PALUP PRIVACY POLICY

INTRODUCTION AND SCOPE

Welcome to Palup, operated by Playsee Pte. Ltd and its affiliates (“Palup,” “we,” “our,” or “us”) respects the privacy of individuals who visit our informational website located at Palup.ai (“the Site(s)”), use or access our mobile application (the “App(s)”), participate in the subscription plans (the “Plan(s)”), or access any other websites, pages, features, or content owned and operated by us that direct to this Privacy Policy (collectively, including the App and Plan, the “Service(s)”). This Privacy Policy (“Policy”) explains how we collect, use, share your personal information, the rights and choices you may have with respect to your personal information, and how to assert those rights.

By accessing, visiting or using our Services, you acknowledge you have read and understand this Privacy Policy and agree to our User Terms of Service. If you are not comfortable with any part of this Privacy Policy or do not agree with the Terms of Service, please immediately discontinue access or use of our Services.

As we may make changes to this Privacy Policy from time to time, please review the “Last Updated” date at the top of this page to determine when this Privacy Policy was last updated. Any changes to this Privacy Policy will become effective on the “Last Updated” date indicated above. If we make material changes to this Privacy Policy, then we will notify users as required by law. If you have questions about this Policy, how we collect or process your personal information, or anything else related to our privacy practices, please contact us at any time via the method specified in the “Contact Us” section below.

In providing our Services to subscribers to our Enterprise Edition (“Clients”), we may process personal information on behalf and at the direction of the Clients. When we process personal information on behalf of the Clients, Palup is a data processor and the Clients are data controllers. This Policy does not apply to Palup’s processing when it is a data processor. Clients are solely responsible for establishing privacy policies for and ensuring compliance with all applicable laws and regulations, agreements, or other obligations, relating to the processing of personal information collected through our Services embedded on the websites the Clients operate and control (“Client Data”). If you are an individual who has submitted data to a Client through our Services, then the processing of your personal information will be subject to that Client’s privacy practices, and you should directly contact that Client for assistance with any requests or questions relating to the processing of your personal information.

1. PERSONAL INFORMATION WE COLLECT

We collect certain personal information when you use our Services. Personal information, used interchangeably with “personal data,” is typically data that identifies an individual or relates to an identifiable individual. The personal information that we collect depends on your interactions with us and the choices you make.

The definition of personal information depends on the applicable law based on your physical location when we collect your personal information. Only the definition that applies to your physical location will apply to you under this Policy.

Information You Voluntarily Provide. The types of personal information that we, or third-party service providers who assist us in providing our Services, may collect from you include:

• Account Registration. We may collect information relating to the creation of an account, such as your username, password, age, email address, phone number, profile picture and gender. To create and personalize your AI avatar, we may also collect images or photos you upload.
• Plan Subscription. When you subscribe to one of our premium plans for additional services, we may collect certain transaction payment information. We use third parties, such as Stripe, Google Play Store or Apple App Store, to process payments for services you buy when using our Service. For example, when you purchase subscription plans, we receive limited personal information related to the purchase you made (namely, a user identification number, or a purchase receipt from third-party payment services). These third parties act as independent controllers, and any personal information you provide to them, such as your legal name, credit or debit card number, card expiration date, CVV code, and billing address, is not governed by this Policy.
• Avatar Interaction. When you send messages and interact with the AI avatar, we may collect information that you voluntarily share, such as facts you may provide about yourself, your life, and any photos, videos, and voice and text messages you provide. If you voluntarily share any sensitive information through our Services, such as information about your medical, health or mental conditions, we will process this information in accordance with applicable legal and regulatory requirements.
• Interests and Preferences. You may select conversation preferences, such as topics you are interested in, communication preferences, and your Avatar’s personality. We also learn about your interests and your preferences over time through your use of the Services to personalize your conversations and the features of the Services.
• Customer Support. When you engage with our support team and customer service providers, we may collect records, copies of your correspondence (including email addresses and phone numbers), or additional information you choose to share with us.
• Newsletter Sign-ups. If you wish to receive promotional emails from us with news & exclusive contents, you will need to provide us your email address.
• Photos, Videos and Audio. When you upload content from your camera roll, take pictures and/or record your own voice, we may ask you to grant us access to your camera, microphone and/or photos/albums in. When you take these steps, we may collect and process data relating to the photos, videos and audio, such as album names, the videos and photos stored in each album, the time and location the content was created, and the amount of content stored in each album.

