DEEN PRIVACY NOTICE

Effective Date: [1 February 2023]

About this Notice

Thank you for downloading Deen.

Your privacy and the security of your personal data is, and will always be, very

important to us. So, we want to transparently explain how and why we gather, store,

share and use your personal data.

This Notice sets out the details of your personal data relationship with Pulse

Ecosystems Pte Ltd, a Singapore company (“PulseCo”) and its affiliates. This Notice

applies to all services made available to you through Deen App (the “Deen Services”).

This Notice tells you:

 Who we are;

 What information we collect and why;

 Where we get your information from and who we share it with;

 What you can ask us to do; and

 How to contact us if you need to.

From time to time, we may develop new or offer additional services. If the introduction

of these new or additional services results in any material change to the way we collect

or process your personal data we will provide you with more information or additional

terms or policies. Unless stated otherwise, when we introduce these new or additional

services, they will be subject to this Notice.

The terms governing your use of Deen App are defined in our Deen App Terms and

Conditions.

Who are we?

Your Data Controllers

PulseCo and any Prudential takaful entity (“Pru Local Entity”) operating in your

territory (see Appendix 2) are separate data controllers (in some territories, this is

known as a data user or data operator) of the personal data collected or gathered

through your use of the Deen Services, although the Pru Local Entity only processes

such data as is necessary to carry out the purposes described in the “Why do we

need your personal data?” section below.

If you purchase any takaful products or register to utilise any takaful services provided

by Pru Local Entity on Deen, the Pru Local Entity will collect and process your data for

such purposes in accordance with their own terms and conditions and privacy notices.

The Pru Local Entity does not gather, collect or process any Health Data (as defined

below) from your use of Deen. If you are a customer of the Pru Local Entity, the Pru

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Local Entity may collect health data as part of the underwriting process to provide you

with an takaful product or service in accordance with their own privacy notices.

For the data controllers' contact information, please see the "Updating your details

and contacting us" section below.

Deen Partners

Deen Partners are third party partners who contract with you directly under their own

terms and conditions to provide services in their own name – these may include sellers

who sell goods and services on the Deen Marketplace, Deen prayer notification

services, Qibla direction services, other Deen content creators, the Health

Assessment and Symptom Checker services, telemedicine Services, and other

services that we may add to the Deen App from time to time.

Deen Partners collect, gather and process information arising from your use of those

services as independent data controllers. Deen Partners will process your personal

information in accordance with their privacy notices which are made available to you

prior to you using the relevant service.

PulseCo is also an independent data controller in relation to such data collected or

generated from your use of the Deen Partner services and PulseCo will process such

data in accordance with this Privacy Notice.

What data do we collect and where do we collect it from?

Providing your personal data is voluntary. However, if you do not provide your personal

data, we may be unable to register you for the Deen App or provide the Deen Services

or your use of or access to the Deen App may be otherwise limited.

These are the data and information we collect or gather about you:

(a) Personal data you provide:



Personal and contact details such as, your name, address, telephone number,

email address, other third party login information (e.g. social media logins)

where you choose to use them;



Biometric information (including facial images) where you choose to use any

aspect of the Deen Services that may require them;

Your gender, date of birth and/or age (if required for use of a service, or with

your consent);

Your identification number, passport number, other Government-issued

identification document details, address proof, and/or other information that

can be used to identify you (if required for use of a service or to enable us to

fulfil our legal obligations);



Records of any communication you have with us or any Deen Partner

(including any our content creators conducting any virtual events), including

any AI personal assistant or chatbot;

Details you provide when you elect to participate in any activities relating to

the Deen Services;

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

Recordings of events or activities which you may participate in on the Deen

App which may reveal your name and image, as displayed during the activity

or event;



Details requested by a Deen Partner as part of the services they provide;

