Introduction

This Privacy Policy describes our practices in connection with personal data that we or our service providers may collect, use or disclose when you visit or use our products, services, websites and apps offered by Cloudsquire Pte. Ltd. (Company Registration No. 201714924M) (“we”, “our”, “us” or “company”), a private limited company incorporated under the laws of the Republic of Singapore with its registered address at 22, Sin Ming Lane, #06-76, Midview City, Singapore 573969 except where otherwise noted. The services include SummyMonkey and SecureHub, as well as any other services we provide from time to time.

We respect your privacy and are committed to protecting it in compliance with the Personal Data Protection Act 2012 (“PDPA”) of Singapore. This Privacy Policy is intended for use in Singapore and, where applicable, other countries or regions which provide the same level of protection for personal data that is comparable to the standards of the PDPA.

The PDPA recognizes the rights of individuals to protect their personal data (including rights of access and correction) and the requirement for organizations to collect, use or disclose personal data for legitimate and reasonable purposes. Accordingly, this Privacy Policy explains the types of information we may collect through our online platform and related services (the “Service“) and our practices for collecting, using, maintaining, protecting, and disclosing that information. We recommend that you read this Privacy Policy and our Terms of Service carefully before disclosing any personal data to us or using the Service.

If you are registering to use the Service on behalf of your employer, company, or organization (the “Organization”), you represent and warrant that you have the authority to accept this Privacy Policy on behalf of the Organization. If you (and your Organization, if applicable) do not agree to our Privacy Policy, please do not use the Service. The term “you,” “your,” in this context refers to both you as an individual user and your Organization (where applicable). Otherwise, “you” or “your” shall mean the party disclosing personal data. 

By accessing or using our Service, you agree to this Privacy Policy. This Privacy Policy may change from time to time. Your continued use of our Service after we make changes is deemed to be acceptance of those changes.

Information We Collect About You and How We Collect It 

When you register to use our Service, we collect personal data from you to provide the Service. “Personal data” or “personal information” means data, whether true or not, about an individual who can be identified (a) from that data; or (b) from that data and other information to which the organization has or is likely to have access. This includes your name, email address for the login credentials, either through Google authentication or your chosen username and email. This information is necessary to facilitate your access to the Service and personalize your experience. If you choose not to provide us with the information requested, you may not benefit from certain features of the Service or participate in a particular activity and your use of the Service may be limited.

We will only collect information that is reasonably necessary for us to provide you with the Service. We collect such information only when we ask you for it and you provide it, and through technology that collects information automatically, such as cookies or other similar technologies (as explained below). We will not be responsible for relying on inaccurate or incomplete data arising from your failure to notify us of any changes or inaccuracies in your personal data that was provided to us.

We collect information in several ways, such as:

1. From our website: you may have an opportunity to send us information about yourself (e.g. when you create an account/when you fill out a registration form/survey). You may choose to personalize your user-experience on the Service in which case we may collect information about your visits to our website, including the URL clickstream, products you viewed or searched for, length of visits to certain pages and page interaction which may be collected automatically through the use of cookies.
2. We may collect information when you contact us for information on our applications and Service, provide feedback or complaints or otherwise in the course of providing technical assistance or responding to product or service queries. 

Our Service offers a range of features including but not limited to storing of audio, audio-to-text conversion, translation of languages, storing of photographs and processing of photographs . These functionalities are designed to enhance user productivity and convenience.

Storing of audio: We store the audio for a period of TWO months or as agreed bilaterally with you.

Audio-to-Text Conversion: With our Service, users can convert audio files into written text. This functionality simplifies the process of transcribing crucial audio content such as meetings, interviews, or recorded conversations, thereby facilitating efficient review and reference of the information.  The storing of text is up to maximum FIVE Years.

Storing of photographs: We store the photographs for a period of TWO months or as agreed bilaterally with you.

