Personal Data Protectionand Privacy Policy (Version: April 2018)

Aquaculture Technologies Asia Ltd ("ATA"or "we" and "us" and "our" shall be construedaccordingly) respect the privacy of all individuals, and we ensure that ouremployees handle personal information in accordance with the strictest standardof security and confidentiality. We pledge to comply with the requirements ofthe Personal Data (Privacy) Ordinance (Cap. 486) ("Ordinance") inHong Kong. This Personal Data Protection and Privacy Policy applies to allproducts and services provided by us including but not limited to the website,app or such other program or software named as ATA NETshop ("ATANETshop") and sets out how we may collect, use and disclose your personalinformation. We protect and handle your personal information in accordance withthese terms and conditions.

1. Collection of Personal Data

1.1 Your privacy is important to us and we donot collect excessive personal information from you for the purpose ofproviding this service and protect the personal information ("ATA NETshopMembership Account") provided by you.

1.2 When you use your ATA NETshop MembershipAccount, including when you register as a ATA NETshop member, we may ask you toprovide personal information, including without limitation to name, date ofbirth, gender, phone number, email address, contact/delivery address, etc.(collectively "Personal Data"). Please note that it is mandatory foryou to provide certain fields of Personal Data as specified at the time ofcollection. Or else, we may not be able to provide you with our products and/orservices (including registering you as ATA NETshop member).

2. Use and Transfer of Personal Date

2.1 We may collect certain your personalInformation, including contact details, and the record about the services orsupport that you have requested. Any Personal Data provided to us means youauthorise us to collect, retain and use Personal Data about you for thefollowing purposes:

(a) operating and/or managing your ATANETshop Membership Account; (b) verifying your identity; (c) providing you withrewards, promotions, vouchers or services under ATA NETshop; (d) updating youfor the latest service update or notice; (e) providing you with customerservices and responding to your queries; (f) performing statistics and analysisin order to develop or improve our services; (g) for marketing and promotionalpurposes; and (h) making such disclosures as may be required for any of theabove purposes or as required by law or in respect of any feedback or claimsmade by you.

2.2 You further agree that we may discloseand transfer (in Hong Kong or overseas) your Personal Data to third partyservice providers engaged by us to provide

(a) data entry, (b) customer databasemanagement, (c) customer contact (and service providers may contact youregarding promotions, product rewards, vouchers, redemptions and customerservices), and (d) secure data disposal services ("Third Party ServiceProviders"). The Third Party Service Providers are under a duty ofconfidentiality to us and are only permitted to use your Personal Data inconnection with the purposes specified in 2.1 above, but not for their ownpurposes (including direct marketing).

2.3 When necessary we may also disclose andtransfer (in Hong Kong or overseas) your Personal Data to our professionaladvisers, law enforcement agencies, insurers, government and regulatory andother organizations for purposes specified in 2.1(h) above.

2.4 We may only use your name, phone number,email address and contact/delivery address with your consent or with yourindication of no objection to provide marketing materials to you relating to ATANETshop and/or your ATA NETshop Membership Account and goods/services which maybe redeemed under ATA NETshop and/or your ATA NETshop Membership Account, includinggoods and services provided by all ATA related companies and ATA 'smerchants/partners.

2.5 We may share unidentified aggregate datawith third parties for various purposes (including marketing and advertising),and may use this data in order to better understand your needs and to improveand adapt to our products and services.

2.6 Any Personal Data supplied by you will beretained by us and will be accessible by our employees, the Third Party ServiceProviders and third parties referred to in 2.3 above, for or in relation to anyof the purposes stated in 2.1 herein.

2.7 We may permit individuals who are staffmembers of ATA ("Staff Members") to use ATA NETshop (including butnot limited to registering as a ATA NETshop member and using the variousfunctions provided by ATA NETshop) but such Staff Members must at all timescomply with all applicable codes of conduct and/or other relevant companypolicies of us and/or their relevant employer(s) when using ATA NETshop.Notwithstanding anything stated herein, in the event it is found that a StaffMember misuses ATA NETshop in his/her capacity as a Staff Member (including butnot limited to using any confidential or other similar insider information toobtain an unfair advantage from any promotions or offers offered by ATANETshop), we will report the said matter to the relevant authorities forinvestigation and/or disciplinary purposes.

3. Safety of Personal Data

No system is impenetrable and no informationprovided over websites, apps or the internet can be guaranteed to be completelysecured. Thus, we cannot guarantee the security of any information that youtransmit to us or receive from us over ATA NETshop or the internet. Allreasonable efforts are made to ensure that any Personal Data held by us isstored in a secure and safe place, and accessed only by our authorisedemployees or authorised Third Party Service Providers.

4. Use by Third Parties

ATA NETshop may link to other apps, websitesand/or webpages which are operated by third parties. We have no control overthe content of the linked apps, websites and/or webpages or the way in whichthe operators of those apps, websites and/or webpages deal with your PersonalData. You should review the Personal Data Protection and Privacy Policy forthose third party apps, website and/or webpages to understand the ways in whichyour Personal Data may be used by those third parties.

5. Access or Amend Personal Data

5.1 Under the Ordinance, you have the rightof access to Personal Data held by us about you and to request correction ofyour Personal Data.

5.2 If you have any questions regarding thisPersonal Data Protection and Privacy Policy or if you wish to access or correctyour Personal Data, you may send your request in writing to the followingaddress:

ATA NETshop

Aquaculture Technologies Asia Ltd

Rm 1103 B, 11/F, Nan Dao Commercial Building359-361 Queen's Rd C
Sheung Wan, Hong Kong

Email: oasis@aquatechasia.hk

5.3 In accordance with the Ordinance, wereserve the right to charge you a reasonable fee for the processing of any dataaccess or correction request.

6. Updates

We may amend or update this Personal DataProtection and Privacy Policy from time to time without prior notice and yourPersonal Data collected shall be governed by our latest Personal DataProtection and Privacy Policy,    whichshall be available in this webpage.

7. Versions

In case of discrepancies between the Englishand Chinese versions in respect of all or any part of this policy, the Englishversion shall prevail.