Supplementary Terms

If you are a user located in the following countries: Hong Kong SAR, Macau SAR, Taiwan, United States, The United Kingdom of Great Britain and Northern Ireland, Japan, Republic of Korea, Singapore, Malaysia, Commonwealth of Australia, Canada, United Arab Emirates, State of Kuwait, State of Qatar, Kingdom of Bahrain, Arab Republic of Egypt, the terms set forth under your jurisdiction apply to you in addition to the terms set forth in our Privacy Policy.

1. Hong Kong SAR

If you choose not to provide personal information, you may not be able to use some of the features of TORRAS properly.

As a user in the Hong Kong SAR, you have the legal rights (to the extent permitted by applicable laws and regulations) to the personal information we hold about you.

You have the right to make an access request to obtain a copy of the data we process about you. You can also exercise the right to data correction and the right to stop the use of personal data for direct marketing purposes.

2. Macau SAR

If you choose not to provide personal information, you may not be able to use some of the features of TORRAS properly.

As a user of the Macau SAR, you have the legal rights (to the extent permitted by applicable laws and regulations) to the personal information we hold about you.

You have the right to make an access request to obtain a copy of the data we process about you. You may also exercise the right to data correction and the right to stop the use of personal data for direct marketing purposes, or the right to object to using your personal data based on your own reason.

3. Taiwan

We do not knowingly collect or solicit personal information from children under the age of 7, nor do we knowingly allow children under the age of 7 to register with TORRAS. If you are under the age of 7, please do not attempt to use or register with TORRAS, or provide us any personal information about yourself. Even if a user under the age of 7 uses TORRAS and its services, he or she must not provide us with any personal information. If the user is located in Taiwan, and is under 20 years of age, you must obtain parental/guardian consent to use TORRAS and its services.

We will first obtain your consent before transferring your personal information in order to provide you with personalized advertising (if any). You may exercise the rights set forth in Article 3 of the Personal Data Protection Act to:

(1) access your personal information for inspection and review;

(2) obtain a copy of your personal information;

(3) supplement or correct your personal information;

(4) request that we stop collecting, processing or using your personal information; and

(5) request that we delete your personal information. To the extent permitted by law, our ability to comply with your request may be limited.

4. United States

We do not collect personal information from children under the age of 13. If you are a child under the age of 13 and need to use TORRAS and its services, please obtain prior consent from a parent/guardian and their confirmation of this Privacy Policy. If you are a parent of a child under the age of 13 and do not agree with the content of this rule, please ask your child to immediately stop accessing/using TORRAS and its services. You have the right to request access to, stop, delete, and refuse to disclose your child's information through support@torraslife.com.

5. State of California

This section applies to California residents covered by the California Consumer Privacy Act of 2018 ("CCPA").

The CCPA provides California residents with certain legal rights, such as the right to access, delete, disclose or "prohibit the sale" of information, subject to exceptions.

If you use TORRAS and its services, we may collect and disclose your personal information as described in the Personal Information Collection List. For more information about the uses and other specifics of each type of personal information, please refer to this Privacy Policy and Personal Information Collection List.

We do not and have not sold your personal information to third parties in the way the term "sale" is traditionally understood or "sold" as defined by the CCPA . If you are a California resident covered by the CCPA and the CCPA does not recognize an exemption that applies to you or your personal information, you have the right to.

• Request that we disclose to you, free of charge, the following information stored during the 12 months prior to your request: the categories of your personal information, the categories of sources; the purposes for which your personal information was collected; the categories of third parties to whom personal information about you was disclosed, the categories of personal information disclosed (if applicable), the purposes for which personal information about you was disclosed; the specific personal information collected about you.

• You may request that we delete personal information about you, unless the CCPA recognizes an exemption.

• When you exercise your rights under the CCPA, you may not unlawfully discriminate on the basis of your exercise of those rights.

We will complete all verified applications within 45 days. If necessary, we may extend the 45-day period and an explanation for the delay will be included at that time.

Please note that in order to protect your personal information, we will need to verify your identity before responding to any exercise of rights request. In some cases, we may need to collect additional information to verify your identity, such as a government-issued identification document.

You may wish to log in to your account and manage your data there, as well as exercise your rights to other data (if any) via support@torraslife.com.

Under the CCPA, you may exercise your rights by contacting us via support@torraslife.com, or you may authorize an agent to make a request on your behalf. For requests made by an agent, we may ask you to verify your identity directly with us and to confirm with us the permission of the request submitted by your agent.