Processing of photographs:  With our service, users can analyse the photo uploaded into our system.  We store the proecessing results of the photo for up to FIVE years.

It is of utmost importance for users to exercise their responsibility to ensure that no personally identifiable information is disclosed or incorporated into the content processed by our Service. We prioritize the privacy and security of our users and refrain from collecting or retaining any sensitive personal data that can be used to identify individuals, unless explicitly provided by users for the sole purpose of accessing and utilizing our Service. Sensitive personal data includes audio, visual or similar information such as photographs, videos or voice recordings. Unless specifically requested for, we ask that you do not send us or disclose to us any sensitive personal information such as passport/national identification card numbers, social security numbers, credit card numbers, information related to racial or ethnic origin, political opinions, sexual orientation, criminal background on or through the Service or otherwise to us. 

We may collect certain information automatically through the use of cookie-less tracking technology when you use the Service, and the information may be collected in the following ways: 

1. Through your browser
   This may include your Media Access Control (MAC) address, computer type (Windows or Mac), screen resolution, operating system name and version, and Internet browser type and version. 
2. IP address
   Your IP address, along with the time of the visit and pages visited, is identified and logged automatically in our server log files whenever you visit the Service. Collection of IP addresses is standard practice and is done automatically by many online services. The IP address collected may be use for diagnosing server problems and administering the Service.
3. Mobile device
   If you access the Service through a mobile device, we may collect information on it such as smartphone device brand and type to understand how you use the Service. 

How We Use Your Information 

The information we collect from you, including personal data, is generally used for purposes not limited to the foregoing and for purposes permitted by applicable laws:

• Delivering information, products, or services subscribed on the platform
• Processing, fulfilling, supporting, and administering transactions and orders related to the Service and other ancillary services you request from us.
• Administration and management of various services provided by us
• Shape strategies and plans for our research, advocacy, support services and operational work
• Carrying out our obligations and enforcing our rights arising from contracts between you and us, including billing and collection.
• Notifying you about changes to our Service or any related products or services.
• Obtaining your consent for any additional purposes, including conducting trials (with your consent) to enhance, improve and optimize your experience when you use the Service
• To comply with regulatory requirements, where applicable.

We prioritize the protection of your personal data and do not share, sell, or disclose it for purposes other than those stated in this Privacy Policy or when we inform you and give you an opportunity to opt out of having your personal information shared. However, we may disclose your personal data with:

1. Our affiliates and third-party service providers who assist us in supporting our business operations. We may share information, including personal information, with third parties that perform certain services on our behalf. These services may include, without limitation, storage of personal information on a cloud service, server hosting, marketing and supporting our notification service functionality. These service providers may have access to personal information needed to perform their functions but are not permitted to disclose or use such information for any other purposes.
2. We may allow third party service providers, advertising companies, advertisement networks, merchandising companies and other third parties to display advertisements and brands on the Service. These companies may use tracking technologies, such as cookies or web beacons, to collect information about users who view or interact with their advertisements.
3. A company that merges with or acquires us, or in the event of any structural changes to our company.
4. Compliance with legal obligations.
5. Enforcing our rights.
6. With your explicit consent.

We do not provide any non-anonymized personal information to third parties. We will adhere to the provisions in the PDPA in relation to any disclosure and dissemination of information to any third parties.

We may disclose your information, including personal information in response to a subpoena or similar investigative demand, a court order, or a request for cooperation from a law enforcement or other government agency; to establish or exercise our legal rights, to defend against legal claims, or as otherwise required by law. 

By using the Service, you expressly authorize and consent to us gathering, reviewing, retaining and where reasonably required, transmitting your personal information to our intermediary companies and entities for the proper and reasonable purpose of them storing and using the data responsibly and in accordance with the PDPA. When you provide personal information on or through the Service, the information may be sent to servers located outside of Singapore. In such an event, we will take appropriate steps to ascertain that the foreign recipient organization of the personal data is bound by legally enforceable obligations that are in-line with the requirements under the PDPA. 