Information We Automatically Collect. To the extent permitted under the applicable law, we may automatically collect certain types of personal information about you when you interact with the Services.

• Usage Data. When you browse our Sites, we automatically collect log data such as your web request, Internet Protocol (“IP”) address, browser type, domain names, referring and exit pages and URLs, pages viewed and the order of these page views, the date and time you access our servers, and other diagnostic data.
• Device Information. When you use your desktop or mobile device to access our Services, we may be able to identify your device’s unique device identifier, MAC address, operating system, and your mobile device’s advertising ID.
• Location Information. When you use our Services, we may infer the generic physical location and geographic regions of your device from your Wi-Fi, Bluetooth and other device settings. For example, your IP address may indicate your general geographic region. Upon your permission, we may collect your mobile device’s precise geo-location to find the closest restaurants, activities, hotels, or other places or activities near you. You may choose not to share your location details with us by adjusting your mobile or desktop device’s location services settings. For instructions on changing the relevant settings, please contact your service provider or device manufacturer.

2. HOW WE USE YOUR PERSONAL INFORMATION

We may use your personal information for the following business and commercial purposes, unless restricted by applicable law:

1. To Operate and Administer Our Services.  We use the personal information we gather from you to provide you with our Services that you request, such as creating and managing user accounts, creating your personalized AI avatar, enabling you to have individualized and safe interactions with the AI avatar, and facilitating payments and transactions including for the subscription of premium plans.  
2. To Provide You with Service-Related Communications. We may use your personal information to communicate with you. We may send you administrative or account-related information to keep you updated about your account and our Services. Such communications may include information about updates to this Privacy Policy or the Terms of Service, security updates, tips or other relevant transaction-related information. Service-related communications are not promotional in nature, and thus you are not able to unsubscribe from them.
3. To Provide Customer Support or Respond to You.  We collect any information that you provide to us when you contact us. Without your personal information, we cannot respond to you or ensure your continued use and satisfaction of the Services.
4. To Provide Marketing Communications. If you have voluntarily provided your email address, phone number or other electronic addresses to us when subscribing to our marketing communications, we may email you about features, plans, services or promotions that we believe may be of interest to you. When you no longer wish to receive these marketing messages from us, you can opt out at any time by following the instructions contained in each email you receive from us or contacting us via the methods specified in the “How to Contact Us” section below.
5. To Research and Develop of Our Services.  We may process your personal information and derive analytical and statistical data to better understand the way you use and interact with our Services, to improve and add features to our Services, to conduct research, to train our AI models and for other similar purposes. For instance, we may analyze where, on which types of devices and how our App is used, and how many users we receive to help us improve our existing Services and to build new Services. From time to time, we may analyze the general behavior and characteristics of users of our Services and share de-identified or aggregated information like general user statistics with third parties, publish such de-identified or aggregated information or make such de-identified or aggregated information publicly available. We will maintain and use de-identified information in de-identified form and we will not attempt to re-identify the information unless required by law.
6. To Infer Your Interest and Personalize Your Experience.  We may process your information to personalize your experience. By personalization, we may create new personal information about you by drawing inferences from the personal information identified in Section 1 to reflect your preferences or interests. We may use such information to enable you to interact with our Services more easily across devices, or to recommend more relevant content to you.
7. To Facilitate Corporate Acquisitions, Mergers and Transactions. We may process any information regarding your account and your use of our Services as is necessary in the context of corporate acquisitions, mergers or other corporate transactions.
8. To Enforce Compliance with Our Terms, Agreements and Policies.  When you access or use our Services, you are bound to our Terms. We may process your personal information when actively monitoring, investigating, preventing and mitigating any alleged or actual prohibited, illicit or illegal activities on our Services. We may also process your personal information to investigate, prevent or mitigate violations of our internal terms, agreements or policies; enforce our agreements with third parties; recover payments due to us; and protect our and others’ rights, privacy, safety, or property.
9. To Ensure the Security of the Services.  We may process your personal information to combat spam, malware, malicious activities or security risks; improve and enforce our security measures; and to monitor and verify your identity so that unauthorized users do not gain access to your information.
10. To Maintain Legal and Regulatory Compliance.  Our Services are subject to certain laws and regulations which may require us to process your personal information. For example, we process your personal information to pay our taxes, to fulfill our business obligations, or as necessary to manage risk as required under applicable law, or to respond to requests by judicial process or governmental agencies.
11. With Your Consent.  For any other purpose disclosed to you prior to you providing us your personal information or which is reasonably necessary to provide the services or other related services requested, with your permission or upon your direction.

