General Terms & Conditions for Marco Polo Business Services Ltd

Card” means an electronic money account issued by us to you including the Prepaid Card linked to your account

Expiry Date” means the date on which your card will cease to work

Account Closure” a fee for redemption where detailed in the Fees and Limits Schedule

Business Day” Monday to Friday, 09:00hrs to 18:00hrs GMT, excluding bank and public holidays in the UK

Fees & Limits Schedule” the schedule contained herein

Fee” any fee payable by the Customer, as referenced in the Fees & Limits Schedule

KYC” Know Your Customer, requirements for knowledge of and information on customers in accordance with Money Laundering Regulations

KYB” Know Your Business requirement for knowledge of and information on the business in accordance with Money Laundering Regulations

SDD Card” Standard Due Diligence Prepaid Card / Instant Issue Prepaid Cards

Limitation Period” the period of 6 years following termination of this Agreement

E-money” is electronically (including magnetically) stored monetary value, represented by a claim on the issuer, which is issued on receipt of funds for the purpose of making payment transactions, and which is accepted by a person other than the electronic money issuer

Merchant” a retailer or any other person that accepts e-money

Payment Services” means all payment and e-money services and any related services available to the Customer and/or Additional Cardholder(s) where applicable through the use of the Account and/or Card

Reload” to add money to Your Account

Username and Password” login details selected by the Customer to access their Payment Services online

Travel Card” a physical pre-paid electronic payment card, it can be used anything within the law

we“, “us” or “our” Prepaid Financial Services Limited are the e-money issuer

MPBS” MARCO POLO BUSINESS SERVICES LTD (HK), it operates and supports Travel Card business

you” or “Your” the Customer and/or any person who has been provided with a Card by the Customer for use as an Additional Cardholder where applicable in accordance with these Terms and Conditions

Additional Card holder(s)” Where applicable you may apply for up to 1 additional Prepaid Cards

Schemes or Associations” As shown on your card

1. About us & MPBS:

Prepaid Financial Services is a licensed principal scheme member of MasterCard. MasterCard is a registered trademark of MasterCard International Incorporated.

MPBS is a Hong Kong incorporated company (registered number: 2216022) for the card-related and payment processing product planning, and product development.

2. Travel Card Management:

You can view your transaction history along with your card information online by logging onto http://www.marcopolobusiness.com/cards as well to report Your Card lost or stolen. If you prefer you can also email Us at support@marcopolobusiness.com.

3. Your Agreement with Us:

3.1. The issuer for Your Travel Card MasterCard is Prepaid Financial Services Limited. The Payment Services are also provided by us, and we are a registered company in England and Wales. Our Company Registration Number is 06337638. We are authorised and regulated as an e-money issuer by the Financial Conduct Authority. Registered Office: 4th Floor, 36 Carnaby Street London W1F 7DR.

3.2. Details of Our authorisation licence by the Financial Conduct Authority is available on the public register at http://www.fsa.gov.uk/

3.3. MPBS operates the Program on behalf of Prepaid Financial Services Limited.

3.4. At all times your Travel Card will remain the property of Prepaid Financial Services Limited.

4. Your Card and Account with Us:

You may reload your Travel Card subject to the limits provided by the Fees & Limits Schedule. We reserve the Right to vary these limits and to decline any reload at any time. A Reloading Fee may apply.

4.1. These terms and conditions administer the relationship between Us and You for the providing of the Payment Services by Prepaid Financial Services to you. This Agreement also contains important notices and information that may affect your rights and your ability to recover your money. By activating your account, you shall be deemed to have accepted and fully understood the terms and conditions set out in this agreement and you agree to comply with these by your use of the card and or by indicating your acceptance.

4.2. Your card is not a credit card and is not issued by a bank. You will not earn any interest on the balance of your card.

4.3. The Payment Services are prepaid payment services and not a credit or bank product, you must therefore ensure that you have a sufficient Available Balance to pay for each purchase you make in addition to all payment or cash withdrawals that you make using the Payment Services.

