1.1 Welcome to the SeaTalk platform run by SeaTalk Private Limited and its affiliates (individually and collectively, "SeaTalk", "we", "us" or "our"). SeaTalk takes its responsibilities under applicable privacy laws and regulations ("Privacy Laws") seriously and is committed to respecting the privacy rights and concerns of all Users of our SeaTalk platform (the "Platform") (we refer to the Platform and the services we provide as described on our Platform collectively as the "Services"). We recognize 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 (“Privacy Policy” or “Policy”) is designed to assist you in understanding how we collect, use, disclose and/or process the personal data you have provided to us and/or we possess about you, whether now or in the future, as well as to assist you in making an informed decision before providing us with any of your personal data.

1.2 "Personal Data" or "personal data" means data, whether true or not, about an individual who can be identified from that data, or from that data and other information to which an organisation has or is likely to have access. Common examples of personal data could include name, identification number and contact information

1.3 By using the Services, registering for an account with us, visiting our Platform, or accessing the Services, you acknowledge and agree that you accept the practices, requirements, and/or policies outlined in this Privacy Policy, and you hereby consent to us collecting, using, disclosing and/or processing your personal data as described herein. IF YOU DO NOT CONSENT TO THE PROCESSING OF YOUR PERSONAL DATA AS DESCRIBED IN THIS PRIVACY POLICY, PLEASE DO NOT USE OUR SERVICES OR ACCESS OUR PLATFORM. If we change our Privacy Policy, we will post those changes or the amended Privacy Policy on our Platform. We reserve the right to amend this Privacy Policy at any time.

2.1 We will/may collect personal data about you:

- when you register and/or use our Services or Platform, or open an account with us;

- when you submit any form, including, but not limited to, application forms or other forms relating to any of our products and services, whether online or by way of a physical form;

- when you enter into any agreement or provide other documentation or information in respect of your interactions with us, or when you use our products and services;

- when you interact with us, such as via telephone calls (which may be recorded), letters, fax, face-to-face meetings, social media platforms and emails;

- when you use our electronic services, or interact with us via our application or use services on our Platform. This includes, without limitation, through cookies which we may deploy when you interact with our application or website;

- when you grant permissions on your device to share information with Platform;

- when you provide us with feedback or respond to surveys; or

- when you submit your personal data to us for any other reason.

The above does not purport to be exhaustive and sets out some common instances of when personal data about you may be collected.

2.2. We may collect personal data about you from you, our affiliates, third parties, and from other sources, including publicly available sources of data.

2.3. In some situations, you may provide us with the personal data of other individuals such as your representatives, employees, family members, friends or other contacts. By providing us with such individual’s personal data, you represent and warrant that you have obtained their consent, or that you have another legal basis or necessary authorization to share such data with us and to permit it to be processed in accordance with this Policy.

3.1 The personal data that SeaTalk may collect includes but is not limited to:

- account registration information (including your name; email address; date of birth; address; country, state, city, telephone number and account identifiers);

- account verification or identity verification information (including photographs; government-issued IDs, personal identification numbers issued by regulatory or tax authorities, and company registration documents containing personal data and copies of such IDs or documents);

- device information (such as device ID, device type, device name and related information sent by or associated with the device(s) used to access our Services or Platform);

- information about your network (such as IP address and network provider);

- location data (exact and approximate location);

- any other information about the User when the User signs up to use our Services or Platform, and when the User uses the Services or Platform, as well as information related to how the User uses our Services or Platform; and

- aggregate data on content the User engages with.

3.2 You agree not to submit any information to us which is inaccurate or misleading, and you agree to inform us of any inaccuracies or changes to such information. We reserve the right at our sole discretion to require further documentation to verify the information provided by you.

3.3 If you sign up to be a user of our Platform using your social media account (“Social Media Account”), link your SeaTalk account to your Social Media Account or use any SeaTalk social media features, we may access information about you which you have voluntarily provided to your Social Media Account provider in accordance with such provider's policies, and we will manage and use any such personal data in accordance with this Policy at all times.

3.4 If you do not want us to collect the aforementioned information/personal data, you may opt out at any time by notifying our Data Protection Officer in writing. Further information on opting out can be found in the section below entitled "How can you withdraw consent, remove, request access to or modify information you have provided to us?" Note, however, that opting out or withdrawing your consent for us to collect, use or process your personal data may affect your use of the Services and the Platform. For example, opting out of the collection of location information will cause its location-based features to be disabled.

We or third parties as authorized by us may from time to time use cookies or similar files (such as scripts, tags, pixels or other technologies) (“Cookies”) to allow us or third parties to collect or share information in connection with your interaction and/or use of the Platform. These features help us improve the Platform and help us offer new services and features through the Platform. We may link cookie information to personal data to enable us and/or third parties engaged by us to conduct data analysis and to monitor usage of the Platform. You can control or delete cookies through your device settings. Most mobile devices and browsers allow you to refuse cookies or alert you when cookies are being set, or allow you to clear and delete cookies on your device. However, please note that if you do this you may not be able to use the full functionality of the Platform.