Details related to or which reveals your health, well-being, or medical

condition (collectively, "Health Data") that you have provided or has been

generated as a result of usage of a Deen Service (including where you have

synchronised or uploaded information from a device, app or system with the

Deen Services). Where required by applicable laws and regulations, any

processing of Health Data will be based on your explicit consent;

Details related to your membership, subscriptions, plans, and any purchase

or transaction on the Deen App or as part of the Deen Services;

Details about your messages (including any content or materials you share)

via any Deen chat, voice or video call functions;

Details about your connections including your contact list, and the groups you

belong to;

Content that you create, post, upload, share or communicate when using any

Deen Services, including any chats, media, photos, comments, and any other

materials you choose to provide;



Details related to your preferences, interests and favourite activities;

Details related to e-wallet services, including bank account, credit and debit

card details, and billing and delivery details;



Details related torewards, loyalty or privileges programmes; and

Data from any responses you provide to surveys.

(b) Personal data we collect from other sources:



Third party login information (e.g. social media logins) from the provider of

such logins, where you choose to use them;



Data (including Health Data) from Deen Partners;

Data from other third party commercial partners of PulseCo or a Pru Local

Entity or other organisations who have the appropriate legal basis for sharing

such data with PulseCo;



Data from service providers who share personal data to enable us to fulfil our

legal obligations.

(c) Personal data we collect automatically when you use Deen Services:



Details relating to your device and use of the Deen Services;

Data from challenges or activities within Deen Services where you have

allowed it;



Data that is generated through your actions when using the Deen Services,

including transaction data related to purchases and transactions;

Data regarding all your other use of and interactions with the Deen Services,

behavioural information, your advertising preferences, your purchasing

preferences, and your communications with us, a Pru Local Entity or other

members of the Prudential Group, or a Deen Partner;

Any chat, voice or video call history;



Location-related data;

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

Mobile device and connection information, information on data traffic, your IP

address, access times, browsing history data, language settings, information

connected with your third party login and/or weblog information etc.

(d) Personal data we collect through cookies or other similar technologies.

These items may include the following, for example (as may be applicable):



Access time, frequency and duration of visits / use of the Deen App and Deen

Services;

Data about your activities and interactions with our advertising partners (if

any);

The model or device type used by you, operating system / version, browser

type and settings, device ID, advertisement ID (if any), and other cookie-

related data;



Location-related data.

(e) Health Data

The Pru Local Entity is not a data controller with respect to your Health Data. PulseCo

and where applicable, the relevant Deen Partner, are separate data controllers of your

Health Data.

To the extent required by applicable laws, PulseCo will ask for your specific consent

to process the Health Data. PulseCo obtains this consent separately when you take

actions leading to collection, gathering, use or disclosure of Health Data. You can

withdraw your consent at any time by contacting the PulseCo Privacy Officer – see

"Updating your details and contacting us" section below.

In addition, you always have the right to ask us to delete your Health Data regardless

of whether local laws provide you with this right, unless we have a legal obligation or

need to retain such data.

(f) Cookies, Beacons

When you use the Deen Services, we may use cookies and similar technologies to

provide you with a better, faster and safer user experience or to show you personalized

advertising. Cookies are small text files that are automatically created by your browser

and stored on your device when you use the Deen Services.

You are free to disable the use of cookies and similar technologies if this is supported

by your device. You can manage your cookie settings in device settings.

If you decide not to have your personal data processed by us for advertising purposes

via cookies (and similar technologies), this does not mean that we will not show you

advertisements. It simply means that these advertisements will not be personalized

for you using first-party or third-party cookies, web beacons, or similar technologies.

Why do we need your personal data?