4.4 When you receive your card, You will need to activate it and then retrieve your PIN by following the activation instructions online at

http://www.marcopolobusiness.com/cards. The card will normally be ready for use immediately or on completion of the steps as outlined on the http://www.marcopolobusiness.com/cards. If you don’t activate your card, then any transactions that you attempt to carry out may be declined.

4.5 Where applicable Corporate Customers, where you have requested us to issue Travel Cards and a PIN to your employee(s) you agree to authorise each employee to undertake transactions on your behalf.

As the account holder you are responsible for the use of the cards and for any applicable fees or charges that your employees may incur. The use of Your Travel Card by Your employees will be regarded as confirmation to us that you have communicated these terms and conditions to them and that they accepted them prior to use. You accept that it is your duty to serve all cardholders with a copy of these terms.

4.6 Prepaid Financial Services Prepaid Cards cannot be shared with second parties

5 KYC / Know Your Customer requirements:

5.1 In order to purchase a Card, You must be at least 18 years old. We may require evidence of who you say you are and of your current address. You must assist us to comply with our regulatory requirements, applicable to KYC and anti-money laundering requirements on our business. Our regulatory requirements require us to keep records of provided information and documents by you which you also agree to.

5.2 We do not conduct credit checks on you but at times it may show on your credit file these will be marked by us as a non-credit search

5.3 The purchase of or use of the card will indicate to us that you consent to the checks described in this agreement being undertaken.

5.4 Being the Travel Card a pure payment processing product, MPBS relays on the applicant’s Bank for enhanced Due Diligence and Source of Wealth.

5.5 SDD card load limits are subject to lower limits and available to anyone aged 18 and over.

5.6 Your prepaid card currency shall be the amount or the local currency equivalent in which your Card is denominated. (E.g. Euros €)

5.7 Where permitted, you may request additional Cards linked to your primary card or account. You authorise us to issue cards and PINs to the additional cardholders and you authorise each additional cardholder to authorise transactions on your behalf. You remain responsible for any fees, transactions, use or misuse of any card or additional card requested by you.

5.8 You agree this agreement also applies to any additional cards and cardholders that you have arranged. You agree to communicate this agreement to any additional cardholders before they start using the card.

5.9 Corporate Customers – To apply for our Travel Card you must be a Public or Private Limited Company or partnership. We will require KYB evidence of who you are and your company address. We may ask you to provide some documentary evidence to prove this and/or we may check all information given by you with credit reference or fraud prevention agencies and other organisations. You will also be asked to meet our KYC requirements as set out in section 5.1.

We may perform a search of credit files in order to verify the identity of your owners, directors, partners or employees. The agencies may keep a record of this information and the searches made.

6. Fees and Charges:

6.1 All fees applicable to your prepaid card are set out in the fee table above. If we make changes to these fees at any point you will be given a 2 month notice period. If you do not contact us within this time frame we will assume you wish to accept the changes and continue to use your card.

7. How to use Your Travel Card:

7.1 A card may only be used by the person to whom the card was issued to.

8. Potential Card Restrictions:

8.1 A Card is not linked to a bank account and is not a cheque guarantee card, or credit card.

8.2 You can use the Payment Services up to the amount of the Available Balance for Transactions at Merchants of the relevant system. If the available balance is insufficient to pay for a transaction, some merchants will not permit you to combine use of a card or account with other payment methods.

8.3 Some transactions such as pay at pump may be restricted by the card programme manager

8.4 Some merchants such as restaurants may pre-authorise up to 20% of the full transaction value prior to processing the final bill

8.5 Your ability to use or access the Payment Services may occasionally be interrupted, for example if we need to carry out maintenance on our Scheme. Please contact Customer Services via our website to notify us of any problems you face.

9. Expiry of Your Card & Redemption of Your funds:

9.1. Your card has an expiry date printed on it. The funds on your account will no longer are usable following the expiry date of the most recent Card that was issued under the Account (“Expiry Date”).

9.2. The Payment Services and this Agreement shall terminate on the Expiry Date unless you request or are issued with a replacement Card prior to the Expiry Date in accordance with clause 10.3 or unless we otherwise agree to continue providing Payment Services to you following the Expiry Date.

9.3. You may not use your expired Card(s) after the Expiry Date.

9.4. If a Card expires before Your Available Balance is exhausted, you can contact Customer Services to request a replacement Card, provided you do so 14 days before the Expiry Date and subject to payment of a fee (where specified).

9.5. Notwithstanding any Expiry Date Your funds are available for redemption by contacting us at any time before the end of the 6 year Limitation Period. After the Limitation Period Your funds will no longer be redeemable to you.

9.6. Provided that Your request for redemption is made less than 12 months following the Expiry Date redemption will not incur any Late Redemption Fee. In the event that you make a request for redemption more than 12 months after the Expiry Date and before termination of the contract an Account Closure Fee may be charged (where detailed).

9.7. Where applicable Additional Cardholders’ Cards will also expire on the Expiry Date as shown on the Customer’s Primary Card.

9.8. We reserve the right to issue you with a replacement for an expired Card even if you have not requested one. If we do so, clause “If a Card expires before Your Available Balance is exhausted, you can contact Customer Services to request a replacement Card, provided you do so 14 days before the Expiry Date and subject to payment of a fee (where specified)” will not apply. If you have not requested a replacement Card, you will not be charged a Card Replacement Fee as set out in the Fees & Limits Schedule.

9.9. We shall have the absolute right to set-off, transfer, or apply sums held in the Account(s) or Cards in or towards satisfaction of all or any liabilities and fees owed to us that have not been paid or satisfied when due.

10. Cancelling Your Card:

10.1. If you are the customer and you wish to cancel the Payment Services at any time, you must request cancellation online by informing us of your wish to cancel and to claim a refund of your unused funds by emailing us as specified in section 2 above. You must e-mail us from the e-mail address you provided when registering your Account. Our Customer Services department will then suspend all further use of your Payment Services.

10.2. You may be asked to provide KYC identity documents as in clause 5.1 to enable us to complete the closure and process a refund for any unspent funds for you.

10.3. Once we have received all the necessary information from you (including KYC) and all transactions and applicable fees and charges have been processed, we will refund to the Customer any available balance less any fees and charges payable to us, provided that:

i. you have not acted fraudulently or with gross negligence or in such a way as to give rise to reasonable suspicion of fraud or gross negligence; and

ii. we are not required to withhold your Available Balance by law or regulation, or at the request of the police, a court or any regulatory authority.

10.4. Once the Payment Services have been cancelled, it will be your responsibility to destroy your Card(s).

10.5. You have 14 days from purchase to exercise your “cooling off rights”. We will cancel and return all funds to you subject to clause 10.3

11. Payment Disputes and Complaints:

11.1. If, following reimbursement of your available balance, any further transactions are found to have been made or charges or fees incurred using the card(s) or we receive a reversal of any prior funding transaction, we will notify you of the amount and you must immediately repay to us such amount on demand as a debt.

11.2. We aim to provide customers with easy access to our customer services team who receive record, investigate and respond to complaints. If you are unhappy with any of the services please email us on support@marcopolobusiness.com.

11.3. We take complaints very seriously and value the opportunity they provide to assist us with reviewing the way we do business and helping us meet our customers’ expectations. Our primary aim is to resolve any complaints that you may have as quickly and effectively as we can and consequently have documented the steps to be taken below.

11.4. In the first instance, your initial communication will be with Our Customer Care Team. We expect Our Customer Care Team to respond to your complaint in writing within five working days. We will do everything in our power at this stage to resolve this for you.