We may also use your personal information to: 

(a) Ensure that the content on the Service is presented in the most effective manner for you and understand your interests;

(b) Provide the Service to you and contact you on the same;

(c) Provide you with updated information with respect to the Service;

(d) Improve the functionality and usage of the Service;

(e) Prepare customer lists for market research;

(f) Resolve or track status of issues on our Service and to guide the development of new services;

(g) Allow you to participate in features of the Service;

(h) Identify the types of devices you use so that we can optimize our systems;

(i) Communicate with you by email or other chosen means to send relevant notifications about our activities, developments and services that may be of interest to you; 

(j) Contact you and notify you about changes to the Service that we offer (except where you have expressly requested for us not to do so);

(k) Ensure that you comply with our terms and conditions and the applicable law; and

(l) Send you important notifications that you will require to use the Service.  

Protection and Security of Personal Information

We will take reasonable steps to ensure that the personal data of users are securely stored or filed. We adopt commercially reasonable security measures to safeguard personal data collected including: 

1. Engaging reputable third-party cloud system service providers and generative AI (such as Azure OpenAI) to host our cloud storage systems and ensuring integration is properly done, as well as reputable e-commerce providers or payment gateway, where applicable;
2. Ensuring the security of our storage systems (e.g. Google Drive) and information communication systems;
3. Checking that the third-party cloud system service providers that we engage adopt robust security measures that include configuring their cloud services to only allow access by whitelist IP addresses, periodically auditing configurations and security controls to ensure that servers or programs that host their cloud storage systems remain secure despite increasing sophistication of data breach threats; and
4. Adopting processes within our information communication systems, and checking with our cloud system service providers, to ensure that the organization has security measures against malware and phishing attempts.

We have implemented reasonable and appropriate data security measures designed to secure your personal data from accidental loss and from unauthorized access, use, alteration, and disclosure.  We have implemented best-practice standards and controls in compliance with internationally recognized security frameworks. The safety and security of your information also depends on you. Where you have chosen a password for the use of our Service, you are responsible for keeping this password confidential. You should not share your password with anyone.  You are also responsible for any transmission of Personal Data by you when using our services. We are not responsible for circumvention of any privacy settings or security measures contained on the Service, or in your operating system.

While we adopt reasonable physical, administrative and technical measures to help safeguard and secure your personal information from unauthorized access, collection, use, copying, modification, disposal and disclosure, we cannot guarantee that data breaches will not occur despite the adoption of commercially reasonable security measures that include the measures set out above. No system can be completely secure. Hence, we also cannot guarantee that your personal information, activities while you use the Services, or other communications will always remain secure. If you have a reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you have with us has been compromised), please immediately contact us below.

We do not keep personal information for longer than is required, and we destroy or permanently anonymize personal information that we no longer need, where permitted. 

Cross-border transfer

Your personal information may be transferred, stored or processed in any country where we have facilities or service providers. By using our Service or by providing consent to us (where required by law), your information may be transferred to countries or territories outside Singapore, including the United States, the United Kingdom or the European Union, which may provide for different data protection rules than in Singapore. We will ensure that the use and disclosure of personal information transferred offshore is dealt with in accordance with this Privacy Policy, and we will not transfer your personal data to a country or territory outside Singapore that does not provide protection of personal data that is comparable to the protection under the PDPA. 

Retention of Personal Information

We retain the personal data of users only for as long as it is required to fulfil the purpose for which it was collected and, in any event, no longer than 5 years after termination of user login account unless it is necessary to retain the data for legal or business reasons.

Third-party sites

There are a number of places on our Service where users may click on a link to access other websites that do not operate under this Privacy Policy. For example, if users click on an advertisement (news and promotions) on our Service, they may be taken to a website that we do not control. These third-party websites may independently solicit and collect information, including personal information, from the users and, in some instances, provide us with information about the users’ activities on those websites. You are advised to consult the privacy statements of all third-party websites that you visit. The availability of, or inclusion of a link to, any such site or property on the Service does not imply endorsement of it by us or by our affiliates. 

Use by minors

Users below 18 years of age or users who are not the minimum legal age in their country of residence to provide consent may not use the Service, subject to their parent or guardian who may open an account to use the Service and help them access appropriate content.

It is your sole responsibility to provide us with your correct information when you set up an account to use the Service. Where you are setting up your account to use or access the Service as a parent or legal guardian, you are required to provide your personal data and the personal data of your charges, and we shall be entitled to assume that all personal data provided is true and accurate. We will take appropriate steps to delete any personal data of persons less than 13 years of age that has been collected on or through the Service without verified parental consent, or consent from a legal guardian, upon learning of the existence of such personal data. 

No Third-party Rights

This Privacy Policy does not create rights enforceable by third parties or require disclosure of any personal information relating to users of the Services. 

Jurisdiction-specific rules: 

For users in the European Economic Area and the United Kingdom

We acknowledge that the European Union General Data Protection Regulation (“GDPR”) will apply if we process or hold any personal data of individuals located at or residing in the European Economic Area (“EEA”) or if we offer goods or services to individuals in the EEA (“EU Individuals”). 

We understand that we may lawfully process personal data if consent is provided by the EU Individual for the processing for specific purposes, if it is necessary for the performance of a contract of if it is necessary for our compliance with a legal obligation.

We understand that personal data must be processed lawfully, fairly and transparently, be collected and applied only for specified, explicit and legitimate purposes, must be limited to only what is required, must be accurate, not be kept in personally identifiable form for longer than is necessary and must be secured and protected pursuant to the GDPR.

We acknowledge and agree that the GDPR affords EU Individuals with rights such as:

1. Right to access and obtain a copy of the EU Individuals’ personal data, including the purposes of processing and who the personal data has been disclosed to;
2. Right to rectify inaccurate personal data concerning the EU Individual;
3. Right to erasure of personal data concerning the EU Individual in certain circumstances;
4. Right to restriction of processing of personal data in certain circumstances, such as where the accuracy of the personal data is contested, or the processing is unlawful;
5. Right to data portability by receiving personal data concerning the EU Individual or data which has been provided to us, in a structured, commonly used and machine-readable format, and the right to transmit that data to another organization;
6. Right to object to the processing of personal data in certain circumstances, including for the purposes of direct marketing; and
7. Right not to be subject to automated decision-making (including profiling) where this has a legal effect on the EU Individual or significantly affects him.

We agree that we will act on a request from an EU Individual without undue delay (within one month). We will maintain records of how we process personal data, acknowledge the need to conduct data protection impact assessments and the need to apply careful consideration in the adoption and engagement of our data processors.

For users in California

This section only applies to California residents (“you”). Under the California Consumer Privacy Act of 2018 (“CCPA”), California residents have the right to know what personal information about them is collected, request deletion of their personal data, opt-out of the sale of their personal data, and not be discriminated against if they choose to exercise any of these rights. We do not sell any of the data we collect about you. If you would like to enquire or exercise any of the other rights afforded to you under the CCPA, please contact us.  

Contact us 

If at any time you would like to access, review, correct, update, restrict, or delete your personal data, or if you would like to enquire about our privacy practices, please contact us by:

• Email to our Data Protection Officer: DPO @cloudsquire.com or contact@cloudsquire.com
• Post to: 22, Sin Ming Lane, #06-76, Midview City, Singapore 573969   

We will endeavour to respond to your request as soon as reasonably practicable and no later than one (1) month after receipt. If circumstances cause any delay in our response, you will be promptly notified and provided a date for our response. Your withdrawal of consent to our collection, use and disclosure of personal information may mean that we will not be able to continue with the existing relationship with you and the contract that you have with us may be terminated.