Privacy Notice for B2

Bsquared Technology Pte Ltd and its affiliated companies, including M2 Digital Pte Ltd (UEN 202311659D), Merkle Prime (Hong Kong) Limited (CR No. 2400797), Merkle (Hong Kong) Limited (CR: 2509675), and Merkle Australia Pty Ltd (ABN 23 651 595 934), (collectively, “B2 Group,” “we,” “us,” or “our”), are committed to transparency in the collection, use, and sharing of personal information across all group entities.

This Privacy Notice explains how we collect, use, and share your personal information, and your rights under the applicable laws, including:

• The Personal Data Protection Act 2012 (PDPA) of Singapore.
• The Personal Data (Privacy) Ordinance (PDPO) of Hong Kong.
• The Privacy Act 1988 (Cth) of Australia, including the Australian Privacy Principles (APPs).

This Privacy Notice applies to all visitors to the B2 Group’s websites, including but not limited to https://www.btwo.io/ (the “Websites”) and any services provided by B2 Group entities.

Collection and Use of Personal Information

We may collect and use your personal information, such as your name, address, email address, and other data, for the following purposes:

• Website Interaction: To understand and improve how visitors use our Websites.
• Onboarding: To process applications for onboarding with any B2 Group entity.
• Communication: To respond to inquiries, comments, or complaints.
• Security: To ensure safety and security across the B2 Group.
• Regulatory Compliance: To comply with legal obligations under relevant laws in Singapore, Hong Kong, and Australia.

Onboarding Information

When onboarding as a counterparty, you may need to provide personal information, including:

• Full name, email address, and phone number.
• Residential address and nationality.
• Date of birth and employment details.
• Financial information.

This information is securely shared within the B2 Group to facilitate:

1. Anti-Money Laundering (AML) Compliance: As required under Singapore’s Payment Services Act 2019 (PS Act), Hong Kong’s Anti-Money Laundering and Counter-Terrorist Financing Ordinance (AMLO), and Australia’s Anti-Money Laundering and Counter-Terrorism Financing Act 2006.
2. Fraud Prevention and Verification: To verify customer identities and prevent fraud.

Failure to provide the required information may prevent us from onboarding you or delivering services.

Group-Wide Sharing of Information

We may share your personal information within the B2 Group to ensure seamless service delivery, compliance, and operational efficiency. This includes:

1. Internal Sharing: Sharing between Bsquared Technology Pte Ltd, Merkle (Hong Kong) Limited, and Merkle Australia Pty Ltd for onboarding, verification, and service delivery.
2. Centralised Functions: Group-level functions such as compliance, audit, and risk management, accessible by relevant teams across jurisdictions.

Purposes and Legal Basis for Processing

The purposes for processing personal information remain consistent across jurisdictions. These include:

1. Onboarding and Trading: Necessary for contract performance, compliance with legal obligations, and legitimate interests.
2. Communications: For responding to inquiries and providing updates on services.
3. Security and Fraud Prevention: Ensuring group-wide security and fraud prevention.
4. Regulatory Compliance: Compliance with Singapore’s PS Act, Hong Kong’s Securities and Futures Ordinance (SFO), and Australia’s Corporations Act 2001.

International Transfers of Data

As a global group, your personal information may be processed in jurisdictions where B2 Group entities or service providers operate, including Singapore, Hong Kong, and Australia. We ensure compliance with:

• The PDPA for transfers from Singapore.
• The PDPO for cross-border data transfers from Hong Kong.
• The APPs under Australia’s Privacy Act 1988 for overseas transfers.

Safeguarding and Retention of Personal Information

B2 Group implements robust measures to safeguard your personal information against unauthorised access. We retain personal information only as long as necessary to fulfil the purposes outlined in this Privacy Notice or to meet regulatory retention requirements.

Your Rights

Depending on your location, you have the right to:

1. Access, update, or correct your personal information.
2. Withdraw consent for processing (where applicable).
3. Request deletion of your personal information, subject to legal or regulatory requirements.

To exercise your rights:

• Singapore residents: Contact us under the PDPA.
• Hong Kong residents: Contact us under the PDPO.
• Australian residents: Contact us under the Privacy Act 1988 (Cth).

Marketing Communications

If you sign up for updates, we collect your name and email address to send you information about our services and events. You may unsubscribe at any time.

Updates to the Privacy Notice

This Privacy Notice applies uniformly across all B2 Group entities, including Merkle (Hong Kong) Limited and Merkle Australia Pty Ltd. Updates may reflect changes in policies, laws, or regulations. Continued use of our Websites or services after updates constitutes acceptance of the revised terms.

Contact Us

For questions or concerns regarding this Privacy Notice, or to exercise your rights, please contact:

• Email: privacy@btwo.io
• Mailing Address (Group HQ):

Attention: The Privacy Officer

Bsquared Technology Pte Ltd
80 Robinson Rd, #08-01, Singapore 068898

Last updated: 18 June 2025