We appreciate that you trust us with your information, and we intend to always keep it that way. We want to make sure that you are aware of and understand the information we collect, why we collect it, how it is used and your choices regarding your information provided. This document may be updated at any time without notice.

1. INTRODUCTION

1.1. YouApp (“YouApp”) is a social networking app with financial features, provided by YouApp Pte. Ltd. 

1.2. This Privacy Policy establishes the basis which we may collect, use, disclose or otherwise process Users’ Personal Data. This Privacy Policy applies to Personal Data in our possession or under our control, including Personal Data in the possession of organisations which we have engaged to collect, use, disclose and/or process Personal Data for our purposes.

1.3. This Privacy Policy is applicable to all Users. If you choose to use our Products or Services, you consent to the collection, use and disclosure of your Personal Data by us for the purposes as set out herein. 

1.4. Some Products and Services may require their own unique privacy policy. If a unique privacy policy applies in respect of any Product or Service, then that policy supersedes this current Privacy Policy.

2. DEFINITIONS

2.1. In this Privacy Policy:

• • “Data Protection Laws” means any applicable law relating to the protection, privacy and security, collection, use, disclosure and/or processing of sensitive or other personally identifiable information, including the PDPA.
  • “Personal Data” means all data, whether true or not, about an individual who can be identified (a) from that data, or (b) from that data and other information which we have or are likely to have access to.
  • “PDPA” means the Personal Data Protection Act 2012 of Singapore. 
  • “PDPC” means the Personal Data Protection Commission of Singapore.
  • “Products” means products provided by us, including without limitation the YouApp.
  • “Services” means the websites, apps, events, and other services provided by us, including without limitation services provided on or through our Products. 
  • “User” means an individual who (a) interacts with us (including without limitation by using any of our Services or Products); (b) submits any information (including without limitation any Personal Data) to us; (c) has contacted us through any means to find out more about any of our Products or Services, or (d) may or has, entered into a contract with us for the supply of any Products or Services.
  • The words “we”, “us”, or “our” means YouApp Pte. Ltd. 
  • The words “you”, “your” or “yours” means the Users or persons to whom this Privacy Policy applies. 

2.2. For the avoidance of doubt, in the event that Data Protection Laws permits us to collect, use, disclose and/or process your Personal Data without your consent, such permission granted by the law shall continue to apply.

3. PERSONAL DATA WE COLLECT

It goes without saying that it would be impossible for us to provide our Products or Services to you or help you develop meaningful connections without collecting, using and storing some of your personal information, such as basic profile details and the types of people you would like to meet. We also collect information about your use of our Products and Services, such as access logs, as well as information from third parties. For example, when you gain access to our Services via your social media account, or when you upload information from your social media account to complete your profile on YouApp, some information from those social media accounts will be collected to ease your signup process. A further explanation on this can be found below:

3.1. Personal Data you provide / Personal Data collected directly from Users

Personal Data is collected directly from Users as far as possible. Depending on which Services you choose and how you interact with us, we may require and collect various types of Personal Data from you, which includes without limitation the following:

• • Account Data/ Login credentials: When you create an account, you provide us with your login credentials and/or phone number, as well as some basic details necessary for us to provide the Services, such as your name, gender, and email address. 
  • Profile Data: When you complete your profile, you share additional information about yourself, such as  details on your age, personality (including without limitation by completing personality tests or questionnaires), lifestyle, interests, photos, occupation, school, current city, approximate location, etc. To add certain content, such as pictures for display purposes, you are required to provide us with access to your camera or photo album. 
  • Contact List information: We collect information about your friends, followers, groups, accounts and other Users and communities that you are connected to and whom you interact with. This includes information about how you interact with them across our Products and Services, and which ones you interact with the most.  We also collect your contacts’ information, such as their name and email address or phone number, if you choose to upload or import such information from a device or by sharing the information with us. Your Contact List Information is securely stored and used solely for the purpose of facilitating connections and invites to your Contact List by your request. The Contact List information is not utilized for marketing purposes nor shared with any other User (unless you otherwise provide your consent to us for this purpose). Our commitment is to maintain the confidentiality and security of your data, ensuring a trustworthy and respectful user experience.
  • Payment and Financial Information: We collect payment and financial information such as but not limited to your debit or credit card number or bank account details, which you provide to us or our payment service providers when using our Services. We also collect details of the transaction such as your purchases, the date of the transaction and the price. 
  • Marketing, Survey and Research Data: When you participate in our: (i) surveys, focus group discussions or market studies; (ii) promotions events or contests, we collect your personal information, insights on our Products and Services, responses to our questions, opinions, testimonials and feedback. 
  • Individual/ Business Account Verification Information: We collect your individual/ business account verification information which you provide to us for the purposes of unlocking merchant features to facilitate payment and withdrawals.
  • Customer Support Data: When you contact and/or interact with us, for example, through our customer care team on our website or App, or on social media, we will gather the information you provide to us during such interactions and such information as necessary to help address your inquiry. Other persons or Users may also submit queries or reports involving you. Our moderation tools and teams can also collect additional data about you as part of their investigations. 
  • Content Data: When you use our Services, we collect information about: 

1. 1. 1. content that you create, upload and/or publish, such as posts, photos, videos, audio, text, and other types of content on our platforms; 
      2. content that you provide through our camera feature or your camera roll settings, or through voice-enabled features; 
      3. messages that you send and receive to other Users, including their content, subject to applicable law.

• • Third Party Data: When you share information with us about other people (for example, if you use the contact details of someone you know, a friend or a contact of yours for a given feature, or if you submit a query or report involving a User), we process this information on your behalf in order to complete your request. 

If you submit any Personal Data relating to a third party to us, you are representing to us that you have obtained the consent of the third party to you providing us with their Personal Data for the respective purpose (save where it relates to a query or report about such third party). 

3.2. Information received from others

In addition to the Personal Data you have provided to us or which we collect from you directly, we also receive and collect information related to you from third parties, including without limitation:

1. Other User Data: We may collect information about you: 

1. • from other Users, including from the interaction between you and other Users; or 
   • if other User(s) provide information about you when they use our Products and Services, or if they submit(s) a report against you; or 
   • by making inferences about you based on others’ usage of and activity on the Products and the Services. 
2. Third Party Social Media Accounts / Networks: We collect your information when you choose to share the data with us through your accounts on other social media applications, websites, platforms, or networks (including but not limited to Facebook, Instagram, X, Tik Tok, Douyin, LinkedIn, Xiaohongshu). For instance, if you choose to create or log into your YouApp account via your social media or other accounts, we will collect information available on your social media or other accounts which you choose to share with us.
3. Other Partners: We may receive information about you from our partners, for instance, where there is publication of YouApp’s advertisement on a partner’s service (in which case they may pass along details on a campaign’s success). If in compliance with Data Protection Laws and where legally allowed, we can also receive information about suspected or convicted bad actors from third parties as part of our efforts to ensure our Users’ safety and security. 

3.3. Information generated or automatically collected when you use our Services

When you use our Products and Services, this generates technical data, which are collected by us, including without limitation:

1. Usage Information: We collect information about your activity and usage of our Products and Services, including without limitation: 
   • how you use the Products and Services, features you have been using, the type of information being shown to you, webpages, addresses, advertisements and third party sites that you have interacted with; 
   • your interactions with other Users, such as Users you connect and interact with, when you interacted with them, the number of messages you send and receive; and
   • groups or communities you participate in through our Products and Services.
2. Device Information: We collect information from and about the device(s) you use to access our Products and Services, including without limitation hardware and software information such as IP address, device ID and type, app settings and characteristics, application crashes, advertising IDs (which are randomly generated numbers that you can reset at your device’s settings), identifiers associated with cookies or other technologies that may uniquely identify a device or browser. 
3. Cookies and Similar Technologies: When you use our Products or Services, we may collect Personal Data from you automatically by using data collection technologies (“cookies”). 

3.4. Other information requiring your consent 

With your consent, we may collect the following information:

1. Geolocation Data: your precise geolocation (latitude and longitude). The collection of your geolocation may occur in the background even when you are not using the Products or Services, if you grant express permission of such collection. If you decline permission, certain features of our Products or Services which rely on precise geolocation may not be available to you. 
2. Personal Data from MyInfo: For your convenience, you may be prompted to pull your data from your MyInfo account. By enabling us to pull your data from MyInfo, you are deemed to have consented and agreed to us accessing, using and collecting your MyInfo data (including without limitation data you supply us or to the Government of Singapore or any Singapore public sector agency from your MyInfo account,  such as but not limited to your NRIC Number / FIN, mobile number, marital status, etc.). For the avoidance of doubt, “Singapore public sector agencies” shall have the meaning ascribed to it in the Public Sector (Governance) Act 2018 of Singapore.
3. Biometrics Data: Subject to Data Protection Laws, when you sign up for an account with us and when you use our Services, we may collect biometric information such as images, scans, video, audio, thermal and olfactory data and other biometric information including through facial recognition, liveness detection, anti-spoofing or other similar technology for the purposes of identity verification. 

3.5. “Sensitive personal data” or special categories of information 

1. Under certain applicable Data Protection Laws in certain jurisdictions, such as the European Union General Data Protection Regulation (“GDPR”), “sensitive personal data” may include information about one’s race, ethnicity, religion or health.
2. If you opt to share with us any information which is considered “special” or “sensitive” in certain jurisdictions, you are taken to have consented to our collection, use, disclosure and processing of such information in accordance with this Policy. 

