PRIVACY POLICIES

GENERAL PRIVACY POLICY

Mogo Holdings Limited values your privacy. This section sets out the Privacy Policy which applies to

our website at www.mogoplus.com and the service that we provide as a result via the website (the

“Service”). It explains what personal information we collect from users of our site and what we do

with that information. We update our policy from time to time, and recommend for you to revisit

our website regularly to see the latest copy of our Privacy Policies. Any changes will come into effect

when the updated Privacy Policies are posted to the website. We have created these Privacy Policies

to demonstrate our commitment to protecting your privacy and to disclose our information and

privacy practices for our website, our software and our services.

If you have any further questions about our Privacy Policies, email us at support@mogoplus.com.

1. WHO ARE WE?

This website and the Service is operated by Mogo Holdings Limited “MOGO”, which is a company

registered in England and Wales with company number 9425237. Its registered office is at 107

Cheapside, London EC2V 6DN.

2. COLLECTION AND USE OF PERSONAL INFORMATION

Our site collects personal information about you when you use a link to send us an email. If, in that

email or any attachment to the email, you voluntarily provide us with personally identifiable

information about yourself, such as your name, address or telephone number, we will collect and

store that personal information and by using that link you consent to us doing so.

3. CONTROL AND PROCESSING OF PERSONAL INFORMATION

We process personal data on behalf of our our customers, who use our Service to gather information about

an application you have made to them. However, we, Mogo Holdings Limited, is the Data Processor

for the purposes of the Data Protection Act 1998 and we do not make independent decisions about

how your personal information is processed in order to provide the Services to our users.

4. SHARING OF PERSONAL INFORMATION

It is necessary for the operation of our service for you or us to disclose your personal information to:

our employees and agents, and any future group companies and their employees and

agents, for the purpose of communicating with you.

– anyone who may purchase any or all of our assets, including your personal information (we

will contact you using the details you provide if there is any change in the person controlling

your information).

As a result of us disclosing your personal information to any of the parties mentioned above, you

consent to your personal information being held by us and additionally by the parties mentioned

above for the purposes of providing the Service.

We will not disclose your personal information to anyone other than those parties set out within this

Privacy Policy without your consent, unless the law requires us to do so.

5. IP ADDRESSES AND COOKIES

We may collect information about your computer, including where available your IP address,

operating system and browser type, for system administration and to analyse aggregate

information. Information about our use of cookies can be found in our Cookies Policy.

6. SECURITY OF PERSONAL INFORMATION

We take the security and disclosure of personal information very seriously and as such we will not

sell, trade, rent or otherwise provide personal information sent to us via our site to any third parties

save as set out above.

We are mindful of the importance of upholding the security of information under our control. All

data collected through our site that is stored electronically, is stored on secure servers, and we have

stringent security and confidentiality procedures covering the storage and disclosure of such

information, in accordance with the Data Protection Act 1998. We endeavour to take all reasonable

steps to protect the privacy of your personal information. However, we cannot guarantee the

security of any personal information you disclose on-line. You accept the inherent security risks of

providing information and transacting over the Internet, and will not hold us responsible for any

breach of security, unless this is due to our negligence or wilful default.

6. OTHER WEBSITES

Some websites that have links to and from our site from time to time may collect personal

information about you when you access or utilise those links. We do not control the collection or use

of such information, and the practices of those websites are not covered by this Privacy Policy. Some

websites that have links to and from our site from time to time may also use their own cookies. We

have no access to, or control over these cookies, and you are advised to check the cookie policies on

such other websites or to amend your site browser’s settings with respect to cookies accordingly.

7. IDE-MNITY

By using our website, you agree to indemnify and hold harmless Mogo Holdings Limited from and

against any and all losses, claims, damages, costs and expenses (including reasonable legal and

accounting fees) that we may become obliged to pay, arising or resulting from your use of our

website, the content, or your breach of this Privacy Policy and the Terms of Use of which they are a

part. Mogo Holdings Limited reserves the right to assume or participate, at your expense, in the

investigation, settlement and defence of any such action or claim.

BUSINESS CONTACTS PRIVACY POLICY

This page provides information about how we use and share personal data relating to our business

contacts and their representatives.

1. WHAT DO WE USE BUSINESS PERSONAL DATA FOR?

This section explains the purposes for which we use personal data about our business contacts

and their representatives.

Marketing

We use personal data for marketing purposes. This includes informing you about products and

services that we think may be of interest to you and providing you with related materials such as

news items and blog posts. We would contact you for marketing purposes by email, telephone or

post with your consent and would stop any such communication upon your request. You might also

be contacted through any channel for other purposes — for example, as part of our ordinary

relationship management activity and as necessary to deliver the Service.

Relationship management

We use personal data for relationship management purposes. Relationship management is the

ongoing maintenance of our relationship with our clients and their representatives. This could

include activities such as letting you know about product changes or planned maintenance activity,

contacting you with billing enquiries, dealing with your enquiries, or asking you for feedback or

about what sorts of products you want us to develop.

Providing services

Sometimes we might need to use your personal data to provide you with information, services and

facilities that you have asked for. For example, if you ask us for a brochure for one of our products.

Monitoring and improving our websites

We may use information such as how different people navigate around our websites, how long they

spend on particular pages, whether they download any of our content (including product brochures,

white papers and so on) or watch videos in order to help improve the user experience of our

websites.

2. WHAT ARE OUR LEGAL GROUNDS FOR HANDLING PERSONAL DATA?

We rely on your consent to make contact with you by email for marketing purposes. You can

withdraw that consent and ask us to delete your information at any time by contacting us directly via

support@mogoplus.com — please see section 6.

The United Kingdom’s data protection law also allows the use of personal data where the benefits

(or “legitimate interests”) of doing so outweigh the possible negative implications for the relevant

individuals. These are the grounds on which we usually rely when we use your information for

anything other than making contact with you by email for marketing purposes with your consent.

In some circumstances, we may have other grounds to process personal data for example:

– Necessary for performance of a contract with the relevant individual, or to take steps for

entering into a contract. For example, if you sign up to one of our products or services, it will

often be necessary for us to use your details in order to provide that product or service and

you must consent to our use of your details to the extent required to provide that product or

service in order to use that product or service.

– Necessary in order to comply with a legal obligation. For example, some regulators,

government bodies and courts have powers to order us to provide personal information

and, like any other organisation, we sometimes have to comply with their requests and we

whilst we may make commercially reasonable efforts to defend personal information from

unjustified regulatory or governmental access, we do not make any guarantee about the

extent to which we

3. WHO DO WE SHARE THE INFORMATION WITH?

Your personal data may be shared between the colleagues of Mogo Holdings Limited to allow them

to perform their job functions and any future companies that are to be set-up or form part of Mogo

Holdings Limited.

We may also provide your information to third parties who help us use it. For example:

– We might use a third party email broadcasting service in order to send you marketing emails

(if you have agreed to receive them).

– We might use a printing company to produce and send personalised direct mail.

– Our database of personal data may be hosted by, but not accessible to, third parties on our behalf.

These service providers will not be allowed to use your information for their own purposes or on

behalf of other organisations.

4. WHERE IN THE WORLD IS THE INFORMATION SENT?

We are based in the United Kingdom, and will normally access and use your information from here.

However, we also have operations in Australia and personal data may be accessed from there too. In

both cases, the use of the information in those locations is protected by European data protection

standards.

In particular, personal data that you submit to us in the EU is stored at rest inside the EU in data

centres located in the United Kingdom. We may transfer your personal data outside of the EU in

providing the Service to you. By using the Service you consent to our doing so. We ensure that we

have adequate contractual and procedural measures in place to protect any such transfers of

personal data outside the EU.