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PulseCo:



To process your registration and provide you with features, functionalities and

services within the Deen Services;



To facilitate purchases or transactions;

To process requests made by you through the Deen Services;

To administer rewards, loyalty or privileges programmes;

For our processing in connection with our internal business purposes, the

improvement and development of the Deen Services, and the research and

development of future data analytics, technology, products, services,

functionalities and features (including AI powered products, features and

services);



To personalise, customise and tailor your use and experience of the Deen

Services including to provide personalised and customised promotions, product

and service suggestions, and tips;

We may also use your name and contact details to send personalised

messages, promotional materials and tailored content to you about Deen

Services, a Pru Local Entity’s products and services and/or any Deen Partner

or third party products and services (related to health, wellness, nutrition,

lifestyle, finance and/or takaful). We may also share your name and contact

details with other PulseCo affiliates to enable them to market the same types

of products and services. We use and share your name and contact details for

marketing purposes only with your consent (we can't use or share the data

otherwise);



Where permitted, and with your specific consent where required by applicable

laws, we may use your Health Data to personalise and tailor our promotions,

personalised and customised messages and suggestions to you;

To assist you in monitoring and improving your health management and

general wellness, which may include providing tailored nudges and suggestions

to you;



To enable you to register with a Deen Partner, should you choose to do so;

To help you manage and associate you with relevant communities lists and

broadcast lists;



To process and communicate with you about your participation in any activities,

events, promotions, focus groups, research studies, contests, fulfilment of

rewards, polls, surveys, productions or similar activities relating to the Deen

Services;



To enable you to view and playback recordings of activities or events that you

or other users may have participated in on the Deen App;

To enable you to share content and comments, and interact with other users of

Deen Services;

As we believe to be reasonably necessary or appropriate to monitor, enforce or

verify your compliance with the Deen App Terms and Conditions and for

protecting PulseCo’s legal and reputational interests;



To communicate with you and provide the relevant customer support and

service to you;

To facilitate the provision of updates, product support, and other services to you

related to the Deen App;



To notify you about changes to the Deen Services;

For any internal administrative and record retention purposes;

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

For purposes of detection, investigation, prevention and addressing fraud,

crime, other illegal activity, or security or technical issues;



To protect the rights, property, and the safety of Deen App users;

To comply with any obligations under applicable law, including but not limited

to anti-money laundering and Know-Your-Client obligations; and

To connect your Deen identity with any existing customer account at the

respective Pru Local Entity and the agents that serve you.



Pru Local Entity:



Where you have provided your consent, we intend to use your name and

contact details to send special promotions and/or materials regarding

personalised or customised products and services and/or products and

services from a Pru Local Entity’s partners (related to health, wellness, nutrition,

lifestyle, finance and/or takaful), and we use your name and contact details for

marketing purposes only with your consent (we can't use the data otherwise);

To personalise, customise and tailor your use and experience of the Pru Local

Entity’s products and offerings, including to provide personalised and

customised promotions, product and service suggestions such as offerings

combining takaful products and other Deen Services, and tips;



For the improvement and development of new financial services or takaful

products and services; and

To perform data analysis and to conduct profiling such as marketing profiling.

What is our justification for using your data?

PulseCo and Pru Local Entity rely on one or more legal bases for processing your

personal data, including:



When the processing is necessary to perform a contract with you and to provide

you with the services you require in accordance with the Deen App Terms and

Conditions;

The legitimate interests pursued by us or by a third party to whom the personal

data is disclosed (except where such interests are overridden by your fundamental

rights and freedoms);

Where you have given your consent, to the extent required by applicable laws and

regulations. For example, applicable laws and regulations may require your

consent for processing of Health Data, processing that involves automated

decision-making or profiling, and/or processing of personal data for marketing and

promotional purposes;



The processing is necessary for compliance with a legal obligation to which

PulseCo is subject;

Other lawful criteria recognized under applicable law.

Who do we share your information with?

Deen App profile information

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The following personal data will be publicly available on the Deen App: your name

and/or username, profile picture, and any other information on your profile page.

