Updated as at: 20 October 2023

PlatoX International Pte. Ltd. (together with our affiliates referred to as “we” or “us” in this Privacy Policy) operate this software application known as “PlatoX” (“our Platform”). We are committed to respecting and protecting your personal data collected through or in connection with our Platform.

1. Introduction We take our responsibilities under the Singapore Personal Data Protection Act 2012 seriously. We also recognise the importance of the personal data you have entrusted to us and believe that it is our responsibility to properly manage, protect and process your personal data. This Privacy Policy is designed to assist you in understanding how we collect, use, disclose and/or process the personal data you have provided to us, as well as to assist you in making an informed decision before providing us with any of your personal data.If you, at any time, have any queries on this policy or any other queries in relation to how we may manage, protect and/or process your personal data, please do not hesitate to contact our Data Protection Officer (the “DPO”) at the contact details below. This Privacy Policy (together with our Terms of Use for our Platform) sets out the basis on which we use and process any personal data we collect from you as a user of our Platform. By accessing our Platform, or any of our services in general, you hereby agree to be bound by the terms of this Privacy Policy.  In addition, our Platform may, from time to time, contain links to and from the websites of our partner networks, advertisers, affiliates or other third parties.  If you follow a link to any of these third-party sites, please note that these sites are not owned, operated or controlled by us. They are governed by their own privacy policies. Hence, we do not accept any responsibility or liability arising from your access or use of these third-party sites, including but not limited to those relating to their processing of your personal data. You acknowledge and accept that you access and provide your personal data to these third party sites at your own risk. 

   
   

2. Personal data we collect We may collect and process the following types of information from you:

   Contact Information When you establish any contact with us, e.g., registering as a user of our Platform and/or subscribe to our Platform etc., we may collect your name, contact information, including your email address and your contact number, to respond to you;We will also use your contact information to further communicate with you for purposes related to your use of our Platform;We also collect the content of your communication with us, including chat history, any internal records of you relating to your communication with us etc.

   Payment InformationIn addition to Contact Information, we collect and process payment information when you subscribe to our Platform, including but not limited to the following: Payment accounts and/or card information including your name, card number, card expiry date, security verification number, card type information etc. that may be required to facilitate payment;Transaction history including details on the history of payments made to us etc.

   Profile Information Personal information about you when you register and/or subscribe as our user, including your name, gender, age, date of birth, martial status, occupation, nationality, residency, residential address etc.; Personal information about your family members which you provide to us as may be the case; Personal information about your preferences when you indicate in settings or otherwise.Personal information about you that is publicly available on the internet or provided to us by third parties.

   User Content Content and data provided by you which may contain personal information when you use our platform, including your location, activities, interests etc.

   Social Media Information Personal information you provide to us when interacting with our social media sites and accounts;Personal information about you that are available and/or provided by the social media sites.

   Information Generated During Use Log data constituting of information automatically sent by your browser when you use our services, including your IP address, browser type and settings, date and time of your requests and your interactions with our Platform;Usage data which are information we automatically collect about your use of the services on our Platform, e.g. the types of content you view or engage with, the features you use, your actions, time zone, country, date and time of access, user agent and version, computer or mobile device type and connectivity etc.; Device information including device name, operating system, device identifiers and the browser you use, depending on the type of device you use and settings; Cookies which operate and manage our services to enhance your experience. A cookie is information sent by a website you visit to your browser. You can set your browser to accept all cookies, reject all cookies, or notify you each time a cookie is offered, allowing you to decide whether to accept it on each occasion. However, rejecting cookies may prevent you from using certain websites or affect the display or functionality of a website. Please refer to our Cookies Policy below for further information on how we process information collected by Cookies. You may select your Cookies and/ or privacy preferences when interacting with our Platform;Data analytics which help us to analyze how our users are using our Platform in order to enhance users experiences.

   Cookies Policy We use cookies on our Website and our Platform. Cookies are small text containing small amounts of information which are downloaded and may be stored on any of your web browsers or internet enabled devices (e.g. your computer, smartphone or tablet) that can later be read by the server – like a memory for a web page. Cookies are used to collect information about your interaction with our website, including the pages you visit and the duration of your visits. Types of Cookies used by our Website and our Platform include the following:

   (a) Functionality Cookies – they allow you to access features that are fundamental to a service, e.g. choice of language, information relating to your session including content and product optimization, preferences etc.;

   (b) Security Cookies – they are used to authenticate users to ensure that only the actual owner of an account can access that account; and

   (c) Analytics Cookies – they help to collect data and allows services to understand how you interact with a particular service.You have the ability to accept or decline cookies by modifying the setting in your browser. If you would like to do this, please see the help menu of your browser. However, you may not be able to use all the interactive features of our Website if cookies are disabled.