5.1 We may collect, use, disclose and/or process your personal data for one or more of the following purposes:

- to consider and/or process your application with us and for identity verification, due diligence, know-your-customer purposes, and anti-fraud measures in accordance with legal or regulatory obligations or our risk management procedures required by law or put in place by us;

- to manage, operate, provide and/or administer your use of and/or access to our Services and our Platform (including, without limitation, remembering your preference), as well as your relationship and user account with us;

- to enforce our Terms of Service or any applicable end user license agreements or to respond to legal processes or to comply with applicable law, governmental or regulatory requirements of any relevant jurisdiction;

- to prevent or investigate any actual or suspected violations of our Terms of Service, fraud, complaints, unlawful activity, or misconduct, whether relating to your use of the Platform or any other matter arising from applicable agreements, contracts and/or terms and/or conditions entered into, as agreed or accepted by you with us;

- to protect personal safety and the rights, property or safety of others;

- to maintain and administer any software updates and/or other updates and support that may be required from time to time to ensure the smooth running of our Services;

- to deal with or facilitate customer service, carry out your instructions, deal with or respond to any enquiries given by (or purported to be given by) you or on your behalf or other communications (including monitoring or recording phone calls and user interactions for quality assurance, employee training and performance evaluation);

- to contact you or communicate with you via voice call, text message and/or fax message, email and/or postal mail or otherwise for the purposes of administering and/or managing your relationship with us or your use of our Services, such as but not limited to communicating administrative information to you relating to our Services. You acknowledge and agree that such communication by us could be by way of the mailing of correspondence, documents or notices to you, which could involve disclosure of certain personal data about you to bring about delivery of the same as well as on the external cover of envelopes/mail packages;

- to allow other users to interact or connect with you on the Platform, including to inform you when another User has sent you a private message or posted a comment for you on the Platform;

- to conduct research, analysis and development activities (including, but not limited to, data analytics, surveys, product and service development and/or profiling), to analyse how you use our Services, to improve our Services or products and/or to enhance your customer experience, including for the purpose of improving AI tools and our other services;

- to allow for audits and surveys to, among other things, validate the size and composition of our target audience, and understand their experience with SeaTalk’s Services;

- for marketing and advertising and in this regard, to send you information and materials relating to products and/or services (including, without limitation, products and/or services of third parties whom SeaTalk may collaborate or tie up with) that SeaTalk (and/or its affiliates or related corporations) may be selling, marketing or promoting, whether such products or services exist now or are created in the future. You can unsubscribe from receiving marketing information at any time by using the unsubscribe function within the electronic marketing material. We may use your contact information to send newsletters from us and from our related companies;

- to produce statistics and research for internal and statutory reporting and/or record-keeping requirements;

- to prevent or investigate any fraud, unlawful activity, omission or misconduct, whether relating to your use of our Services or any other matter arising from your relationship with us and whether or not there is any suspicion of the aforementioned;

- to store, host, back up (whether for disaster recovery or otherwise) of your personal data, whether within or outside of your jurisdiction;

- to deal with and/or facilitate a business asset transaction or a potential business asset transaction, where such transaction involves SeaTalk as a participant, along with any other third party organisations who are participants in such transaction. A “business asset transaction” refers to the purchase, sale, lease, merger, amalgamation or any other acquisition, disposal or financing of an organisation or a portion of an organisation or of any of the business or assets of an organisation; and/or

- any other purposes which we notify you of at the time of obtaining your consent.

(collectively, the “Purposes”).

5.2 As the purposes for which we will/may collect, use, disclose or process your personal data depend on the circumstances at hand, such purpose may not appear above. However, we will notify you of such other purpose at the time of obtaining your consent, unless processing of the applicable data without your consent is permitted by the Privacy Laws and/or other applicable laws.

5.3. You acknowledge, consent and agree that we may access, preserve and disclose your personal data, account information and any other materials or information you provide to us to any legal, regulatory, or governmental authority, the relevant rights owner, or other third parties if required to do so by law, pursuant to an order of a court or lawful request by any governmental, law enforcement, or regulatory authority having jurisdiction over us or our affiliates or in a good faith belief that such access preservation or disclosure is reasonably necessary to: (a) comply with legal process or applicable law; (b) comply with a request from any governmental, law enforcement, or regulatory authority having jurisdiction over us or our relevant affiliates; (c) enforce our Terms of Service or this Privacy Policy; (d) respond to any threatened or actual claims asserted against SeaTalk or its affiliates or other claim that any content uploaded to the Platform violates the rights of third parties; (e) respond to your requests for assistance; or (f) protect our rights, property or personal safety, or that of other users and/or the public.