6.The United Kingdom of Great Britain and Northern Ireland

You can contact us at support@torraslife.com to process your personal information.

7. Japan

By clicking "Accept", you are consenting to the transfer of your personal information across borders to any country where our database is located or to any country where our service providers are located.

When you provide data to us, you need to know that China is not a country that has obtained an adequacy determination under Article 45 of the GDPR, and is not a member of APEC's CBPR system or the OECD. For information on the personal information protection systems of major countries and regions, please visit the website of the Commission for Personal Information Protection at https://www.ppc.go.jp/en/index.html

8. Republic of Korea

Children under the age of 14 must have their parent/guardian read and agree to this Privacy Policy (including the parent/guardian's own consent and consent on behalf of their child) before they can use TORRAS and its services(regardless of the reason for the use). We will not knowingly collect personal information from any child under the age of 14 without such consent. If you believe that we are holding any personal information about a child under the age of 14 without the consent of the parent/guardian, please contact our Data Protection Privacy Officer and we will immediately investigate (and delete) such personal information.

From time to time, we may provide your personal information to third parties outside of Republic of Korea for your use of TORRAS and its services，your personal information will be retained for the period described in the Privacy Policy of the relevant third-party service. In addition, we will retain certain personal information for a specific period of time as mandated by Republic of Korean law.

We will destroy personal information after the purposes for which it was collected and processed have been fulfilled (e.g., when its retention period expires and the purposes for which it was processed have been fulfilled) (except in cases where we are required by law or regulation to retain such personal information).

Under the supervision of our Data Protection Privacy Officer and in accordance with the agreement between you and us, we will destroy personal information that needs to be destroyed. We destroy personal information recorded and saved in electronic format by methods such as low-level formatting to ensure that such data cannot be copied; and personal information recorded and saved in hard copy by shredder or incineration. In addition, you may contact us by contacting the Data Protection Privacy Officer via support@torraslife.com.

9. Singapore

By clicking "Accept" you consent to the transfer of your personal information across borders to any country in which our database is located or to any country in which our service providers are located.

Your personal data is processed by TORRAS employees operating outside of Singapore. In such cases, before disclosing your personal data to a third party, TORRAS will take reasonable steps to ensure that the third party provides a standard of protection for the personal data so transferred that is comparable to the protection afforded by the Personal Data Protection Act 2012.

You have the right to access and correct your personal information. If you believe that we hold any other personal information about you or believe that we hold any other personal information about you and that information is inaccurate, you may contact us via support@torraslife.com.

10. Malaysia

In the event you are agreeing to the Privacy Policy in order for a minor (a person under the age of 18) to access and use TORRAS, you hereby consent to the provision of Personal Information of the minor to be processed in accordance with the Privacy Policy and you personally accept and agree to be bound by the terms in the Privacy Policy. Further, you hereby agree to take responsibility for the actions of such minor, and that minor's compliance with the Privacy Policy.

We are aware of the importance of protecting your personal information and therefore we promise you that we will examine the relevant privacy safeguards before processing your personal information. We undertake to take the necessary precautions to protect your personal information from loss, damage, alteration, disclosure, access or unlawful use.

You may request limiting the processing of your Personal Information by using the contact details provided in the Privacy Policy. However this may affect our provision of TORRAS to you. You have the right to withdraw your consent of Privacy Policy and request us correct, discontinue the use or provision of your personal information, and/or delete any and all personal information we have stored about you. If you need to make such a request, please contact us via support@torraslife.com.

11. Commonwealth of Australia

We take reasonable steps to ensure that the receipt and processing of your personal information by third parties located outside of Commonwealth of Australia complies with Commonwealth of Australian laws. However, you acknowledge that we have no control over, and are not responsible for, the actions and omissions of such third party recipients.

If you are dissatisfied with our response to your privacy complaint regarding your personal information, you may contact us via support@torraslife.com.

12. Canada

By clicking "Accept", you consent to the transfer of your personal information across borders to any country in which we have databases or affiliates. You may withdraw your consent to the collection, use and disclosure of your personal information that you have previously given us, subject to contractual or legal restrictions, by contacting our Data Protection Privacy Officer via support@torraslife.com. You have the right to withdraw your consent. To withdraw this consent, you may contact support@torraslife.com. This may affect the features of TORRAS and our ability to provide its services to you.

In addition, you have the right to access the personal information we hold about you, to be informed about how we use it and to whom we may disclose it. You may login your account or make a written request to access your personal information through the email support@torraslife.com. We may ask you to verify your identity further.

