer(s), accountants, auditors, lawyers, payment processors, information technology consultants, advisors and our affiliates. We only share information to the extent it is required to fulfill our obligations to you and to regulators, and to operate the Platform and the Services. The information is only shared so long as you are a member or user of the Platform.

4. Affiliates: We do routinely share information with companies closely related to us – our "Affiliates" – for certain purposes under this policy. By "Affiliate," we mean an entity that controls, is controlled by, or is under common control with Jomee Jomaa, whether the control results from equity ownership, contract, overlapping management or otherwise. In this context, "control" means the ability to replace the officers or directors or otherwise materially influence or control management decisions. Our Affiliates will be entitled to enjoy our rights under this Privacy Policy and we will be responsible for our Affiliate's conduct related thereto.

5. Regulators: We may share information about you with Bangladeshi local or international regulators, Bangladesh Bank, NBR, BSEC, or ACC where we believe doing so is required or appropriate to comply with any laws, regulations or other legal processes or law enforcement requests, such as court orders, search warrants, or subpoenas, including the requirements under the Digital Security Act, 2018.

6. Third-Party Sites: The Platform may contain links to third party websites and may redirect you to third party websites. These sites include, among others, service providers who have a relationship with Jomee Jomaa. Third party websites are not under our control, and we are not responsible for any third party websites, or the accuracy, sufficiency, correctness, reliability, veracity, completeness, or timeliness of their information, links, changes or updates. The inclusion or access to these websites does not imply an endorsement by Jomee Jomaa, or of the provider of such content or services, or of any third party website. Please be aware that when you enter a third party website, any information you provide, including financial information, is subject to the terms of use and privacy policy of that website.

How We Safeguard Your Personal Data

Security Systems and Processes: Jomee Jomaa developed a detailed written Information Security Policy that covers all personnel, and regularly conducts company-wide training on protecting the personal information of users and investors, as well as the disposal of non-essential user information. We have put in place security systems designed to prevent unauthorized access to or disclosure of Personal Data, and we take all reasonable steps to secure and safeguard this Information, including:

• Our Platform's password-protected section requires users to give us unique identifiers such as their user ID and password and authenticate themselves prior to accessing the Services;
• We use industry standard encryption technology for any information we store;
• Jomee Jomaa employees are required to acknowledge that they understand and will abide by this Privacy Policy with respect to the confidentiality of Personal Data;
• Where applicable, companies and vendors that we do business with agree to abide by this Privacy Policy and apply similar contractual safeguards to Personal Data;
• We provide access to our databases containing Personal Data on a need-to-know basis only; and
• We use automated tools to monitor network traffic to detect, identify and track unauthorized attempts to upload information, change information, or otherwise seek to "hack into" our systems.

Our security systems are therefore structured to deter and prevent hackers and others from accessing information you provide to us. However, please understand that this information should not be construed as a warranty that our security systems are fail proof. Due to the nature of internet communications and evolving technologies, we disclaim and cannot provide assurance that the information you provide us will remain free from loss, misuse, or alteration by third parties who, despite our efforts, obtain unauthorized access.

Credit Card Security: Jomee Jomaa does not take or retain credit card information directly. Any credit card information submitted will be done through our third party financial providers and will be governed by their terms and conditions.

Other Important Privacy Information

Opting Out of Communications:

If you wish to stop receiving marketing or promotional communications or to opt out of use of your information for the purposes described in this Privacy Policy, please follow the opt-out instructions, such as clicking "Unsubscribe" (or similar opt-out language), in those communications. You can also contact us here to opt out. Despite your indicated email preferences, we may send you service-related communications, including notices of any updates to our terms of service or this policy. Please understand that you will not be allowed to opt–out of certain communications required to comply with applicable laws, rules and regulations or other legal and related notices concerning your relationship to the Platform.

Changing or Deleting Information:

All users may review, update, correct or delete the user's Personal Data that Jomee Jomaa has on file by contacting us here or, in certain cases, by accessing your member account. If you request, we will take reasonable steps to remove your name and other Personal Data from our databases. Please understand, however, that:

• it may be impossible to remove this information completely, due to Bangladesh Bank, NBR, and regulatory reporting requirements, investments on the platform and the rights thereof, and data backups and records of deletions;
• if you request deletion of your information, you will be unable to use certain features of the Platform and any associated Services; and
• certain Personal Data may remain in our databases following the deletion of your account pursuant to our data retention policy.

Incident Response:

In the event of a purported data breach or inclusion, we will investigate and endeavor to notify any affected individual in writing (including by email) within seventy-two (72) hours of detection of any Personal Data. This notice will provide, at a minimum, a description of the event, the type(s) of information that was affected, Jomee Jomaa’s mitigation response, and information for any individual on how to further protect their Personal Data.

Data Retention:

We retain information we collect for as long as you use the Services (including your ownership of land properties in Jomaa Jomaa Platform) or as necessary to fulfill the purposes for which it was collected, provide our Services, resolve disputes, establish legal defenses, enforce our agreements and comply with applicable laws. We may retain information that is otherwise deleted in anonymized and aggregated form, in archived or backup copies as required pursuant to records retention obligations or otherwise as required by law. We may retain an archived copy of your records as required by law or for legitimate business purposes.

Lost or Stolen Information:

You must promptly notify us if you become aware that any information provided by or submitted to the Platform is lost, stolen or used without permission.

Right to Opt Out of Sharing:

You have the right to request to opt out from your Personal Data being shared with unaffiliated third parties by contacting us here Please note that you may not be able to opt-out if the Personal Data is shared: (i) pursuant to a joint marketing arrangement with third party service providers; (ii) in connection with maintaining and servicing customer accounts and effecting certain transactions; or (iii) in situations related to protecting against fraud, complying with certain legal and regulatory requirements and required consumer reporting.

Children and Teens:

WE DO NOT ALLOW INDIVIDUALS WHO WE KNOW ARE UNDER 18 YEARS OLD TO PARTICIPATE IN OUR PLATFORM OR SERVICES. YOU MUST BE AT LEAST 18 YEARS OLD TO USE OUR PLATFORM AND SERVICES. Please understand that we cannot necessarily tell if a user is providing us with his or her true age. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us here We will delete such information from our files within a reasonable amount of time.

Changes to this Privacy Policy:

Each time you visit our Platform or use our Services, the current version of this privacy policy will apply. When you use our Platform, you should check the date of the last update to the policy (which appears at the top of the policy) and review any changes since the last version. Our business changes frequently and this policy is subject to change from time to time. Unless stated otherwise, our current policy applies to all information that we have about you. We may require you to affirmatively consent to a revised version of this policy as a condition of continuing to use the Platform and or our Services.

Further Resources:

If you wish further information concerning privacy policies in general, and concerning online social networking and safety, you should visit the DSA’s website.

We Operate in Bangladesh:

Jomee Jomaa is based in Bangladesh. The Services are controlled and operated by us from Bangladesh and are not intended to subject us to the laws or jurisdiction of any other state, country or territory other than Bangladesh. Your Personal Data may be stored and processed in any country where we have facilities or in which we engage service providers, and by using the Services, you consent to the transfer of information to countries outside of your country of residence, including Bangladesh, which may have data protection rules that are different from those of your country. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your Personal Data.