6.1 We implement a variety of technical and security measures such as encryption of your personal data and strive to ensure the security of your personal data on our systems. User personal data is contained behind secured networks and is only accessible by a limited number of employees who have special access rights to such systems. However, there can inevitably be no guarantee of absolute security, for instance, when unauthorised disclosure, access, or use arises from malicious and/or sophisticated hacking by individuals or organisations through no fault of ours. Third parties may unlawfully intercept or access, or attempt to intercept or access, personal data transmitted to or contained on the Platform, or that technologies may malfunction or not work as anticipated. We will nevertheless deploy reasonable security arrangements to protect your personal data as required by Privacy Laws.

6.2 We will retain personal data in accordance with the Privacy Laws and/or other applicable laws, including as necessary to fulfil the purpose(s) for which it was collected, process your application, resolve disputes, establish legal defences, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws. That is, we will destroy or anonymize your personal data when we have reasonably determined that (a) the purpose for which that personal data was collected is no longer being served by the retention of such personal data; (b) retention is no longer necessary for any legal or business purposes; (c) if you seek correction or amendment of inaccurate, untrue, incomplete, or improperly processed personal data; and/or (d) request erasure of personal data held about you by us, subject to certain exceptions prescribed by law.

6.3 If you cease using the Platform, or your permission to access or use the Platform and/or the Services is terminated or withdrawn and/or you otherwise terminate your relationship with us, we may continue storing, using and/or disclosing your personal data in accordance with this Privacy Policy and our obligations under the Privacy Laws and/or other applicable laws. Subject to applicable law, we may securely dispose of your personal data without prior notice to you.

7.1 In conducting our business or providing access to the Platform to you, we will/may need to disclose your personal data to our third party service providers, agents and/or our affiliates or related corporations, and/or other third parties, whether situated within or outside Singapore, for one or more of the above-stated Purposes. Such third party service providers, agents and/or affiliates or related corporations and/or other third parties would be processing your personal data either on our behalf or otherwise, for one or more of the above-stated Purposes. Such third parties include, without limitation:

- our subsidiaries, parent company, affiliates and related corporations;

- other users of our Platform for one or more of the above-stated Purposes;

- contractors, agents, service providers and other third parties we use to support our business. These include but are not limited to those which provide administrative or other services to us such as financial service providers, telecommunications companies, IT providers, insurance companies, mailing houses, analytics services, advertising and marketing partners, information technology companies and data centres; Your inputs and information may also be transmitted to AI models or service providers such as Open AI and Google, which process personal data in accordance with their respective terms and privacy policies.

- a buyer, potential buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of SeaTalk’s assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal data held by SeaTalk about our Users is among the assets transferred; or to a counterparty in a business asset transaction that SeaTalk or any of its affiliates or related corporations is involved in;

- in connection with business transactions;

- government or law enforcement officials, regulatory authorities, or private parties as we, in our sole discretion, believe necessary or appropriate to respond to legal claims and legal processes, protect our rights and/or the rights of other third parties, and/or to prevent or address any activity we consider unlawful, unethical or legal actionable; and

- third parties to whom disclosure by us is for one or more of the Purposes and such third parties would in turn be collecting and processing your personal data for one or more of the Purposes

7.2 For the avoidance of doubt, in the event that Privacy Laws or other applicable laws permit an organisation such as us to collect, use or disclose your personal data without your consent, such permission granted by the laws shall continue to apply. Consistent with the foregoing and subject to the Privacy Laws and/or other applicable laws, we may use your personal data for recognized legal grounds including to comply with our legal obligations, to perform our contract with you, to achieve a legitimate interest and our reasons for using it outweigh any prejudice to your data protection rights, or where necessary in connection with a legal claim.

8.1 The Services are not intended for children under the age of 13. We do not knowingly collect or maintain any personal data or non-personally-identifiable information from anyone under the age of 13 nor is any part of our Platform or other Services directed to children under the age of 13. As a parent or legal guardian, please do not allow such children under your care to submit personal data to SeaTalk. In the event that personal data of a child under the age of 13 in your care is disclosed to SeaTalk, you hereby consent to the processing of the child’s personal data and accept and agree to be bound by this Policy on behalf of such child. We will close any accounts used exclusively by such children and will remove and/or delete any personal data we believe was submitted without parental consent by any child under the age of 13. In some jurisdictions, the age of 13 limit may be higher or lower pursuant to applicable laws, in which case we comply with applicable age restrictions.

9.1 Our Platform uses Google Analytics, a web analytics service provided by Google, Inc. ("Google"). Google Analytics uses cookies, which are text files placed on your device, to help the Platform analyse how Users use the Platform. The information generated by the cookie about your use of the Platform (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the Platform, compiling reports on website activity for website operators and providing other services relating to website activity and Internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf. Google will not associate your IP address with any other data held by Google.

9.2 Our Services may be used in connection with third-party applications, platforms, and services that you integrate with the Services including but not limited to (a) large language models (including those provided by Google and OpenAI); and (b) websites, web applications, browser interfaces, and online services accessed through browser-based actions, whether or not such services are identified, integrated, or supported by us (collectively, “Third-Party Services” and each, a “Third-Party Service”). We do not control or accept responsibility for any loss or damage that may arise from your use of any Third-Party Services, for which we make no representations or warranties. By using the Services, you acknowledge and agree that we are not responsible for examining or evaluating the content, accuracy, completeness, availability, timeliness, validity, copyright compliance, legality, decency, quality or any other aspect of such Third-Party Services. Your use of any Third-Party Services, is at your own risk and subject to any terms, conditions, or policies (including privacy policies) applicable to each such Third-Party Service.

9.3 We, and third parties, may from time to time make software applications downloads available for your use via the Platform or through the Services. These applications may separately access, and allow a third party to view, your identifiable information, such as your name, your user ID, your device’s IP Address or other information such as any cookies that you may previously have installed or that were installed for you by a third party software application or website. Additionally, these applications may ask you to provide additional information directly to third parties. Third party products or services provided through these applications are not owned or controlled by SeaTalk. You are encouraged to read the terms and other policies published by such third parties on their websites or otherwise.

10.1 WE DO NOT GUARANTEE THE SECURITY OF PERSONAL DATA AND/OR OTHER INFORMATION THAT YOU PROVIDE ON THIRD PARTY SITES. We do implement a variety of security measures to maintain the safety of your personal data that is in our possession or under our control. Your personal data is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems, and are required to keep the personal data confidential. When you access your personal data, we offer the use of a secure server.

10.2 In an attempt to provide you with increased value, we may choose various third party websites to link to, and frame within, the Platform. These linked sites have separate and independent privacy policies as well as security arrangements. Even if the third party is affiliated with us, we have no control over these linked sites, each of which has separate privacy and data collection practices independent of us. Data collected by our co-brand partners or third party web sites (even if offered on or through our Platform) may not be received by us.

10.3 We therefore have no responsibility or liability for the content, security arrangements (or lack thereof) and activities of these linked sites. To protect your information we recommend that you carefully review the privacy policies of all third-party services that you access. These linked sites are only for your convenience and you therefore access them at your own risk. Nonetheless, we seek to protect the integrity of our Platform and the links placed upon each of them and therefore welcome any feedback about these linked sites (including, without limitation, if a specific link does not work).

11.1 Your personal data and/or information may be transferred to, stored or processed outside of your country for one of more of the Purposes. In most cases, your personal data will be processed in Singapore, where our servers are located and our central database is operated. SeaTalk will only transfer your information overseas in accordance with Privacy Laws and/or other applicable laws, and will provide suitable protection measures which enable the enforcement of the data subject’s rights in accordance with Privacy Laws and/or other applicable laws.

12.1 Withdrawing Consent

12.1.1 You may withdraw your consent for the collection, use and/or disclosure of your personal data in our possession or under our control by sending an email to our Personal Data Protection Officer at dpo@seatalk.biz, and we will process such requests in accordance with this Privacy Policy and our obligations under the Privacy Laws and other applicable law. However, your withdrawal of consent may mean that we will not be able to continue providing access to the Platform to you.

12.2 Requesting Access and/or Correction of Personal Data

12.2.1 You may request to access and/or correct your personal data currently in our possession or control by submitting a written request to us. We will need enough information from you in order to ascertain your identity as well as the nature of your request so as to be able to deal with your request. Hence, please submit your written request by sending an email to our Personal Data Protection Officer at dpo@seatalk.biz.

12.2.2 We may charge you a reasonable fee for the handling and processing of your requests to access your personal data. If we so choose to charge, we will provide you with a written estimate of the fee we will be charging. Please note that we are not required to respond to or deal with your access request unless you have agreed to pay the fee.

12.2.3 We reserve the right to refuse to correct your personal data in accordance with the provisions as set out in Privacy Laws, where they require and/or entitle an organisation to refuse to correct personal data in stated circumstances such as if access would cause immediate or serious harm, or threaten an individual’s safety, physical or mental health.

12.2.4. Please note that certain information may be exempt from such requests under applicable law and that, depending on your data choices, certain services may be limited or unavailable.

13.1 If you have any questions or concerns about our privacy practices, we welcome you to contact us by e-mail at dpo@seatalk.biz.

13.2. Please include your name, contact information, and the nature of your request so that we can appropriately respond to your communication.

14.1 Where you authorise the connection of any Google Workspace APIs, the use and transfer of raw or derived user data received from Google Workspace APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements.