INFORMATION WE COLLECT & HOW WE USE IT

1. We will collect the following Personal Information about you generated in these circumstances:
   1. Registration of individual account

      Your name, email, and password, during the creation of your account on our Services.

   2. Registration of organisation account

      Your name, email, organisation entity name, organisation entity address, corresponding postal code, and password, during the creation of your account on our Services.

   3. Application information

      Your audio recordings, or any text, images or videos that you upload or provide to us during the usage of our Services.

   4. Contact information

      When you contact us, you provide us with your phone number, email, or any other information you choose to provide as a form of communication.

2. We also collect, and use aggregated data such as statistical or demographic data for our purposes. Aggregated data may be derived from your Personal Information but is not Personal Information as this data will not directly or indirectly reveal your identity. However, if we combine or connect aggregated data with your Personal Information so that it can directly or indirectly identify you, we will treat the combined data as Personal Information which will be used in accordance with this Policy.
3. If you provide us with any Personal Information relating to a third-party (e.g. information of spouse, children, parents, employees and/or authorised representatives), you are taken to have obtained the consent of the third-party to you providing us with their Personal Information for the respective purposes upon your submission of such information.
4. We will use your Personal Information for:
   1. Account creation

      We use your registration information, device information and information received from third parties (e.g. your name, email address) in order to set up an account for you to use our Services. We do so in accordance with our contractual and precontractual obligations to you in order to provide you with an account to use the Services.

   2. Enable the use of our Services

      We utilise your audio recordings, videos, photos, text and any data provided by you for the usage of the Services. We also use the data automatically collected or generated about you when you use the Services for training our artificial intelligence technology and to improve its performance and accuracy. Due to the nature of REST API and AI models, the data provided by you may be accessible by our Source partner for the above limited purposes only.

   3. Billing purposes

      The account registration information specified at Clauses 1.1(a) and 1.1(b) are provided to Xero for invoice generation and accounting audit processing. More information is available here at: https://www.xero.com/sg/about/privacy/ .

   4. Customer service purposes

      When you contact us, we will use your contact information to connect with you. We use third-party customer support partners, such as Zendesk and HubSpot. More information is available here : https://www.zendesk.com/company/privacy-and- data-protection/ and https://legal.hubspot.com/privacy-policy.

   5. Marketing purposes

      By signing up for our Services, we deem it as your consent to allow for the information specified at Clauses 1.1(a) and 1.1(b) for our Company's analytics, sales and marketing purposes. This would include sending you emails with news or updates pertaining to our Services. When doing so, we will process your information and may process your usage information. Your consent can be withdrawn at any time by email to enquiry@sentient.io.

   6. Any legal matters

      We will abide by any applicable law(s) or order(s) of a court of competent jurisdiction or any recognised stock exchange or government or regulatory department or agency with jurisdiction over Sentient.io to disclose your information, provided that, where legally permissible, prior to such disclosure we consult you on the proposed form, nature and purpose of the disclosure and notify you promptly so that the you may seek appropriate remedies to protect your interests in such information, including but not limited to seeking an appropriate protective order.

5. To facilitate our global operations, Sentient.io may transfer, store and process your operations with our partners and service providers based outside of the country in which you are based. Laws in those countries may differ from the laws applicable to your country of residence. Where we transfer, store and process your Personal Information outside of Singapore, we will obtain your consent for the transfer to be made and we will take steps to ensure that your Personal Information continues to receive a standard of protection that is at least comparable to that provided under the PDPA.
6. You should ensure that all Personal Information submitted to us is complete, accurate, true and correct. Failure on your part to do so may result in our inability to provide you with products and services you have requested.

INFORMATION DISCLOSURE

1. Sentient.io will disclose or share your Personal Information, without notice, only if required to do so by law or in good faith that any such action is necessary to: (a) comply with any legal requirements or legal process served on Sentient.io or the Website; (b) protect and defend the rights or property of Sentient.io; and (c) act under exigent circumstances to protect the personal safety of users of the Website, or the general public.
2. We share your Personal Information with selected third parties, including:
   1. Paypal

      We use Paypal for all payment processing. We have no access to your credit card data. You will be directed to the PayPal website to provide your payment information directly to PayPal. PayPal's privacy policy applies to the information you provide on the PayPal website.

   2. Xero

      We use Xero for all billing purposes (please see Clause 1.4(c) above).

   3. HubSpot

      We use HubSpot for customer service purposes (please see Clause 1.4(d) above) as well as sales and marketing purposes (please see Clause 1.4(e) above). More information is available here: HubSpot Privacy Policy.

   4. Marketing and advertising agencies

      From time to time, we will engage third-party agencies for marketing and advertising purposes, including but not limited to marketing events, advertising campaigns, sales activities, social media advertising. All such engagements will be governed by legally-bound commercial agreements.

3. We will take reasonable measures to safeguard your Personal Information and share Personal Information to third parties only to the extent that it is necessary to provide you with the Services.

PUBLIC DATA

1. The Website may make use of public data obtained from publicly available sources at zero cost, including but not limited to public datasets. Sentient.io shall not be responsible for any Personal Information that has entered or will subsequently enter public domain, unless it was caused by a breach of any agreement.
2. Information you make publicly available in any public or open forum, including but not limited to social networks, may be considered public data for the purposes of this Policy, and may be accessed and collected by us. Please exercise care when disclosing such Personal Information to third parties.
3. The use of datasets on the Website is wholly governed by the Singapore Open Data Licence. Access to datasets via APIs is governed by the API Terms of Service. The terms in this Policy do not cover datasets and the use of datasets on the Website.

DATA STORAGE

1. Sentient.io stores all Personal Information for as long as necessary to fulfil the purposes set out in this Policy, or for as long as we are required by law or in order to comply with a regulatory obligation.
2. When deleting Personal Information, we will take measures to render such Personal Information irrecoverable or irreproducible, and the electronic files which contain Personal Information will be permanently deleted.

THIRD-PARTY EMBED

1. The Website and Service may provide features or links to other websites operated by third parties, such as our business partners, the data protection and privacy practices of which may differ from those of Sentient.io. We are not responsible for their content and privacy practices, and encourage you to consult their own privacy notices.
2. Any information you provide on third-party websites or services is provided directly to the operators of such websites or services and is subject to their policies governing privacy and security, even if accessed via our Website or in connection with our Service.

TRACKING & COOKIES

1. We and our third-party partners use cookies, pixel tags, and similar technologies to collect information about your browsing activities and to distinguish you from other users of our Services in order to aid your experience and measure and improve our advertising effectiveness.
2. Cookies are small files of letters and numbers that we store on your browser or on your device. They contain information that is transferred to your device.
3. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you, and can only be read by a web server in the domain that issued the cookie to you.
4. 6.4 We use the following types of cookies and similar technologies (collectively, "Cookies"):
   1. Strictly necessary cookies

      Some cookies are strictly necessary to make our services available to you. For example, to provide login functionality, user authentication and security. We cannot provide you with the Services without this type of cookie.

   2. Functional cookies

      These types of Cookies are used to recognise you when you return to our Website and platform. This enables us to personalise our content for you and remember your preferences (e.g. choice of language).

   3. Analytical, performance, or advertising cookies

      We also use cookies and similar technologies for analytics purposes in order to operate, maintain, and improve our Services and measure and improve our advertising effectiveness. We use third-party analytics providers, including Google Analytics and Hubspot, to help us understand how users engage with us. We also use third-party advertising partners, including Facebook, to deliver advertisements to you on other sites. Google Analytics uses first-party cookies to track user interactions which helps show how users use our Service and Website. This information is used to compile reports and to help us improve our Service and Website. Such reports disclose Website trends without identifying individual visitors. You can opt out of Google Analytics by going to https://tools.google.com/dlpage/gaoptout https://tools.google.com/dlpage/gaoptout or via Google's Advertisement settings. More information on HubSpot's cookie policy is available here: https://legal.hubspot.com/cookie-policy.

5. You can block cookies by setting your internet browser to block some or all or cookies. However, if you use your browser settings to block all cookies you may not be able to use our Services.
6. All Cookies will expire after a maximum of 3 years.

MODIFYING OR DELETING YOUR PERSONAL INFORMATION

1. Subject to the exceptions referred to the PDPA, you have the following rights in relation to your Personal Information that we hold.
   1. Right to access. You have the right to access the Personal Information we hold about you, and to receive an explanation of how we use it and who we share it with.
   2. Right to correction. You have the right to correct any Personal Information we hold about you that is inaccurate or incomplete.
   3. Right to deletion. You have the right to request for your Personal Information to be erased or deleted.
   4. Right to withdraw consent. You have the right to withdraw any consent you previously applied to us. We will apply your preferences going forward, and this will not affect the lawfulness of processing before your consent was given.
2. If you would like to exercise any of such rights, please send an email to enquiry@sentient.io. We may make a small charge for an access request. If so, we will inform you of the fee before processing your request.
3. Please note that, prior to any response to the exercise of such rights, we will require you to verify your identity. In processing your request, we may require additional information (e.g. why you believe the information we hold about you is inaccurate or incomplete). Where there may be valid legal reasons to refuse your request, we will inform you if that is the case. For more information on how to exercise your rights, or to exercise your rights, please email enquiry@sentient.io.
4. Please note that if your Personal Information has been provided to us by a third-party, you should contact such party directly to make any queries, feedback, and access and correction requests to Sentient.io on your behalf.

DATA SECURITY

1. We use certain physical, managerial, and technical safeguards that are designed to improve the integrity and security of Personal Information that we collect and maintain. However, the transfer of Personal Information through the internet will carry its own inherent risks and we do not guarantee the security of your data transmitted through the internet. You make any such transfer at your own risk.

BUSINESS TRANSFERS

1. During the course of its business, we may sell or purchase assets. You also consent to the collection, use and disclosure of your Personal Information by Sentient.io in connection with any transaction relating to the acquisition, divestment, securitisation, amalgamation, listing or other transaction relating to any interest in Sentient.io, the shares or assets of Sentient.io, and any other corporate transaction involving Sentient.io, including any evaluation or due diligence relating thereto, as well as to the collection, use and disclosure of such information by the counterpart(ies) thereto for the same purposes, and the provision of goods and services by such counterpart(ies) following such transaction, as may be relevant.

CONTACT & COMPLAINTS

1. If you have any questions, comments or concerns about our Policy, you may contact us in the following manner:
   Data Protection Officer

   Email address:	chris@sentient.io or enquiry@sentient.io
   Contact number:	(65) 9686 0250
   Address:	3 Fusionopolis Place, 03-56 Galaxis Workloft, Singapore 138523

CHANGES TO THIS POLICY

1. As part of our efforts to ensure that we properly manage, protect and process your Personal Information, we reserve the right to amend the terms of this Policy and any other information contained on this Website, at any time and at its absolute discretion.
2. We encourage you to periodically review this Policy to be informed of how Sentient.io is protecting your Personal Information. By continuing to interact with us, you agree to be bound by the prevailing terms of this Policy, as so updated from time to time.

JURISDICTION

1. All matters relating to the Website including this Policy are governed by the laws of Singapore and you agree to submit to the non-exclusive jurisdiction of the Singaporean courts for settlement of any disputes.
2. Users accessing the Website from locations other than in Singapore must ensure that they are complying with locally applicable laws.