11.5. You agree to provide us with all receipts and information that we request which are relevant to your claim.

11.6. If our customer service team are unable to resolve your complaint. We will refer to our internal Complaints Officer who will respond to you within 14 working days. You may email them on complaints@prepaidfinancialservices.com

11.7. If having done and presented our complaints department with all of the information they request from you including receipts and copies of all communications sent and received and you still feel unhappy with our response you are able to escalate your complaint to the Financial Ombudsman Service;complaint.info@financial-ombudsman.org.uk. The Financial Ombudsman Service, South Quay Plaza, 183 Marsh Wall, London E14 9SR.

12. Lost and Stolen Cards

If your card is lost or stolen you must notify us straight away. The card will be blocked; this can also be done by you if you contact our online system at http://www.marcopolobusiness.com/cards. You may be liable to pay a replacement card fee. If you later find the card it will not be reactivated so you must destroy the card and await your replacement prepaid card.

13. Changes to the terms and conditions:

We may update or amend these terms and conditions (including our Fees & Limits Schedule). Notice of any changes will be given on the website or by notification by e-mail or by means of mobile device at least 2 months in advance. By continuing to use the Payment Services after the expiry of the 2-month notice period, you acknowledge that you indicate your acceptance to be bound by the updated or amended terms and conditions. If you do not wish to be bound by them, you should stop using the Payment Services immediately in accordance with our cancellation policy.

14. Cooling off Period and Your Rights to cancel your Agreement

You have a cooling off period of 14 days starting the date that you have successfully completed registration of your prepaid card with us. You may withdraw from our service without any penalties but subject to deduction of any reasonable costs incurred by us. You may cancel within these 14 days informing us in writing that you wish to withdraw and cancel the agreement you have with us. After the cooling off period you may cancel your agreement with us in accordance with clause 11.

15. Deposit Guarantee Scheme

The Payment Services, card and account are payment products and not deposit, credit or banking products, as such they are not covered by the Financial Services Compensation Scheme.

16. Protecting your money

In the unlikelihood that Prepaid Financial Services was to become insolvent you may lose your funds. However we will do everything that we can lawfully to safeguard your funds for you.

Additional Terms and Conditions

1. General

The terms and conditions concerning the issuance and use of the Travel Card are regulated in the General Terms & Conditions for Marco Polo Business Services Ltd.

2. Liability

MPBS shall not be held liable for any transactions conducted with the Travel Card. In particular, the Cardholder shall acknowledge that MPBS is not liable even if, for any reason, the affiliated merchants or authorized banks do not accept the Travel Card, or accept it only partly. This shall also apply in the case of late delivery of, or failure to deliver, goods or services. In the event of disputes or complaints of any kind concerning goods or services, or the exercise of any right in this connection, the Cardholder shall contact exclusively the affiliated merchant and/or authorized bank.

3. Transmittal of Documentation and Identification Tools

The Cardholder authorizes MPBS to use all kind of documentation and information delivered by the Cardholder to MPBS.

4. Duration

This Agreement shall come into force as of the date of issuance of the Travel Card and shall continue in force until the expiry date engraved upon the Travel Card. Thereafter, it shall be renewed for the same duration of the Travel Card unless terminated by either Party by giving at least 2 months previous written notice to the other Parties.

MPBS reserves the right at its discretion to terminate the agreement or to block the Travel Card in case the Cardholder fails to pay the Fees in time or in any other cases decided by MPBS.

In case of termination of the agreement MPBS shall transfer to the Cardholder the Deposited Amount after deduction of the applicable Fees.

5. Others Conditions

The Cardholder has read and understood these General Terms and Conditions and accepts them in full by signing this documents. MPBS reserves the right to amend the fees and the General Terms and Conditions at any time. The Cardholder shall be informed of such changes by circular letter or in some other appropriate form. The changes shall be regarded as accepted if the Cardholder raises no objection within 14 days from notification. All legal relations between the Cardholder and MPBS Ltd shall be subject to Hong Kong law. The place of performance, the place of special proceedings for the collection of debts owed by Cardholders residing abroad and the exclusive place of jurisdiction for all disputes shall be Hong Kong. MPBS shall, however, also have the right to take legal action against the Cardholder in the competent court of his place of residence or in any other competent court.

Privacy Policy

1. Collections and Usage of Personal Information:

Personal information is data that can be used to identify or contact a single person.

You may be asked to provide your personal information anytime you are in contact with Invest Asia and/or Marco Polo or one of their affiliated companies. Invest Asia and/or Marco Polo or one of their affiliated companies may share this personal information with each other and use it consistent with this Privacy Policy. They may also combine it with other information to provide and improve our products, services, content, and advertising. You are not required to provide the personal information that we have requested, but, if you chose not to do so, in many cases we will not be able to provide you with our products or services or respond to any queries you may have.

Here are some examples of the types of personal information Invest Asia and/or Marco Polo or one of their affiliated companies may collect and how we may use it.

1.1 What personal information we collect:

▪ When you create an Invest Asia and/or Marco Polo or one of their affiliated companies ID, apply for commercial credit, purchase a product and/or service, download a software update, contact us or participate in an online survey, we may collect a variety of information, including your name, mailing address, phone number, email address, contact preferences, and credit and store valued cards information.

▪ When you share your content with family and friends using Invest Asia and/or Marco Polo or one of their affiliated companies` services, or invite others to participate in Invest Asia and/or Marco Polo or one of their affiliated companies` services or forums, Invest Asia and/or Marco Polo or one of their affiliated companies may collect the information you provide about those people such as name, mailing address, email address, and phone number. Invest Asia and/or Marco Polo or one of their affiliated companies will use such information to fulfill your requests, provide the relevant product or service or their promotion, or for anti-fraud purposes.

1.2 How we use your personal information:

▪ The personal information we collect allows us to keep you posted on Invest Asia and/or Marco Polo or one of their affiliated companies latest product announcements, software updates, and upcoming events or promotions.

▪ We also use personal information to help us create, develop, operate, deliver, and improve our products, services, content, promotion and advertising, and for loss prevention and anti-fraud purposes.

▪ We may use your personal information, including date of birth, to verify identity, assist with identification of users, and to determine appropriate services. For example, we may use date of birth to determine the age of Invest Asia and/or Marco Polo or one of their affiliated companies` ID account holders.

▪ From time to time, we may use your personal information to send important notices, such as communications about purchases and changes to our terms, conditions, and policies. Because this information is important to your interaction with Invest Asia and/or Marco Polo or one of their affiliated companies, you may not opt out of receiving these communications.

▪ We may also use personal information for internal purposes such as auditing, data analysis, and research to improve Invest Asia and/or Marco Polo or one of their affiliated companies` products, services, and customer communications.

▪ If you enter into a sweepstake, contest, or similar promotion we may use the information you provide to administer those programs.

2. Collection and Use of Non-Personal Information:

Invest Asia and/or Marco Polo or one of their affiliated companies also collect data in a form that does not, on its own, permit direct association with any specific individual. We may collect, use, transfer, and disclose non-personal information for any purpose. The following are some examples of non-personal information that we collect and how we may use it:

▪ We may collect information such as occupation, language, zip code, area code, unique device identifier, referrer URL, location, and the time zone where an Invest Asia and/or Marco Polo or one of their affiliated companies` product or service is used so that we can better understand customer behavior and improve our products, services, and advertising.

▪ We may collect information regarding customer activities on our website, or o the Cloud, and its online stores and from our other products and services. This information is aggregated and used to help us provide more useful information to our customers and to understand which parts of our website, products, and services are of most interest. Aggregated data is considered non-personal information for the purposes of this Privacy Policy.

▪ We may collect and store details of how you use our services, including search queries. This information may be used to improve the relevancy of results provided by our services. Except in limited instances to ensure quality of our services over the Internet, such information will not be associated with your IP address unless fraud is allegedly detected.

If we do combine non-personal information with personal information the combined information will be treated as personal information for as long as it remains combined.

3. Cookies and Other Technologies:

Invest Asia and/or Marco Polo or one of their affiliated companies` websites, online services, interactive applications, email messages, and advertisements may use “cookies” and other technologies such as pixel tags and web beacons. These technologies help us better understand user behavior, tell us which parts of our websites people have visited, and facilitate and measure the effectiveness of advertisements and web searches. We treat information collected by cookies and other technologies as non-personal information. However, to the extent that Internet Protocol (IP) addresses or similar identifiers are considered personal information by local law, we also treat these identifiers as personal information. Similarly, to the extent that non-personal information is combined with personal information, we treat the combined information as personal information for the purposes of this Privacy Policy.

Invest Asia and/or Marco Polo or one of their affiliated companies and its partners use cookies and other technologies also in mobile advertising services to control the number of times you see a given ad, deliver ads that relate to your interests, and measure the effectiveness of ad campaigns.

Invest Asia and/or Marco Polo or one of their affiliated companies and our partners also use cookies and other technologies to remember personal information when you use our website, online services, and applications. Our goal in these cases is to make your experience with Invest Asia and/or Marco Polo or one of their affiliated companies more convenient and personal. For example, knowing your first name lets us welcome you the next time you visit the Invest Asia and/or Marco Polo or one of their affiliated companies Online Store.

As is true of most Internet services, we gather some information automatically and store it in log files. This information includes Internet Protocol (IP) addresses, browser type and language, Internet service provider (ISP), referring and exit websites and applications, operating system, date/time stamp, and clickstream data.

We use this information to understand and analyze trends, to administer the site, to learn about user behavior on the site, to improve our product and services, and to gather demographic information about our user base as a whole. Invest Asia and/or Marco Polo or one of their affiliated companies may use this information in our marketing and advertising services.

In some of our email messages, we use a “click-through URL” linked to content on the Invest Asia and/or Marco Polo or one of their affiliated companies` websites. When customers click one of these URLs, they pass through a separate web server before arriving at the destination page on our website. We track this click-through data to help us determine interest in particular topics and measure the effectiveness of our customer communications. If you prefer not to be tracked in this way, you should not click text or graphic links in the email messages.

Pixel tags enable us to send email messages in format customers can read, and they tell us whether mail has been opened. We may use this information to reduce or eliminate messages sent to customers.

4. Disclosure to Third Parties:

At times Invest Asia and/or Marco Polo or one of their affiliated companies may make certain personal information available to strategic partners that work with Invest Asia and/or Marco Polo or one of their affiliated companies to provide products and services, or that help us market to customers. For example, when you purchase and activate your Account, you authorize Invest Asia and/or Marco Polo or one of their affiliated companies and our partner(s) to exchange the information you provide during the activation process to carry out service. If you are approved for service, Invest Asia and/or Marco Polo or one of their affiliated companies` respective privacy policies will govern your Account

4.1 Service Providers:

Invest Asia and/or Marco Polo or one of their affiliated companies shares personal information with companies who provide services such as information processing, extending credit, fulfilling customer orders, delivering products to you, managing and enhancing customer data, providing customer service, assessing your interest in our products and services, and conducting customer research or satisfaction surveys. These companies are obligated to protect your information and may be located wherever Invest Asia and/or Marco Polo or one of their affiliated companies operates.

4.2 Others:

It may be necessary − by law, legal process, litigation, and/or requests from public and governmental authorities within or outside your country of residence − for Invest Asia and/or Marco Polo or one of their affiliated companies to disclose your personal information. We may also disclose information about you if we determine that for purposes of national security, law enforcement, or other issues of public importance, disclosure is necessary or appropriate.

We may also disclose information about you if we determine that disclosure is reasonably necessary to enforce our terms and conditions or protect our operations or users. Additionally, in the event of a reorganization, merger, or sale we may transfer any and all personal information we collect to the relevant third party.