   
   

3. How we use your personal data Generally, we may use, record, systemize, store, update, modify, retrieve, share, disclose, delete or otherwise process your personal data for the following purposes, using manual or automated means for the following purposes: to contact you through the contact information provided by you in order to provide you with the information that you request from us through email, text messages, notifications, alerts and other communications to you; to customize and personalize content, product and services to you;to provide, manage, operate, process and administer our services to you, including services agreed under contract, including content, product, services, technical support and/or responses to you; to assess, process, administer, implement and effect your requests in the use of our services our Platform; to send marketing communications and informational newsletters if you have requested, opted-in to or otherwise agreed to receive; to improve the quality of your experiences and/or our provision of products and services to you, including sending customer surveys and feedback forms to you for completion; to contact you as may from time to time be necessary in connection with your use of our services, and/or our Platform; to keep your account information updated to ensure accuracy of information; to store, host and/or back up (whether for disaster recovery or otherwise) your personal data, whether within or outside Singapore for purposes of providing our services to you and for record-keeping purposes; to conduct research, analysis and development activities (including but not limited to data analytics, surveys and/or profiling) to improve our services, Platform and facilities in order to enhance the services we provide to you, where you have consented to be contacted for such purposes; to comply with legal and regulatory requirements, our company policies and procedures as may be applicable from time to time, including but not limited to responding to legal process, governmental or regulatory bodies, pursuing legal rights and remedies, defending litigation and managing any complaints or claims, investigations, audit and compliance purposes;Any other reasonable purposes related to the above.

   
   

4. Aggregation and/or De-identification of Information We may aggregate or de-identify personal information so that it cannot be used to identify you, and use such information to analyze the effectiveness of our services, improve and enhance our service functionalities, conduct research, and for similar purposes. Additionally, we may periodically analyze general behaviors and characteristics of users of our services and share similar aggregated information with third parties, such as general user statistics, without disclosing or making such aggregated information publicly available. We may collect aggregated information through the services, cookies, and other means described in this Privacy Policy. We will maintain and use de-identified information in an anonymous or de-identified form and will not attempt to re-identify such information unless required by law. As mentioned above, we may use the content you provide to us to improve our services, such as training AI models. If you do not wish for your content to be used for improving the services, you can opt-out by contacting our Data Protection Officer (email: privacy@platox.ai). Please note that in certain cases, this may limit our ability to better address your specific use cases with our services.

   
   

5. Consent Without prejudice to the above, we generally do not collect and process your personal data unless:

   (a) it is provided to us voluntarily by you directly or via a third party who has been duly authorized by you to disclose your personal data to us;

   (b) it is necessary for the performance of our services under the contract; or

   (c) such collection and use of personal data without consent is permitted or required by the PDPA or other laws. We shall seek your consent before collecting any additional personal data and before using your personal data for a purpose which has not been notified to you (except where permitted or authorized by law). If you have given us consent to receive marketing and promotional information through electronic mail, we may from time to time contact you through electronic mail to provide you with marketing, promotional information and updates about our products and services. We may also seek your consent and notify you separately of the purposes of the collection, use and disclosure of your personal data from time to time with respect to particular products and services. Any consent that you have given for marketing purposes is not affected by termination of your policy. If you have requested for us to contact you via telephone calls, SMS/MMS and/or fax using the telephone number(s) to provide you with information about our products and services that you have provided to us, you hereby consent that we may contact you via telephone calls, SMS/MMS and fax using such telephone number(s) to send you marketing messages regarding these products and services.

   
   

6. Disclosure of your personal data Your personal data may be used, disclosed, maintained, accessed, processed and/or transferred to the following third parties, whether sited in Singapore or outside of Singapore, for one or more of the purposes set out above. We may share your personal data with the following:Within our group of companies, e.g. with our headquarters, subsidiaries and affiliate companies; third party service providers which require the processing of your data, for example, third party service providers which have been engaged by us to: (i) to provide and maintain any IT equipment used to store and access your personal data; (ii) to host and maintain our Platform; or (iii) otherwise in connection with the provision of certain services provided to you on or via our Platform; our auditors and legal advisors; public and governmental/regulatory authorities, statutory boards, industry associations; courts and other alternative dispute forums; and any other party to whom you have consented the disclosure of your personal data.We may share your personal information (including information related to your interactions with our services) with government agencies, industry peers, or other third parties if:required by law or if we have a legitimate belief that such action is necessary to comply with legal obligations; to protect and defend our rights or property; if, in our sole discretion, there is a violation of our terms, policies, or laws; to detect or prevent fraud or other illegal activities; to protect the safety of our products, employees, users, the public; and/or to prevent legal liability.In certain circumstances we may provide third parties (whether or not located in Singapore) with aggregate information about our Platform’s users. This may include information about your computer, including where available your IP address, operating system and browser type, for system administration and to report aggregate information to our advertisers. This is statistical data about our users’ browsing actions and patterns and does not identify any individual. We are not responsible for the use (or misuse) of your personal data by any of our partners or third-party service providers.In the event of merger, acquisition, takeover, bankruptcy, liquidation, transfer of the business or assets, we may disclose, share, transfer your information to the prospective acquirer or and/or other relevant third-parties. We will make sure that any such transfer is done in a secure way. Please be rest assured that we never sell or rent your personal data.

   
   

7. Transfer of your personal data outside of Singapore The personal data that we collect from you may be transferred to, used, processed and stored outside of Singapore for one or more of the purposes set out above. By submitting your personal data and/or using our Platform, you agree and consent to such transfer, storing or processing.We have entered into contractual undertakings to ensure that the personal data which we collect from you and transfer to our service providers (whether or not located in Singapore) is adequately protected. We will take reasonable steps to maintain appropriate physical, technical and administrative security to help prevent loss, misuse, unauthorized access, disclosure or modification of your personal information.

   
   

8. Security of your personal data We adopt appropriate organizational safeguards and security measures to protect your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. Our measures include but are not limited to the following:

   (a)The entire system and user information storage is deployed in the highly secured cloud computing services such as Amazon Web Services and Microsoft Azure ;

   (b)All customer data is encrypted at rest with AES-256 and in transit via TLS, which are industrial standard strong cryptographic encryption algorithms;

   (c) Conduct system security audits on a regular basis;d)Implement role-based data access control, to make sure that user data is accessible to authorized persons only.

   
   

9. Retention of your personal data We will only retain your personal data for as long as is needed to fulfil the purposes outlined in this Privacy Policy, or for as long as it is necessary for legal or business purposes, following which time it is either anonymized (where permitted by applicable law), deleted or destroyed. Please note that we may continue to retain log files for internal record, analysis and regulatory purposes even after you close your account.

   
   

10. Accuracy As we rely on your personal data to provide products and services to you, you shall ensure that the information provided by you to us is at all times correct, accurate and complete. You shall update us in a timely manner of all changes to the information provided to us. You may update your personal data via the client manager whom you liaise with, or via email to our Data Protection Officer whose contact details are provided below.

    
    

11. Access and correction of your personal data If you wish to make:

    (a) an access request for access to a copy of the personal data which we hold about you or information about the ways in which we use or disclose your personal data, or

    (b) a correction request to correct or update any of your personal data which we hold about you; you may submit your request via email to our Data Protection Officer (email: privacy@platox.ai).Please note that a reasonable fee may be charged for an access request. If so, we will inform you of the fee before processing your request. We will respond to your request as soon as reasonably possible. In general, our response will be within thirty (30) business days. Should we not be able to respond to your request within thirty (30) days after receiving your request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to your request. If we are unable to provide you with any personal data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the PDPA).

    
    

12. Your rights Subject to the principles of proportionality and any legal or regulatory requirements, you may: request to access to your personal information and information related to its processing; request to delete your personal information from our records; request to amend or update your personal information that is inaccurate, incomplete or out of date; request to transfer your personal to a third party (data portability); request to restrict how we process your information; request to withdraw your consent for us to collect, use, disclose and/or process your personal data for some or all of the purposes listed in this Privacy Policy, by writing to our Data Protection Officer (email: privacy@platox.ai).You also have the right to: object to how we process your personal information; and/ or lodge a complaint with the data protection authority in your jurisdiction.The above rights may vary depending on your location, and individuals within the European Economic Area (EEA), the United Kingdom, and globally may have certain statutory rights related to their personal information.

    
    

13. Changes to this Privacy Policy We may amend or update this policy from time to time. If we believe that the changes are material, we will let you know by doing one (or more) of the following:

    (a) Posting the changes on or through the services;

    (b) Sending you an email or message about the changes; and/ or

    (c) Posting an update in the version notes on our Platform.We encourage you to check back regularly and review any updates.

    
    

14. Data Protection Officer If you want to contact us with specific queries or concerns in relation to this Privacy Policy, or if you have any questions or complaints as to how your personal data is collected, used, disclosed and/or processed by us, please contact our Data Protection Officer at privacy@platox.ai.

    Appendix I – Further Notices on Personal Data Collection in EU and UKIn addition and without prejudice to the generality of the provisions in this Privacy Policy, we set out the specific purposes and legal basis for our collection and processing of your personal data as follows: