Privacy Policy

Introduction

We at AIPOCH PTE. LTD. (hereinafter referred to as “AIPOCH”, “we” or “us”) attach great importance to the protection of your privacy and personal data. This privacy policy (“Privacy Policy”) applies to AIPOCH Services (hereinafter referred to as “Services”), including www.aipoch.com and related services accessed via any platform or device that link to this Privacy Policy. This Privacy Policy explains to you how we collect, use, save, share, transfer or otherwise process your personal data, and your rights regarding the information.

We may from time-to-time update this Privacy Policy to reflect changes in legal, regulatory, operational requirements, our practices, and other factors.

If you are a U.S. resident, please refer to “U.S. STATE SPECIFIC TERMS” section.

If you live in the European Economic Area (“EEA”), please refer to the “EEA Specific Terms” section.

Please check these policies periodically for the latest updates.

If you have any question about this Privacy Policy, please contact: [email protected].

What Information We Collect From You

We collect the following types of information from you when you use the Services.

Personal Data You Provide

Registration and Log-in Information. When you create an account with our Services or log into an existing account (if any), we may ask you to provide your email address, password, as well as your nickname and profile information (if you choose to set them up when logging in).

Communication Information. When you contact us, we may ask you to provide certain personal data including contact information, feedback, inquiries or other information you choose to send.

If you do not create any account or log into your account and only access our website using an AI Agent, we cannot identify you or obtain your personal information.

Personal Data We Automatically Collect

Technical Information. When you use our Services, we may automatically collect personal data including device information, IP address, operating system, system language and browsers you are using. Information collected may vary based on the type of device and its settings.

Usage Data. When you use our Services, we may automatically collect personal data about your use of our Services, including the type of content you elect to interact with, the features you use, the duration and frequency of using our Services.

Combination of Data

We may combine the personal data we receive from and about you, including Personal Data You Provide and Personal Data We Automatically Collect, as well as Personal Data We May Receive from Third Parties to help us tailor our communication to you and to improve our Services and products.

It may be that providing certain personal data to us is a statutory or contractual requirements, a requirement necessary to enter into a contract, or that you are otherwise obliged to provide the data to us. If that is the case, we will inform you thereof separately, and will also explain the possible consequences if you fail to provide such personal data to us. In all other cases, provision of the requested personal data is optional, but it may affect your ability to use certain services or to participate in certain programs or systems, where the information is needed for those purposes.

Use of Your Personal Data

We use information we collect solely to operate, improve, and secure our Services. Specifically, we may use your personal data to:

• Deliver services and manage your account (if any);

• Communicate with you about your account (if any) and our Services;

• Protect the security and integrity of our platform and our users;

• Comply with legal obligations;

• Honor your rights, preferences, and consent choices;

• For any other purposes disclosed at the time the information is collected or to which you consent; and

• As otherwise specifically described in this Privacy Policy.

Sharing Information

Other than consented by you, we commit that we will not share or sell your personal data to any third party.

Depending on where you are and which product you asked for, we may share your personal data with our affiliates so that we can response to your request, provide our Services in a consistent manner or for other purposes in this Privacy Policy. You can obtain the identity and contact details on our affiliates with who we share your personal data by contacting us using the details set out below in the “Contact Us” section.

We will not disclose or transfer your personal data to any non-affiliated third parties, unless:

External Processing

To provide you with a better experience through improving the Services or otherwise where you have consented, we may share the personal data with third-party service providers (eg. site hosting), contractors, and use it consistent with this Privacy Policy.

Legal Reasons

We will share personal data if we have a good-faith belief that access, use, preservation, or disclosure of the information is reasonably necessary to (i) meet any applicable law, regulation, legal process/procedure, lawsuit or enforceable governmental request, (ii) protect and defend our rights or property, (iii) prevent fraud or criminal activity, (iv) respond under urgent circumstances to protect the personal safety of any entity, person or group, or (v) to avoid or mitigate against legal liability.

Business Transfers

If AIPOCH is involved in a reorganization, merger, acquisition, sales of assets or liquidation, we will continue to ensure the confidentiality of your personal data and inform you that your personal data will be transferred or become subject to a different Privacy Policy in advance.

Managing, Reviewing, or Updating Your Information

When using the Services, you can always manage, review and update information by contacting us at [email protected]. In the meanwhile, you are responsible for the truthfulness, accuracy, legality, validity and completeness of the information you provide, and update and maintain your personal data in a timely manner to ensure the truthfulness, accuracy and validity of the information.

Exporting, Removing, or Deleting Your Information

You can request a copy of the information you provided to us if you want to back it up or use it with a service outside of the Services by sending your request to [email protected]. We will help you export the information based on applicable law and your specific request. You can also remove or delete information you provided. In some cases, we retain data for limited periods when it needs to be kept for legitimate business or legal purposes or to be protected from accidental or malicious deletion, there may be delays between when you delete something and when copies are deleted from our active and backup systems.

Protecting Information

Security Measures

We use a variety of organizational and technical security measures, including encryption and authentication tools, to protect your personal data. We use secure servers when you use our Services. Despite our efforts, we cannot guarantee that unauthorized access or use will never occur and we cannot ensure or warrant the security of your data. It is important that you take steps to keep your data safe and secure.

Data Transfers

We may maintain servers around the world and your information may be processed on servers located outside of the country where you live.

Regardless of where your information is processed, we apply the same protections described in this policy. We will also keep this Privacy Policy in compliance with significant legal frameworks relating to the transfer of data. If we receive your complaints about data transfers, we will cooperate with appropriate regulatory authorities when we cannot directly resolve it. Some of our recipients of your personal data are located in countries that may not – by law – provide the same level of data protection as you are used to in certain countries. If that is the case, we will ensure that adequate safeguards are in place to duly protect your personal data and we guarantee that we are able to and have mechanisms in place to respect the level of data protection required by EU data protection laws and that we shall refrain from processing personal data in the event of a breach of the concluded safeguarding measures or if we (or our recipients) are no longer able to honour them.

For transfers of personal data from EEA to a third country, please refer to our “EEA SPECIFIC TERMS” section below.

Children's Policy

We do not collect or solicit personal data from children under 18. If you are under the age of 18, you must obtain prior consent from your parents/legal guardians before using our Services. If we are aware that a child under 18 has provided us with personal data without prior consent, we will delete such information from our servers. If you have reason to believe that a child under the age of 18 has provided Personal Data to us through the Services, please contact us via [email protected].

Application

This Privacy Policy applies to all the Services provided by AIPOCH.

This Privacy Policy does not apply to personal data that we process on behalf of customers of our business offerings, such as our API (if any). Our use of that data is governed by our Terms of Service covering access to and use of those offerings.

To better enrich your experience, our Service may contain links to other websites not operated or controlled by AIPOCH (including AIPOCH affiliates), including social media services (collectively, “Third-Party Services”). You can choose whether to access such content or links, or whether to use the third party’s products or services. However, we do not have control over the products or services provided by third parties. We cannot control any of your personal data held by third parties. By providing these links we do not imply that we endorse or have reviewed these Third-Party Services. The personal data protection issues in connection with your use of any Third-Party Services are not governed by this Privacy Policy. We strongly advise you to review the privacy policy of every site you visit.

If provisions from this Privacy Policy are in conflict with the law, they will be replaced by provisions of the same purport that reflects the original intention of the provision, all this to the extent legally permissible. In that case, the remaining provisions remain applicable unchanged.

Your Rights Relating to Your Personal Data

You are entitled to the following rights:

• right of access to your personal data;

• right to data portability (i.e., you have the right to receive your personal data in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller);

• right to correction if your personal data is not complete or accurate;

• right to deletion or restriction of your personal data, as permitted by law;

• right to object (i.e., objecting to our processing of your personal data) (e.g., in case we process your data for direct marketing purposes), as permitted by law;

• right to withdraw your consent where we have asked for your consent at any time with future effect and without affecting the lawfulness of processing of your personal data based on the consent you provided before you withdrew it.

The exercise of the above mentioned rights is free of charge and can be carried out by phone or by e-mail via the contact details displayed in the “Contact Us” section. If requests are manifestly unfounded or excessive, in particular because of the repetitive character, we will either charge you a reasonable fee or refuse to comply with the request. We may request specific information from you to help us confirm your identity before we comply with a request from you concerning one of your rights.

We will provide you with information about the follow-up to the request without undue delay and in principle within one month of receipt of the request. Depending on the complexity of the request and on the number of requests, this period can be extended by another two months. We will notify you of such an extension within one month of receipt of the request. The applicable privacy legislation may allow or require us to refuse your request. If we cannot comply with your request, we will inform you of the reasons why, subject to any legal or regulatory restrictions.

These rights are not absolute, they may be limited in some situations. For example, where we can demonstrate that we have a legal requirement to process your data or if making the information available to you would reveal personal data about another person or if we are legally prevented from disclosing such information. In some instances, this may mean that we are able to retain data even if you withdraw your consent.

We hope that we can satisfy any queries you may have about the way we process your data. In the event you still have unresolved concerns, you also have the right to lodge a complaint with a supervisory authority, in particular to the data protection authority in the country of your habitual residence or place of work.

Marketing

If we are legally required to do so, we will seek your prior consent before providing you with promotional materials or information. You may withdraw your consent at any time (this will not affect the processing of your personal information undertaken until the withdrawal). If you want to stop receiving promotional materials, etc., you can do so at any time by communicating with us.

Data Retention

We will retain your personal data for as long as is necessary to carry out the purposes set out herein. We will also retain your personal data deemed necessary to comply with legal obligations, settle disputes, and enforce agreements.

Where applicable, we will delete your personal data upon your request. We are entitled at all times to delete your personal data without notice. In such case, we owe no compensation to you as result of deletion of the personal data.

If you wish to obtain further information about the retention periods as applied to your personal data, you may contact us via the contact details displayed in the “Contact Us” section.

Contact Us

The data controller for your personal data will be AIPOCH PTE. LTD.

If you have any questions about this Privacy Policy or wish to contact us for any reason in relation to our personal data processing, please contact us at [email protected].

EEA Specific Terms

In addition to our Privacy Policy presented above, the following terms will apply to the processing of Personal Data of data subjects in the European Economic Area (“EEA”).

Legal Basis of GDPR for Processing Your Personal Data

We process this personal data for the following purposes and based on the following legal grounds:

• On the basis of our legitimate interests for example when required by us to conduct our business, in particular:

  • we will use your information to identify you and provide you with a consistent service experience throughout our Services;

  • we will use your information to respond to any comments or complaints you may send us;

  • we monitor use of the Services, and use your information to help us monitor, improve and develop our Services;

  • we use information you provide to personalise our Services for you and assist you with your purchase;

  • we will use data in connection with legal claims, compliance, regulatory and investigative purposes as necessary (including disclosure of such information in connection with legal process or litigation); and

  • we will notify you about changes to our Services, where applicable.

• On the basis of your consent:

  • providing you with information relating to AIPOCH or promotional details about Services that may be of interest to you, as well as marketing mailings (electronic or otherwise) or other communications; and

  • on other occasions where we ask you for consent, we will use the data for the purpose which we explain at that time.

• As this might be necessary for compliance with a legal obligation that is applicable to us, such as:

  • in response to requests by government or law enforcement authorities conducting an investigation, or to comply with the requirements imposed by applicable law or any court order.

Purpose of processing	Type of Personal Data processed	Legal Basis
To provide and maintain Services	Account Information if any, Usage Data	Necessary to perform a contract with you

Aggregated Personal Data refers to data that has been carefully de-identified and anonymized to ensure that it cannot be linked back to any specific individual. We may aggregate Personal Data or collect aggregated data from our users, which is essential for enhancing the functionality and performance of our Services. This enables us to analyze user behavior, improve our product's features, develop new products and services, conduct research, and other similar purposes. We use this information to gain insights into overall usage patterns and trends, helping us make data-driven decisions to enhance the user experience. In some cases, we may also choose to share or publish this aggregated information.

In addition, from time to time, we may share or publish aggregated information like general user statistics with third parties. We collect this information through the Services and through other means described in this Privacy Policy. We will maintain and use de-identified information in anonymous or de-identified form, and we will not attempt to re-identify the information, unless required by law.

We are committed to adhering to relevant privacy and data protection regulations and our Privacy Policy in all our data aggregation activities. If you have any questions or concerns regarding data aggregation, please read our full Privacy Policy for more details on how we handle and safeguard your information. Your privacy and security are our top priorities.

Transfer of Personal Data Outside of the EEA

We may transfer to, and store the data we collect about you, in countries other than the country in which the data was originally collected, including the United States, Canada or other jurisdiction outside the EEA. Those countries may not have equivalent data protection laws as the country in which you provided the data. When we transfer your personal data to other countries, we will protect the data as described in this Privacy Policy and comply with applicable legal requirements providing adequate protection.

A copy of the relevant mechanism can be obtained for your review on request via the contact details displayed in the “Contact Us” section.

U.S. State Specific Terms

In addition to our Privacy Policy presented above, the following terms will apply to the processing of Personal Data of data subjects in the United States (“U.S.”).

• You may have other choices under applicable state laws. Depending on where you live, you may be entitled to certain additional rights, as described below. We only honor these rights where required by law. If you wish to exercise these rights under applicable state privacy laws, you can contact us at [email protected]. We currently do not "sell" or "share" your personal information for targeted or cross-contextual behavioral advertising purposes, collect any "sensitive" personal information, or engage in any profiling or automated decision-making.

• If we deny your privacy request, you may appeal that decision by emailing us at [email protected]. We will respond to your appeal within a reasonable period of time, as required by law. If, after we have processed your appeal, you remain unsatisfied with our response, you may have the right to file a complaint with your state attorney general.

• If you are an authorized agent (including an AI agent) submitting a privacy rights request on behalf of an individual, you must provide a copy of a lawful power of attorney or written authorization from the requester (along with proof of identity). If you submit a request as an authorized agent, you may receive additional instructions. Depending on the nature of the request, we may contact you or the individual on whose behalf you have submitted the privacy rights request(s).