Privacy Notice

1. Why we collect and process your personal data

We collect and process your personal data to perform our obligations pursuant to the Travē App Terms and Conditions. To create your Travē App user account. You have the following options when creating your user account:

• Register your email address and set a password. A One-Time Pin ("OTP") will be sent to your email address, which you need to submit through the App to complete the registration.
• Log-in using your Apple, Facebook, or Google account. If you choose this option, your name, email address, and unique identifier associated with your account will be shared with us.

To purchase an international eSIM. The App presents you with a selection of data-only eSIM plans that you may use outside of the Philippines. We have made several payment methods available for your convenience, which includes:

• Credit Card or Debit Card via [Stripe, Inc.]
• Apple Pay
• PayPal
• Alipay

The payment details that you submit via any of the aforementioned options are transmitted directly to the payment partner. These details are processed in compliance with the terms of use and privacy policy of the respective payment partner. SMART does not have access to your payment information.

To manage your purchased eSIM profiles. The App enables you to add, activate, view, modify, and delete the eSIM profiles that you have purchased. Purchased eSIM profiles will remain accessible on your Travē App account even after you use up the data allocation. To reactivate a specific eSIM profile, simply purchase top-ups for more data allocation or extend the validity of your eSIM.

To provide you with customer support. When contacting us for support, we will collect and process your name and email address to validate your Travē App account and confirm the eSIM and data package you have subscribed to. Additionally, you may be asked to provide a mobile number which we will use to contact you for updates regarding your request.

We process your personal data based on our legitimate interest to function effectively as a business, except when your fundamental rights and freedoms override our interests. Such interests, include, among others:

• To continuously improve our products and services. We collect, use, process, and analyze your usage of the App to understand areas for improvement and identify relevant products and offers. This analysis includes data such as the eSIM data plans and sections of the App you frequently view, the time spent on purchases, and other similar interactions with the App. Where possible, the information used for analysis is in aggregate form, which does not identify you individually.
• To send you information about special offers and promotions within the Travē App. From time to time, we may carry out special promotions that are exclusively available to Travē App users. You may automatically qualify for these special promotions when you purchase certain eSIM data plans within a promo period. The mechanics of these special promotions will be published in the App for your information.

2. Why your personal data is shared

We have partnered with Redtea Mobile PTE. LTD ("Redtea") for the development, operations, and customer support for the Travē App. When your personal data is shared, we ensure that it is done on a confidential basis, through secure channels, and in compliance with applicable privacy laws and regulations. Only personnel with a need-to-know will have access to your personal data.

Redtea is also the supplier of the international eSIM data plans available for purchase through the App; thus, Redtea may process your personal data for their own purposes as a personal information controller. For information about how Redtea processes your personal data in relation to your purchase, activation, and usage of these eSIM plans, you may refer to their Privacy Policy (https://redteago.com/privacy-policy/).

3. How your personal data is protected

The integrity, confidentiality, and security of your personal data is important to us. This is why we strictly enforce this Privacy Notice within SMART and have implemented technical, organizational, and physical security measures that are designed to protect your information from unauthorized or fraudulent access, alteration, disclosure, misuse, and other unlawful activities. We also require our service providers to implement the same measures. Your personal data is also protected from other natural and human dangers.

Your Personal Information will remain in our records for an additional three (3) years after your last transaction or usage after which your account will automatically be deleted. However, should you intentionally delete your Travē App user account, we will immediately delete all your data, including your personal information, purchase history, and other stored information.

4. Your rights and choices

Subject to exceptions under applicable Privacy Laws, you are entitled to request:

• Access to the personal data we process about you;
• Rectification of your personal data if it is found to be outdated, inaccurate, or incomplete;
• Erasure of your personal data in cases where it is no longer needed to achieve the legitimate purpose of its processing;
• Restriction of processing of your personal data in limited circumstances;
• Portability of your personal data so that you may receive a copy thereof or that we transmit the same to another company on your behalf.

Depending on the circumstances, such as when we process your personal data based on your consent, you may also have the right to object to the processing thereof. Please note that this will not affect the lawfulness of the processing that was carried out before you withdrew your consent or SMART's right to continue parts of the processing based on other legal bases than your consent. If, however, we have not provided you with another legal basis justifying the processing of your personal data in this privacy statement, we will stop the processing and delete your personal data.

To exercise any of these rights, you may get in touch with our Data Privacy Officer through the contact details provided below. In some instances, we may request for supporting documents or proof before we effect any requested changes to your personal data.

If, despite our commitment and efforts to protect your personal data, you believe that your data privacy rights have been violated, we encourage you to come to SMART first so that we can work together to resolve your complaint. You have the right at all times to register a complaint directly with the National Privacy Commission or to make a claim against us with a competent court (either in the country where you live, the country where you work or the country where you deem that data privacy law has been infringed).

5. Changes to our Privacy Policy

From time to time, we may update this Privacy Notice to comply with changes in applicable laws, to comply with government and regulatory requirements, to adapt to new technologies and protocols, to align with industry best practices, and for business purposes.

You will always be provided notice if these changes are significant and, if we are required by law, we will ensure to obtain your updated consent.

This notice is effective on [1-June-2025].