13. United Arab Emirates

By clicking on "Accept" you are consenting to the transfer of your information across borders to any country where our database is located or to any country where our service providers are located.

You may request that we notify you of the purposes for which we use, disclose, correct, discontinue using or providing, and/or delete any and all personal information we store about you. If you need to make such a request, please contact us via support@torraslife.com (Personal Information Protection Officer). We may also use the personal information you provide for the purpose of displaying personalized advertisements to you when you use the Services. For information on personal information protection systems in major countries and regions, please visit the website of the Commission for Personal Information Protection at https://www.ppc.go.jp/en/index.html

14. State of Kuwait

You have the right to withdraw your consent to this Privacy Policy and we delete/destroy the information you provide upon your request. If you need to make this request, please contact us via the the Personal Information Protection Officer: support@torraslife.com.

15. State of Qatar

By clicking on "Accept" you are consenting to the transfer of your information across borders to any country where our database is located or to any country where our service providers are located.

You can request that we inform you the purposes for which your personal information is used and disclosed, you have the right to withdraw your consent of Privacy Policy and request us correct, discontinue the use or provision of your personal information, and/or delete any and all personal information we have stored about you. If you need to make such a request, please contact us via support@torraslife.com. For information on major national and regional personal information protection systems, please visit the website of the Commission for the Protection of Personal Information at: https://www.ppc.go.jp/en/index.html

16. Kingdom of Bahrain

By clicking on "Accept" you are consenting to the transfer of your information across borders to any country where our database is located or to any country where our service providers are located.

You need to ensure that you have full legal capacity to use TORRAS (regardless of the reason for the use). If you have limited or no legal capacity, you should inform your legal guardian/parent and let them read and agree to this Privacy Policy. If you believe that we are holding any personal information about a person who does not have full legal capacity without the consent of the parent/guardian, please contact us and we will immediately investigate (and delete) such personal information.

After the purposes of this Privacy Policy and the User Agreement have been met, we will delete personal data in a timely manner if no retention is necessary. If there is a legitimate need to retain such personal data, we will retain it in a de-identified manner; and we will keep full records of the processing of personal data. Your personal data will be transferred to the People's Republic of China for processing. For information on the personal data protection systems of the main countries and regions, please visit the website of the Commission for Personal Data Protection at https://www.ppc.go.jp/en/index.html

We may use your personal information for direct marketing purposes and you have the right to request us to stop using personal data for direct marketing purposes.

You also have the right to be informed of the personal data that is being processed, the source of the data we obtain about you, the purpose of the processing, and how your rights may be affected if you do not provide us with your personal data, as set forth in the foregoing provisions of this Privacy Policy. If you need to exercise any of the foregoing rights, you may contact us and we will respond to your request within 15 days after verifying your identity. If we need any additional information from you, we will notify you of the additional information within 10 days after verifying your identification. If you abuse your rights as described above, we may deny your request and notify you within 15 days. If you believe that we should not refuse your request, or respond beyond the deadline, you may file a complaint with the Personal Data Protection Authority as provided by law.

In addition, you have the right to ask us to correct, block or delete personal data relating to you. You can do so by contacting the Data Protection Privacy Officer via support@torraslife.com to exercise your rights.

17. Arab Republic of Egypt

By clicking on "Accept" you are consenting to the transfer of your information across borders to any country where our database is located or to any country where our service providers are located.

We do not collect data relating to children under the definition of the Arab Republic of Egypt law. If you believe that we are holding any personal information about a child without the consent of the parent/guardian, please contact our Data Protection Privacy Officer and we will immediately investigate (and delete) such personal information.

You have the following rights with respect to your personal information under the laws of the Arab Republic of Egypt.

• The right of access, where you have the right to know which of your personal data is being processed and by whom, and the right to access such data.

• The right of withdrawal, where you have the right to withdraw your authorization for the processing of personal data.

• The right to modify, edit, delete and update, and the right to request timely corrections and additions to the data.

• The right to restrict processing, where you have the right to request the data user to restrict the processing of their personal data.

• The right to be informed of personal information breaches and your right to be informed of any breach involving your personal information.

• The right to object to personal information processing, should you find that activities involving the processing of your personal information violate fundamental rights and freedoms, you have the right to object to the relevant information processing activities.

If you need to exercise the above rights, please contact us via support@torraslife.com.

After the agreed purposes of this Privacy Policy and the User Agreement have been met, we will promptly delete personal data if there is no legal need to retain it. If there is a legitimate need to retain the personal data, we will retain it in a de-identified manner; at the same time, we will keep all records of the processing of the personal data.