Privacy Policy

ChatGiraffe our affiliated companies (hereinafter referred to as "we"). We respect your privacy and are committed to safeguarding the security of any information we obtain from you or about you. This Privacy Policy outlines our practices regarding the collection of personal information about you when you use our website, applications, and services (collectively referred to as the "Services") in accordance with the Singapore Personal Data Protection Act ("PDPA") and the European Union General Data Protection Regulation ("GDPR"). Both the GDPR and PDPA are deemed to have extraterritorial effect. Therefore, the GDPR also applies to non-EU/EEA data controllers that offer their services to data subjects within the EU or EEA, and the PDPA applies to non-Singaporean data controllers that offer services within Singapore.

I. Personal Information We Collect

We collect personal information related to you ("Personal Information") in the following ways:

(I) Personal Information You Voluntarily Provide

If you create an account to use our Services or communicate with us, we will collect the following Personal Information:

• Account Information: When you create an account on our platform, we will collect information associated with your account, which may include your name, contact details, and account credentials (collectively referred to as "Account Information").
• User Content: When you use our Services, we will collect Personal Information contained in the input content, uploaded files, or feedback you provide to the Services (hereinafter referred to as "Content").
• Communication Information: If you communicate with us, we will collect your name, contact details, and the content of any messages you send (hereinafter referred to as "Communication Information").

(II) Personal Information Automatically Obtained When You Use the Services

When you visit, use, or interact with the Services, we will obtain the following information about your visiting, using, or interacting activities (hereinafter referred to as "Technical Information"):

• Log Data: Information automatically sent by your browser when you use our Services. Log Data includes your Internet Protocol (IP) address, browser type and settings, the date and time of your request, and how you interact with our website.
• Usage Data: We may automatically collect information about your use of the Services, such as the types of content you view or interact with, the features you use and the actions you take, as well as your time zone, country of residence, access dates and times, user agent and version, type of computer or mobile device, and your computer connection status.
• Device Information: Includes the device name, operating system, device identifiers, language and time zone settings, and the browser you use. The information collected may vary depending on the type of device you use and its settings.
• Cookies: We use Cookies to operate and manage the Services and improve your user experience. A "Cookie" is a piece of information sent by a website you visit to your browser. You can set your browser to accept all Cookies, reject all Cookies, or notify you when a Cookie is offered, allowing you to decide whether to accept it each time. However, please note that in some cases, rejecting Cookies may prevent you from using the website or adversely affect the display or functionality of the website (including specific areas or features of the website). For more details about Cookies, please visit the "All About Cookies" website.
• Analytics Data: We may use a variety of online analytics tools (which operate via Cookies) to help us analyze how users use the Services and enhance your experience when using the Services.

(III) Personal Information Obtained from Third Parties

If you register or log in to our Services using a third-party account (such as Google, Apple, etc.), we may obtain the following specific information (hereinafter referred to as "Third-Party Information"):

• Profile Information: We will obtain profile information from your third-party service provider, which may include your name, email address, profile picture, and other information you choose to make public on the third-party platform.
• Usage Data: We may automatically collect information about your use of the Services in connection with your third-party account, such as the types of content you view or interact with, the features you use and the actions you take, as well as your time zone, country of residence, and language preferences. We use this data to improve the Services, provide personalized recommendations, and enhance your overall user experience.

II. How We Use Personal Information

We may use Personal Information for the following purposes:

1. To provide, manage, maintain, and/or analyze the Services;
2. To improve the Services and conduct research;
3. To communicate with you;
4. To develop new programs and services;
5. To prevent fraud, criminal activities, or abuse of the Services, and to protect the security of our information technology systems, infrastructure, and networks;
6. To conduct business transfers;
7. To comply with legal obligations and legal procedures (including responding to requests from regulatory authorities) and to protect the rights, privacy, safety, or property of us, our affiliated companies, you, or other third parties.

(I) Aggregated Information or De-Identified Information

We may aggregate or de-identify Personal Information so that it can no longer be used to identify you, and use such information to analyze the effectiveness of the Services, improve the Services and add new features, conduct research, and for other similar purposes. In addition, we may from time to time analyze the overall behavior and characteristics of users of the Services, and share aggregated information (such as overall user statistics) with third parties, publish such aggregated information, or make such aggregated information available to the public. We may collect aggregated information through the Services, Cookies, and other methods described in this Privacy Policy. We will store and use de-identified information in an anonymous or de-identified form and will not attempt to re-identify such information (unless required by law).

(II) Enhancing Your User Experience

As mentioned above, we may use the Content you provide to improve the Services, products, marketing activities, and your user experience. We may use information obtained from Google APIs to show you relevant content from your emails and calendars. ChatGiraffe's use of information obtained from Google APIs and its transfer to any other application will comply with the Google API Services User Data Policy, including the "Limited Use" requirements.

III. Disclosure of Personal Information

Under certain circumstances, we may provide your Personal Information to third parties without further notice to you (unless required by law):

• Vendors and Other Third-Party Service Providers: We may share your data with third-party vendors, service providers, contractors, or agents who provide services for us or on our behalf and need access to such information to perform their work. Examples include: calendar management, payment processing, data analysis, email delivery, hosting services, customer service, and marketing-related service providers. We may allow selected third parties to use tracking technologies on the Services, enabling them to collect data on our behalf regarding how you interact with the Services over time. Such information may be used, among other things, to analyze and track data, determine the popularity of specific content, pages, or features, and better understand online activities. Unless otherwise stated in this Policy, we will not share, sell, rent, or trade any of your information with third parties for their promotional purposes.
• Business Transfers: If we are involved in strategic transactions, reorganizations, bankruptcies, receiverships, or the transfer of services to another provider (collectively referred to as a "Transaction"), your Personal Information and other information may be shared with counterparties and other parties assisting in the Transaction during the Transaction process, and will be transferred to a successor or affiliated company together with other assets.
• Legal Requirements: If required by law, or if we have a reasonable belief that such action is necessary, we may share your Personal Information (including information about your interactions with the Services) with government authorities, industry peers, or other third parties in the following situations: (1) complying with legal obligations; (2) protecting and defending our rights or property; (3) when we determine in our sole discretion that there is a violation of our terms, policies, or laws; (4) detecting or preventing fraud or other illegal activities; (5) protecting the safety, security, and interests of our products, employees, users, or the public; (6) avoiding legal liability.
• Affiliated Companies: We may disclose Personal Information to our affiliated companies (entities that control ChatGiraffe, are controlled by ChatGiraffe, or are under common control with ChatGiraffe). Our affiliated companies may use the Personal Information we share in accordance with the provisions of this Privacy Policy.

IV. Use Based on the "Legitimate Interests" Exception

(I) In accordance with the guidelines specified in the PDPA and GDPR, ChatGiraffe has the right, in specific circumstances and without obtaining your explicit consent, to collect, use, or disclose your Personal Information based on the legitimate interests of ChatGiraffe or other parties. In this process, ChatGiraffe will conduct a careful assessment to ensure that the potential adverse impacts on individuals are fully weighed against the prevailing legitimate interests.

(II) Pursuant to the "Legitimate Interests" exception, your Personal Information may be used for the following purposes:

1. Identifying and preventing fraudulent activities;
2. Detecting and preventing abuse of the Services;
3. Conducting network analysis to prevent fraud and financial violations, and performing credit assessments;
4. Obtaining and using Personal Information on company-provided devices to prevent data breaches;
5. Providing services to customers;
6. Complying with legal requirements, such as anti-money laundering and anti-terrorism regulations;
7. Understanding and enhancing the customer experience;
8. Recruiting and retaining suitable employees;
9. Protecting the security of systems and premises, and preventing cyber threats.

Even if your cooperative relationship with us (such as a contractual relationship) has been terminated or changed, the aforementioned purposes will remain valid for a reasonable period thereafter.

V. Your Rights

Depending on your location, individuals in the European Economic Area (EEA), the United Kingdom, Singapore, and other regions around the world may have certain statutory rights regarding their Personal Information. For example, you may have the right to:

(I) Access and Correct Your Personal Information

1. If you wish to request access to or correction of your Personal Data, please contact us via email at yueancheng8@gmail.com (using the provided contact information).
2. Any applicable fees related to access requests will be notified to you before processing.
3. We will respond to your request as promptly as possible. If we are unable to respond within 30 days, we will notify you in writing. If we are unable to fulfill your request, we will generally provide reasons (unless otherwise specified by the PDPA and GDPR).

(II) Request Us to Delete Your Personal Information from Our Records in the Following Circumstances

1. The data is no longer necessary;
2. You have withdrawn your consent to the use of the data, and there are no other legitimate reasons to continue using it;
3. The processing of the data is illegal;
4. The data needs to be deleted to comply with legal obligations;
5. You object to the processing of the data, and there are no overriding legitimate grounds to support continued processing.

(III) Transfer Your Personal Information to a Third Party (Right to Data Portability).

(IV) Restrict How We Process Your Personal Information.

(V) Withdraw Your Consent

1. Your authorization for us to collect, use, and disclose your Personal Data will remain valid until you withdraw it in writing. You may withdraw your consent by contacting us via email at yueancheng8@gmail.com.
2. After receiving your written withdrawal request, we will process it within a reasonable period.
3. Please note that withdrawing your consent may affect our ability to provide goods or services to you. We will notify you before making any changes.
4. Withdrawing your consent does not affect our legal right to collect, use, and disclose Personal Data where permitted or required by law.

(VI) Object to How We Process Your Personal Information.

(VII) Lodge a Complaint with a Local Data Protection Authority.

You may exercise some of the above rights through your ChatGiraffe account. If you are unable to exercise your rights through your account, please send your request to yueancheng8@gmail.com. To protect your Personal Information from unauthorized access, modification, or deletion, we may require you to verify your identity credentials before you submit a request to inquire about, correct, or delete your Personal Information. If you do not have an account on our platform, or if we suspect fraudulent or malicious activities, we may request you to provide additional Personal Information and proof of residence to verify your identity. If we cannot verify your identity, we will be unable to fulfill your request.

VI. Protection of Personal Data

We take a variety of measures to protect your Personal Data from unauthorized access or abuse, including limiting the scope of data collection, password protection, encryption technology, antivirus software, regular updates, secure disposal of storage media, web security protocols, and additional authentication methods such as one-time passwords or multi-factor authentication. Although we will continuously review and enhance our security measures, please note that no data transmission or storage method is absolutely secure.

VII. International Transfer of Data

The data we collect from you may be transferred to and stored at locations both within and outside Singapore. We ensure that your Personal Data is stored and transferred in a secure manner. Therefore, we will only transfer data outside Singapore if it complies with data protection regulations and the transfer method can provide adequate safeguards for your data in accordance with the PDPA and GDPR. We will take all reasonable measures to ensure that your data is processed securely and in accordance with the provisions of this Privacy Policy.

VIII. Provisions Regarding Children

This Service is intended for general users. If a minor intends to use our Services and provide Personal Information, they must do so with the consent of their guardian. You represent and warrant that you have the capacity to act and the legal capacity required to use our Services. If you are a minor, you represent and warrant that you are using our Services with the consent of your guardian. In cases where we cannot confirm whether you have reached a specific age, we have voluntarily set age restrictions on some Services. We are well aware of the importance of protecting Personal Information provided by minors (under the age of 13 in the United States, under the age of 16 in Europe, and under the age of 11 in Thailand) within the United States, Europe, or Thailand when they use our Services, and we will not intentionally collect any Personal Information from minors.

However, if you believe that we have collected Personal Information from minors in the aforementioned countries or regions, please contact us via email at yueancheng8@gmail.com. If we discover that we have inadvertently collected Personal Information from minors in the aforementioned countries or regions, we will deactivate the relevant accounts and take reasonable measures to immediately delete such Personal Information from our records.

IX. Links to Other Websites

This Service may contain links to other websites not operated or controlled by ChatGiraffe, including social media services (hereinafter referred to as "Third-Party Websites"). The information you share with Third-Party Websites will be governed by the specific privacy policies and terms of service of the Third-Party Websites, rather than this Privacy Policy. Our provision of these links does not imply that we endorse or have reviewed such websites. For information about the privacy practices and policies of Third-Party Websites, please contact the relevant Third-Party Website directly.

X. Security and Retention

We adopt commercially reasonable technical, administrative, and organizational measures to protect Personal Information (whether online or offline) from loss, abuse, and unauthorized access, disclosure, modification, or destruction. However, please note that Internet or email transmission is not absolutely secure or error-free. In particular, emails sent to or received from us may not be secure. Therefore, you should exercise extra caution when deciding what information to send to us via the Service or email. In addition, we are not liable for any acts that circumvent the privacy settings or security measures in the Service or on third-party websites.

We will only retain your Personal Information for the period necessary to provide the Service to you, or for other legitimate business purposes (such as resolving disputes, ensuring security, or complying with legal obligations). The period for which we retain Personal Information depends on a variety of factors, including the quantity, nature, and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure, our purpose for processing the information, and relevant legal requirements.

XI. Changes to the Privacy Policy

We may update this Policy from time to time. After the update, we will post the revised version of the Policy on this page (unless applicable law requires another form of notification). If you do not agree to any changes and no longer wish to use our Services, you may choose to cancel your account. Your continued use of the Services after a change notice has been notified to you or posted on the Services indicates that you accept such changes and agree to the revised version of this Policy. We will obtain your consent if required by applicable law.

XII. Contact Us

If you have any questions or suggestions about our Privacy Policy, please feel free to contact us via email at yueancheng8@gmail.com.

XIII. Acknowledgment and Consent

By visiting our website, accessing or using any of our products, services, information, content, features, or premises, you confirm that you have read and understood this Privacy Policy and accept the practices and terms specified in this Privacy Policy.

To comply with applicable data protection laws (including the PDPA and GDPR), you also consent to our collection, use, disclosure, sharing, and other processing of your Personal Data in accordance with the provisions of this Privacy Policy.