3. HOW WE DISCLOSE YOUR PERSONAL INFORMATION

We may disclose your personal information as described below:

1. Within Our Corporate Organization.  We may share some or all of your personal information with our subsidiaries and corporate affiliates, joint ventures, or other companies under common control with us as permitted by the applicable law.
2. With Our Service Providers.  We may disclose your personal information to our contractors, affiliates, distributors and suppliers (“Service Providers”) who provide certain services to us or on our behalf, such as fulfilling orders you place through the Services, processing payments, operating and supporting the Services, analyzing data, or performing marketing or consulting services. These Service Providers will only have access to the information needed to perform these limited functions on our behalf.
3. To Respond to Subpoenas or Court Orders or to Protect Rights and to Comply with Our Policies.  We may disclose personal information to government authorities or third parties if: (a) required to do so by law, or in response to law enforcement requests and legal processes, such as a subpoena or court order; (b) comply with requests from auditors, examiners or other regulators; (c) we believe in our sole discretion that disclosure is reasonably necessary to protect against fraud, to protect the property or other rights of us or other users, third parties or the public at large; or (c) we believe that you have abused the Services by using it to attack other systems or to gain unauthorized access to any other system, to engage in spamming or otherwise to violate applicable laws. You should be aware that, following disclosure to any third party, your information may be accessible by others to the extent permitted or required by applicable law.
4. During Business Transfers; Bankruptcy.  In the event of a merger, acquisition, bankruptcy or other sale of all or a portion of our assets, any personal information owned or controlled by us may be one of the assets transferred to third parties. We reserve the right, as part of this type of transaction, to transfer or assign personal information and other information we have collected from users of the Services to buyers, service providers, advisors, potential transactional partners or other third parties in connection with the advisors, potential transactional partners or other third parties of a corporate transaction. Other than to the extent ordered by a bankruptcy or other court, the use and disclosure of all transferred user information will be subject to this Privacy Policy. However, any information you submit or that is collected after this type of transfer may be subject to a new privacy policy adopted by the successor entity.
5. With Our Business Partners. When you subscribe to one of our premium plans, we may disclose your personal information with our business partners to facilitate service requested by you through interaction with the Avatars, such as order placement, reservation booking, and other services initiated and authorized by you.
6. With Your Consent.  We may share your personal information with other companies if you give us permission or direct us to share your information.

4. COOKIES AND OTHER TRACKING TECHNOLOGIES

We and our service providers may automatically collect information about you when you use the Site using “cookies” and other similar technologies, such as web beacons (“Tracking Technologies”), to personalize your experience with our Services. We and third-party businesses on our behalf, may use Tracking Technologies to help us customize your experience and better manage content on our Sites.

Cookies are small amounts of data that are stored within your computer’s Internet browser and accessed and recorded by the websites that you visit so that they can recognize the same browser navigating online at a later time. Information that may be collected by cookies when you use the Site may include, without limitation: the pages you visit within the Site; the date and time of your visit to the Site; the amount of time you spend using the Site; the IP address used to connect your computer to the Internet; and/or your computer and connection information such as your browser type and version, operating system and platform.

Generally, we use first-party and third-party cookies for the following purposes: to make our Services function properly; to provide a secure browsing experience during your use of our Services; to collect passive information about your use of our Services; to measure how you interact with our marketing campaigns; to help us improve our Services; and to remember your preferences for your convenience.

California Do Not Track.  Some web browsers incorporate a “Do Not Track” feature that signals to websites you visit that you do not want to have your online activity tracked. How browsers communicate the Do Not Track signal is not yet uniform. For this reason, our Site does not respond to such signals.

For opting out of cookies, see the “Managing Cookies” in Section 6(c) below.  

5. THIRD PARTY LINKS AND CONTENT

Please note that this Policy only applies to the Palup Service, and not to website, applications, operating systems, or other platforms of third parties (collectively, “Third-Party Platforms”), even if such Third-Party Platforms are linked to or accessible from the Service. Each Third-Party Platform will have its own data collection and usage practices, and may use their own cookies, web beacons, and other technology to collect information from you. Palup is not responsible for the content or practices of any Third-Party Platforms and, if you choose to visit or use them, you do so at your own risk.

6. YOUR CHOICES

We offer you certain choices about how we communicate with you and manage what personal information we collect from you.

1. Correct or Update Your Information

If you have created a user account through the Services, you will have the ability to access, update and correct the personal information you have provided in connection with your account by logging into your account through the Services. If you do not have an account and would like to request to correct or update your personal information that we have collected or has been previously provided to us, please contact us as described in the “How to Contact Us” section.

To protect your privacy, we must be able to verify your identity to confirm that the request came from you before we can process your request. We may contact you by phone or e-mail to verify your request. Depending on your request, we will ask for information such as your name, an email address or a phone number you have used with Palup.

2. Marketing Communications

We offer you certain choices about how we communicate with you. To update your preferences, limit the communications you receive from us, please contact us as specified in the “How to Contact Us” section at the end of this Privacy Policy. Where provided by law, you may withdraw your consent previously provided to us, and we will apply your preferences going forward. You can also choose not to receive marketing communications from us by clicking on the unsubscribe link in our marketing content.

3. Managing Cookies

You have the right to decide whether to accept cookies. If you do not want us to deploy cookies in your browser, you may modify your web browser setting to refuse some or all cookies or to notify you and ask for your permission when a website tries to set a cookie. If you want to learn how to modify your browser settings, please use the “Help,” “Tools” or “Edit” menu in your browser or review the instructions provided by the following browsers: Microsoft Edge, Google Chrome, Mozilla Firefox, Safari Desktop, Safari Mobile; and Android browser. If you block or delete technical and/or function cookies used by our Sites, the Sites may become impossible to browse, certain services or functions of the Sites may become unavailable or other malfunctions may occur. In this case, you may have to modify or manually enter some information or preferences every time you visit the Sites.

Analytics. We may use third-party service providers to monitor and analyze the use of our Sites, such as Google Analytics. Google Analytics is a web analytics service offered by Google LLC (“Google”) that tracks and reports website traffic. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics, available at: https://tools.google.com/dlpage/gaoptout.

7. CHILDREN

Our Services are not intended for persons under the age of 13. We do not knowingly collect or distribute personal information that we collect directly from children. If you are a parent or guardian and wish to review information collected from your child, or have that information modified or deleted, you may contact us via the method identified in the “How to Contact Us” section below. If we become aware that a child has provided us with personal information, we will terminate the user’s access to our Service and take steps to delete such information from our systems, unless we have a legal obligation to keep it.

8. RETENTION

We will retain your information for as long as your account is active, as needed to provide you Services or for other purposes stated in this Policy. We will cease to retain your personal information or remove the means by which the personal information 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 information was collected and is no longer necessary for legal or business purposes. If you wish to cancel your account or request that we no longer use your information to provide you services, please contact us via the method identified in the “How to Contact Us” section below. We may still retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

9. SECURITY OF YOUR PERSONAL INFORMATION

We implement security measures intended to protect against the loss, misuse and alteration of the personal information under our control. While we use reasonable commercial efforts to protect the data, no technology, data transmission, or system can be guaranteed to be 100% secure. We cannot guarantee the security of our databases or the databases of the third parties with which we may share such information, nor can we guarantee that the information you supply will not be intercepted while being transmitted over the internet. Please remember that you play a valuable part in security as well. If you feel that the security of any account you might have with us has been compromised, you should contact us immediately as described in the “How to Contact Us” section.

