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SYNAGIE PLATFORM PRIVACY POLICY

This Privacy Policy sets forth how Synagie, its owner, group and affiliated companies ("us", "we", or "our") collect, use, disclose, and/or process your personal data through your use of our Synagie ("Platform") accessible at www.synagie.com.

By using or accessing any part of our Platform, including registering for a Synagie Account to access or use any of the features, functionalities or services we provide or make available through the Platform (the "Services"), you hereby agree to be bound by the terms of this Privacy Policy. If you do not agree to be bound by this Privacy Policy, you should not access or use our Platform or disclose any personal data through our Platform.

This Privacy Policy is incorporated into and is subject to our Synagie Platform Terms of Use, which is available at www.synagie.com. Capitalised terms used but not defined in this Privacy Policy shall have the meaning given to them in the Synagie Platform Terms of Use.

1. PERSONAL DATA THAT WE MAY COLLECT

We may collect the following personal data about you when you create a Synagie Account, access or use our Platform:

  1. Information that you may provide when filling in forms on the Platform or otherwise submit or make available to us. This includes but is not limited to any Registration Data provided for any Services, your name, email address, contact details, and details of your authorised Sub-Users;
  2. Information that you may provide when you interact with our customer service team;
  3. Financial account information, such as credit card numbers and other payment information;
  4. Your transaction history with us;
  5. Information that you input into our Platform, including your user-generated content, search history, interaction data, and preferences; and
  6. Technical data collected when you visit our Platform, which may include URL information, cookie data, web beacons and other tracking technology information, your IP address, the types of devices you are using to access or connect to our services, unique device IDs, device attributes, network connection type (e.g., Wi-Fi, 5G, LTE, Bluetooth) and provider, network and device performance, browser type, language, and operating system.
2. HOW WE USE YOUR PERSONAL DATA

You agree and consent to us processing, collecting, using and disclosing your personal data for the following purposes:

  1. To process, administer and/or manage your account information;
  2. To verify your identity;
  3. To provide you with technical support that you have requested for;
  4. To facilitate your Marketplace activity during the Subscription Period;
  5. To provide you with any services (including Third Party Services) and products that you may request from us from time to time and to communicate with you in relation to those services and products;
  6. To deliver to you any administrative notices, updates, notifications, alerts and communications relevant to your use of our Platform and/or any orders placed to us through the Platform;
  7. To enhance our services and provide you with personalised experiences using our Platform and/or integrated artificial intelligence ("AI") tools;
  8. To analyse and process your personal data using AI tools to improve the accuracy, efficiency, and effectiveness of our Platform;
  9. To train and improve our technology and any integrated AI tools, such as our machine learning models and algorithms, including by monitoring interactions and usage across your devices;
  10. To promote the safety, security, and stability of the Platform, such as by preventing and detecting abuse, fraud, and illegal activity on the Platform and by conducting troubleshooting, data analysis, testing, and research;
  11. To monitor and evaluate the performance of the Platform, the AI tools and the delivery of services to you;
  12. To contact you through the contact information provided by you in order to provide you with information or services that you request from us or which we feel may interest you, where you have consented to be contacted for such purposes;
  13. To store, host and/or back up (whether for disaster recovery or otherwise) your personal data;
  14. For record-keeping purposes;
  15. To conduct research, analysis and development activities (including but not limited to data analytics, surveys and/or profiling) to improve our Platform;
  16. To respond to any legal processes, pursue legal rights and remedies, and manage any complaints or claims;
  17. To respond to requests for information from public and any Governmental Authority, statutory boards, related companies and for audit, compliance, investigation and inspection purposes;
  18. To comply with any Applicable Laws, regulation, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority, whether within or outside Singapore;
  19. Any third party in connection with (i) the sale of any of our business or assets, in which case we may disclose your personal data to the prospective buyer of such business or assets; or (ii) the acquisition of us or substantially all of our assets by a third party, in which case personal data held by us about you and our other customers will be one of the transferred assets; and
  20. To achieve any other incidental business purposes related to or in connection with the above.

(collectively, the "Purposes").

3. WHO WE DISCLOSE YOUR PERSONAL DATA TO

You agree and consent that your personal data may be used, disclosed, maintained, accessed, processed and/or transferred to the following third parties, for one or more of the Purposes or otherwise permitted/required by law:

  1. Third party vendors or service providers which require the processing of your personal data, for example, AI capabilities which have been offered and/or integrated into our Platform or 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 the Platform; or (iii) otherwise in connection with the provision of our Platform;
  2. Third Party Services which you have requested for, including to facilitate your Marketplace activity;
  3. Our advisors including auditors and legal advisors;
  4. Financial institutions, credit card companies and payment processors; and
  5. Governmental Authorities, statutory boards, industry associations or as otherwise required by Applicable Laws and regulations,

(collectively, the "Permitted Parties").

The Permitted Parties listed above may continue to apply even in situations where your relationship with us has been terminated or altered in any way, for a reasonable period thereafter.

4. TRANSFERS OUT OF SINGAPORE

Your personal data may be transferred and/or stored outside of Singapore. We will take appropriate steps to ascertain whether, and to ensure that, any third-party recipient in a country outside Singapore is bound by legally enforceable obligations to provide the transferred personal data a standard of protection that is at least comparable to the protection under Singapore's Personal Data Protection Act 2012 ("PDPA").

5. ACCURACY OF PERSONAL DATA

Where you submit personal data through our Platform, you should try to ensure such personal data is accurate, and let us know if such personal data changes so that we are not holding any inaccurate personal data about you, or your authorised Sub-Users.

6. PROTECTION OF PERSONAL DATA

We will take appropriate administrative, physical, and technical measures to safeguard your personal data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, and the loss of any storage medium or device on which personal data is stored.

You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your personal data, and are constantly reviewing and enhancing our security measures.

7. YOUR RIGHTS

You may withdraw your consent for us to use your personal data for one or more of the Purposes by writing to our Data Protection Officer using the contact details below. Upon receipt of your written request to withdraw your consent, we may require a reasonable period of time to process and respond to your request. However, please note that your failure to supply certain personal data to us or depending on the nature and scope of your request to withdraw your consent, it may result in us being unable to continue providing you with the services under our Platform.

You may request to (i) access and/or (ii) correct the personal data currently in our possession, including but not limited to any situation where you notice that any output from our Platform contains factually inaccurate information about you, by writing to the Data Protection Officer using the contact details provided below.

Please note that we may charge you a reasonable fee for the handling and processing of your requests to access your personal data. If so, we will inform you of the fee before processing your access request.

We will respond to your request as soon as reasonably possible. 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.

8. CHANGES TO THIS PRIVACY POLICY

The terms of this Privacy Policy may be revised from time to time by us. We will use commercially reasonable methods to notify you of such revisions, such as by posting a revised version of this Privacy Policy on our Platform. Your continued access to or use of our Platform after such notice had been given and such revised Privacy Policy had come into effect shall constitute your acceptance of the revised Privacy Policy.

9. HOW LONG WE RETAIN YOUR PERSONAL DATA

We may retain your personal data for as long as it is necessary to fulfil the Purposes, or as required or permitted by applicable laws.

We will cease to retain your personal data or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purpose for which the personal data was collected, and is no longer necessary for legal or business purposes.

10. DATA PROTECTION OFFICER

If you want to contact us with specific queries or concerns in relation to this Privacy Policy, request to access and/or correct your personal data in our possession, 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

Email:

dataofficer@synagie.com


Office address:

38 Jalan Pemimpin

#05-09

M38

Singapore 577178

Attention: The Data Protection Officer

Privacy Policy last updated: 21 March 2025