5. FOR HOW LONG IS THE INFORMATION RETAINED?

We will normally keep your personal data while you or your employer have an ongoing relationship

with us or if you have demonstrated an interest in our products and services within the past two

years. You can request us to delete it earlier as explained in section 6.

6. WHAT RIGHTS DO YOU HAVE IN RESPECT OF THE INFORMATION THAT WE HOLD ABOUT YOU?

You have several different rights in relation to the personal data that we hold about you. These are

briefly described below.

Access: You have a right to find out what personal data we hold about you, and certain other

information such as how we are using it. From 25 May 2018, you also have a right to receive

information in a portable format in certain circumstances.

Rectification: If you believe that the information that we hold about you is Inaccurate or out of date,

you have a right to get it corrected.

Withdrawal of consent / objection: Where we rely on your consent to use your personal data, you

are free to withdraw that consent at any time. In any other cases, you can let us know that you

object to us using your personal data (for example, if you do not want to receive marketing calls

from us any more).

Deletion: If you want us to delete your personal data, you can ask us to do so at any time. (However,

you may wish us to retain your basic details on a suppression file so that we do not subsequently

contact you if we receive your details again in the future.)

Restriction: You can ask us to restrict our use of your personal data in some circumstances, such as

while we are verifying whether the information is accurate. While the information is restricted, it can

only be used for certain limited purposes such as bringing or defending legal claims, or protecting

another person. It cannot be used or shared for ordinary purposes.

If you have any questions about our processing of personal information, or the rights set out in these

Privacy Policies and how to exercise them you can write to:

The Data Protection Officer

Mogo Holdings Ltd

58 Davies Street,

London, Wik 5AB

support@mogoplus.com

MOGO SOFTWARE PRIVACY POLICY

This section sets out the Privacy Policy which applies to our software. It explains what security

measures we have in place, how we store log-in credentials and what personal information we

collect from users of our software.

1. SECURITY

We maintain our servers in a highly secure server environment with 24 X 7 monitoring, surveillance

and support to prevent unauthorized access and data security. Advanced security measures

including firewalls, security guards and surveillance are taken to ensure the continued service and

protection of our services from natural disaster, intruders and disruptive events.

2. PASSWORDS AND LOG-IN CREDENTIALS

Your passwords and other log-in credentials do not pass through Mogo Holdings Limited servers or

those of its service provider partners. When you enter this confidential information into the MOGO

application, it goes straight to the secure website which you authorise to access on your behalf.

Neither Mogo Holdings Limited employees nor any of its contractors or service provider partners can

obtain or access your passwords or other log-in credentials entered into our software. We will also

never ask you for your passwords or other log-in credentials via mail, email or telephone or in any

other unsolicited manner.

3. INFORMATION WE COLLECT

Our application collects, encrypts and securely transfers confidential, personal information. By

downloading or connecting to the application, entering their secret log-in credentials and other

information required from time to time to complete a form on our website or in our Service users

consent to Mogo Holdings Limited providing this service to service provider partners, requesting and

paying for verification of specified information. We may store this confidential, personal information

at the request of the relevant Data Controller for a period of no longer than 30 days after we have

collected it. Once it has been received by our service provider partners, we delete it permanently.

We may collect limited personal information from users who download or use our software, as

required by a service provider partner. This data consists of names, email address, a reference

number and/or other identifying data provided by a service provider. We use this information to

authenticate users and implement our verification service.

We collect and log aggregate user statistics and website traffic. Such information includes traffic

statistics, date and time of visits, device and browser type used to access the service, frequency of

visits, etc. We use this information to improve the services delivered to our customers, to track and

diagnose software performance problems and to administer our website. We may disclose such

aggregated user statistics in order to describe our services to prospective partners, affiliates and

other third parties for lawful purposes.

Other than as required by your service provider and agreed by you or as disclosed in this Privacy

Policy, at no time will Mogo Holdings Limited disclose identifiable personal information to any third

parties without your express, written consent.

If you have any further questions about our Privacy Policies, email us at support@mogoplus.com.