Personal data you may choose to share

The following personal data will only be shared with other Deen App users as

follows:



You share your messages and other content with the Deen App users as part of

using Deen Services, including any virtual event functionality;

You permit Deen Services to share certain particular details or data to any Deen

Partner in order for the Deen Partner to provide services to you or to enhance

their ability to provide their services to you. This may include your Health Data

being provided to other Deen Partners providing health related services to you;

Where you participate in a virtual or live event / activity on the Deen App, the

recordings of such event / activity, which may reveal your name and image as

you may have disclosed during the event / activity; and



Where you participate in a challenge, your personal data related to that challenge

will visible to all participants in the same challenge.

Who we may share your personal data with

We may share your personal data with the following transferees to the extent

necessary for them to assist us with fulfilling the above purposes or in accordance with

any consent you have given: service providers, accountants, auditors, IT service and

platform providers, intermediaries, reinsurers, retakaful operators, investment

managers, agents, pension trustees (and other stakeholders), scheme advisors,

introducers, selected third party financial, insurance, takaful and wealth management

product providers, advertising providers and legal advisers.

We share your personal data when we in good faith believe it is necessary for us to

do so in order to comply with a legal obligation under applicable law, or respond to

valid legal process, such as a search warrant, a court order, or a subpoena. We also

share your personal data where we in good faith believe that it is necessary for the

purpose of our own, or a third party’s legitimate interest relating to national security,

law enforcement, litigation, criminal investigation, protecting the safety of any person,

or to prevent death or imminent bodily harm.

We may share your personal data with other PulseCo affiliates where it is needed to

carry out our daily business operations and to enable us to maintain and provide the

Deen Services to you, as well as for marketing purposes as mentioned in the section

"Why do we need your personal data?" above.

We may share your personal data with an actual or proposed purchaser or transferee

if we are involved in a merger, acquisition, re-organisation, sale of assets, or other

similar corporate transaction, including for the purpose of any due diligence exercise.

Where may we process your personal data?

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We may process your personal data in a territory other than the one you are resident

in. To the extent we transfer your personal data, we will use appropriate safeguards

and comply with the laws of the territory from which your personal data is transferred.

How do we keep your data safe?



We have detailed security policies and standards which allow us to effectively

manage keeping your data safe;



We use encryption when your data is stored and when it is sent across networks;

We work closely with our partners to ensure that they provide the same level of

protection to data they hold on their own or process on our behalf, including through

detailed due diligence and Privacy Impact Assessments;



We manage and control who has access to your information both within and

outside the Deen App through access control and identification techniques; and

We have detailed plans for any unforeseen events including reporting (where

required to do so by applicable laws and regulations) any breaches that may involve

your data.

How long do we keep your data for?

We keep your personal data only as long as necessary to provide you with the Deen

Services and for legitimate and essential business purposes, such as maintaining the

performance of the Deen Services, making data-driven business decisions about new

services and products, complying with our legal obligations, and resolving disputes.

We maintain your personal data for the following periods:

 For as long as it is required for the purposes;

 For as long as may be required by applicable laws and regulations; or

 For legitimate business purposes of PulseCo and where relevant, the Pru Local

Entity.

Your personal data will be deleted or anonymised after the relevant retention periods

have expired.

What can you do?



Where processing is based on consent, you can withdraw your consent for our

collection, use or disclosure of your personal data by contacting us as set out

in this Privacy Notice. Even if you withdraw your consent we may still collect,

store, use or disclose your personal data if applicable laws and regulations

require or authorize us to do so;



You can change your preferences, where you have given specific consent. This

may vary depending on the territory you are resident in and may include, but is

not limited to, objecting to receiving marketing and other promotional materials,

automated decision making, using sensitive information, and overseas transfer.