5. Protection of Personal Information:

Invest Asia and/or Marco Polo or one of their affiliated companies take the security of your personal information very seriously. Invest Asia and/or Marco Polo or one of their affiliated companies services such as your Account online protects your personal information during transit using certified encryption by Norton. When Invest Asia and/or Marco Polo or one of and the ones of their affiliated companies to store your personal data.

When you use some Invest Asia and/or Marco Polo or one of their affiliated companies products, services, or applications or post on an Invest Asia and/or Marco Polo or one of their affiliated companies forums, chat room, or social networking service, the personal information and content you share is visible to other users and can be read, collected, or used by them. You are responsible for the personal information you choose to share or submit in these instances. For example, if you list your name and email address in a forum posting, that information is public. Please take care when using these features.

6. Integrity and Retention of Personal Information:

Invest Asia and/or Marco Polo or one of their affiliated companies make it easy for you to keep your personal information accurate, complete, and up to date. We will retain your personal information for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law.

6.1 Access to Personal Information

You can help ensure that your contact information and preferences are accurate, complete, and up to date by logging in to your Account. For other personal information we hold, we will provide you with access for any purpose including to request that we correct the data if it is inaccurate or delete the data if Invest Asia and/or Marco Polo or one of their affiliated companies are not required to retain it by law or for legitimate business purposes. We may decline to process requests that are frivolous/vexatious, jeopardize the privacy of others, are extremely impractical, or for which access is not otherwise required by local law.

7. Location Based-Services (LBS)

To provide location-based services on Invest Asia and/or Marco Polo or one of their affiliated companies products and or services, Invest Asia and/or Marco Polo or one of their affiliated companies and our partners and licensees may collect, use, and share precise location data, including the real-time geographic location of your computer or device. Where available, location-based services may use GPS, Bluetooth, and your IP Address, along with crowd-sourced Wi-Fi hotspot and cell tower locations, and other technologies to determine your devices’ approximate location. Unless you provide consent, this location data is collected anonymously in a form that does not personally identify you and is used by Invest Asia and/or Marco Polo or one of their affiliated companies and our partners and licensees to provide and improve location-based products and services.

8. Third-Party Sites and Services

Invest Asia and/or Marco Polo or one of their affiliated companies` websites, products, applications, and services may contain links to third-party websites, products, and services. Our products and services may also use or offer products or services from third parties − for example, a third-party application. Information collected by third parties, which may include such things as location data or contact details, is governed by their privacy practices. We encourage you to learn about the privacy practices of those third parties.

9. International Users

All the information you provide may be transferred or accessed by entities around the world as described in this Privacy Policy. Invest Asia and/or Marco Polo or one of their affiliated companies abide by the “safe harbor” frameworks set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information collected by organizations in the European Economic Area and Switzerland.

Please note that personal information is controlled by Invest Asia and/or Marco Polo or one of their affiliated companies, and processed on their behalf by Invest Asia and/or Marco Polo or one of their affiliated companies.

10. Our Companywide Commitment to Your Privacy

To make sure your personal information is secure, we communicate our privacy and security guidelines to Invest Asia and/or Marco Polo or one of their affiliated companies` employees and strictly enforce privacy safeguards within the company.

11. Privacy Questions

If you have any questions or concerns about Invest Asia and/or Marco Polo or one of their affiliated companies` Privacy Policy or MDPA or if you would like to make a complaint about a possible breach of local privacy laws, please contact us at the contact email address provided in each site (e.g. contacts@marcopoloexchage.com)

All such communications are examined and replies issued where appropriate as soon as possible. If you are unsatisfied with the reply received, you may refer your complaint to the relevant regulator in your jurisdiction. If you ask us, we will endeavor to provide you with information about relevant complaint avenues, which may be applicable to your circumstances.

Invest Asia and/or Marco Polo or one of their affiliated companies may update its Privacy Policy from time to time. When we change the policy in a material way, a notice will be posted on our websites along with the updated Privacy Policy.