10. ADDITIONAL NOTICE TO INDIVIDUALS IN THE EUROPEAN ECONOMIC AREA, THE UNITED KINGDOM, AND SWITZERLAND

This section only applies to individuals using or accessing our Service while located in the European Economic Area, the United Kingdom, or Switzerland (collectively, the “European Countries”) at the time of data collection pursuant to the European Union’s General Data Protection Regulation, the UK General Data Protection Regulation or the Swiss Data Protection Act (collectively, the “GDPR”).

We may ask you to identify which country you are located in when you use or access some of the Services, or we may rely on your IP address to identify which country you are located in. When we rely on your IP address, we cannot apply the terms of this section to any individual that masks or otherwise hides their location information from us so as not to appear located in European Countries. If any terms in this section conflict with other terms contained in this Policy, the terms in this section shall apply to individuals in a European Country.

Our Relationship to You. The controller for the processing described in this Privacy Policy is: Playsee Pte. Ltd, 12 MARINA VIEW, #12-05, ASIA SQUARE TOWER 2, SINGAPORE, and you can contact our privacy office at privacy@palup.ai. 

Legal Bases for Processing Your Personal Data

Your Privacy Rights

• Right to access. You may have the right to obtain a copy of your personal data that we hold about you, as well as other supplementary information, such as the purposes of processing, the categories of personal data that we process, the entities to whom we disclose your personal data, etc.
• Right to rectification. You may have the right to request us to correct any of your personal data in our files.
• Right to erasure. Under certain circumstances, you may have the right to request erasure of your personal data that we hold about you. To note, this right is not absolute, and we may refuse your right to erasure if there are compelling legitimate grounds for keeping your information.
• Right to restriction. You have the right to request that we restrict our processing of your personal data in certain circumstances. For instance, this right is available if you contest the accuracy of the personal data, or if you objected to our processing.
• Right to object to processing. You have the right to object to our processing of your personal data at any time and as permitted by applicable law if we process your personal data on the legal bases of consent or legitimate interests. However, we may continue to process your personal data if it is necessary for the defense of legal claims, or for any other exceptions permitted by applicable law.
• Right to portability. Under circumstances, you may have the right to receive personal data we hold about you in a structured, commonly used, and machine-readable format so that you can provide that personal data to another controller.
• Right to Lodge a Complaint. If you reside in the European Countries, you may have the right to lodge a complaint with a supervisory authority or equivalent regulatory body. Contact details for data protection authorities in the European Economic Area are available here, and contact details for the United Kingdom’s ICO are available here.

Submitting a Request to Exercise Your Privacy Rights  

To assert your privacy rights noted above, you may email us at privacy@palup.ai. To protect your privacy, we must be able to verify your identity to confirm that the request came from you before we can process your request to exercise any of the privacy rights that you may be entitled to under the applicable law. We may contact you to verify your request. Depending on your request, we will ask for information such as your username, an e-mail address, or a phone number you have used with us.

International Transfer of Your Personal Data

We rely primarily on the European Commission’s Standard Contractual Clauses to facilitate the international and onward transfer of personal data collected in the European Economic Area (“EEA”), the United Kingdom and Switzerland (collectively “European Personal Data”), to the extent the businesses receiving he European Personal Data are in a country that the European Countries consider to not provide an adequate level of data protection. We may also rely on an adequacy decision of the relevant regulatory body confirming an adequate level of data protection in the jurisdiction of the party receiving the information, or derogations in specific situations.

11. HOW TO CONTACT US

If you have any questions or complaints regarding this Privacy Policy, please contact us by sending an email to privacy@palup.ai.