To make changes you can use the privacy feature within the Deen Services or

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in the manner indicated in the "Updating your details and contacting us"

section;



You may also (where local laws provide you with the rights):

o

ask us for a copy of and/or access to information that we hold about you

in relation to the Deen Services (you will need to request any information

held by Deen Partners where they act as a data controller directly from

them);

o

ask us to amend any data that is incorrect, incomplete, outdated and/or

misleading except in such cases where such a request is unreasonable;

ask us to delete your data (unless we are legally allowed or required to

maintain certain personal data);

o

ask us to restrict our use of your data; and

ask that we provide you with a copy of certain personal data in a form

that can be shared with others, and where technically feasible, to

transmit such personal data to another data controller.



You may also (where local laws provide you with the rights) lodge a complaint

with the data privacy regulator.

Children's information

Deen App is not targeted at persons under the age of 18. We do not knowingly

collect personal data from persons under the age of 18. While certain Deen

Services may ask parents to provide data of their children where required for the

service, we do not knowingly collect personal data about persons under the age

of 18 without a parent/legal guardian's consent (please see the “Acting on

someone else’s behalf?” section below). If you believe that we have collected

personal data from a person under the age of 18, or we have collected personal

data about a person under the age of 18 without a parent/legal guardian's

consent, please inform us via the details in the "Updating your details and

contacting us" section below.

Acting on someone else’s behalf?

Deen App is primarily designed to be used by yourself only; however there may

be limited circumstances where you may give us personal data about others. If

you give us personal data about another person (or persons), we’ll take that to

mean they have appointed and authorised you to act on their behalf. This

includes providing consent to:



our processing of their personal data (including any Health Data) as mentioned

above; and

you receiving this Privacy Notice on their behalf.

If you give us personal data about a person under the age of 18, you must either

be the person's parent/legal guardian or have the consent of the person's

parent/legal guardian before doing so.

Updating your details and contacting us

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Please update your details as directed on the Deen App if any details you have

provided to us in your registration change (e.g., if you change your e-mail

address, telephone number). Please use the details below to contact PulseCo

with any requests to do with your data.

Title / Designation:

Deen Helpdesk

Postal Address:

Attention: Privacy Officer, Pulse

Ecosystems Pte Ltd, 7 Straits View,

#06-01 Marina One East Tower,

Singapore 018936

Tel:

+65 6704 7216

Email:

privacy@wedopulse.com

We will respond to and action all requests within the time limits required by

applicable law and regulation. We may refuse to action a request to correct or

provide access to personal data where the law allows or requires us to do so. For

security reasons, we may take steps to authenticate the identity of the requesting

party before responding to a request.

In those countries where we are required to do so by law, we have appointed

data protection officers to oversee the protection of your personal data. If you

have any questions about this Privacy Notice or about data protection for the

Deen Services or have complaints regarding this Privacy Notice or our handling

of personal data, you can contact PulseCo through the Deen Helpdesk above. To

contact a Pru Local Entity, please refer to the contact information on their own

privacy notice which you may access via the websites indicated in Appendix 2.

About this notice

Language: To the extent there is any inconsistency between the English version

and an official local translation of this Privacy Notice, the English version shall

prevail.

Definitions: Capitalised terms not defined in this Privacy Notice shall have the

meaning given to them in the Deen App Terms and Conditions.

"Prudential Group" means Prudential Plc and any affiliates of Prudential Plc.

Amendments: We change this Privacy Notice from time to time. We will not

reduce your rights under this Privacy Notice without informing you. We always

indicate the date the last changes were published.

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Appendix 1 - Territory Specific Information

If you are a user in one of the following countries, the following information is relevant to you.

Indonesia

In the Children’s Information and Acting on someone Else’s Behalf? sections, all references

to ‘age of 18’ shall be replaced with ‘age of 21 or person under guardianship’.

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Appendix 2 – Details of Prudential takaful entities in your territory

Territory

Indonesia

Malaysia

Prudential insurance or wealth

management entity

Website

PT Prudential Sharia Life Assurance

https://www.prudential.co.id/id/footer/privacy-

policy/

Prudential BSN Takaful Berhad

https://www.prubsn.com.my/en/

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