Users have the right to choose whether to provide their Personal Data when using our Products and Services. However, if you choose to opt out of providing your personal information, certain functionality or features within YouApp may be limited or unavailable, and we may not be able to provide you the requested Products or Services.

4. CONSENT AND WITHDRAWAL OF CONSENT

4.1. Generally, we will not collect your Personal Data unless: 

• • it is provided to us voluntarily by you directly or through a third party who has been duly authorised by you to disclose your Personal Data to us (your “Authorised Representative”) after: 

1. 1. 1. you (or your Authorised Representative) have been notified of the purposes for which the Personal Data is collected; and 
      2. you (or your Authorised Representative) have provided written consent to the collection and usage of your Personal Data for those purposes; or 

• • the collection and use of Personal Data without your consent is permitted or required by Data Protection Laws or other applicable laws. 

If you do not or are unable to provide your consent for the collection, use or disclosure of your Personal Data, we may not be able to provide the Products and /or Services and certain features of our Products and Services may not be available to you. Please note that your consent to our collection, use, disclosure and/or processing of your Personal Data will remain valid until such time it is being withdrawn by you in writing.

4.2. If you wish to withdraw your consent to the collection, use or disclosure by us of certain “sensitive personal data”, you may revoke your consent by adapting your settings (for instance, in relation to the collection of your precise geolocation), or by deleting your content (for instance, where you entered information in your profile that may be considered “special” or “sensitive”). 

4.3. In any event, you have the full right to withdraw your consent for us to collect, use, disclose and/or process your Personal Data at any given time by changing your settings or by reaching out to us. If you wish to do so, you may send your consent withdrawal request in writing via email to our Data Protection Officer at the contact details provided below.

4.4. Whilst we respect your decision to withdraw your consent, please note that depending on the nature and scope of your request, we may no longer be able to continue providing certain Products and/or Services or features of such Products and/or Services to you, without the necessary Personal Data required for the operation of the Product or Service. In such circumstances, we shall notify you before completing the processing of your request. 

4.5. Please note that your withdrawal of consent does not affect our right to continue collecting, using, disclosing and/or processing your Personal Data where doing so without consent is permitted or required under applicable laws.

5. COLLECTION AND TRANSFER OF DATA OUTSIDE THE EEA

5.1. We may collect Personal Data from Users located in the European Economic Area (“EEA”) as out lined above. To facilitate the Products and Services we provide to Users located in the EEA, we request explicit consent for the transfer of Personal Data from the EEA to outside of the area. 

5.2. If you are an individual located in the EEA and you decline to consent to such a transfer, you will no longer be able to use our Products and our Services. 

5.3. You may still withdraw your digital assets, however all other functionalities on the YouApp will be disabled.

6. PURPOSES FOR WHICH WE USE / PROCESS YOUR PERSONAL DATA

6.1. The main reason we use and process Users’ Personal Data is to communicate with Users and to provide, administer, deliver, improve, and personalise our Services for Users, for example personalising features and content for Users.

6.2. Apart from the statutorily provided situations in which Personal Data may be collected, used or disclosed without consent, generally, we may collect, use and/or disclose Personal Data for any one or more of the following purposes and any purposes reasonably related and/or ancillary to any of the below-mentioned purposes: 

• • create and maintain your account and profile on our Products or Services; 

• • for identification and verification, including without limitation to verify your identity and eligibility to be a member and/or create an account with us; 

• • communicate with you with regard to our provision of the Products and Services; 

• • processing your transactions with us or any applications, instructions or requests from you, including without limitation, applications to join our Elite / Platinum plans; 

• • facilitate your use of our Products and Services; 

• • facilitate matches between and amongst Users, recommending other Users to you and recommending you to them; 

• • operate, maintain and monitor the usage and various features and functions on our Products or Services, troubleshooting and fixing issues as necessary and improving our Products and Services; 

• • manage the safety and security of the use of our Products and Services, including without limitation network and information security, prevention of fraud, prevention of violation of the terms and conditions of our Products and Services and prevention of other illegal or unauthorised activities; 

• • responding to your comments, questions, requests and providing customer service, and reviewing and improving service quality; 

• • to enable your purchases on our Products and Services, including without limitation, processing payments, offering and administering discounts and promotions, customising prices; 

• • subject to applicable laws, monitor and analyse trends, usage and activities on our Services and Products; 

• • administer promotions and contests, including joint promotions, events and contests with our industry partners;

• • subject to Data Protection Laws and applicable laws, for the purposes of operating advertising and marketing campaigns, marketing research, and publishing of research papers;  

• • developing and improving new features, Products and Services, including through machine learning and other technologies; 

• • defending any legal proceedings or threatened proceedings, or exercising any of our legal rights; 

• • responding to lawful requests from law enforcement, government authorities, courts, regulators; 

• • to comply with any Data Protection Laws or any other applicable laws; 

• • for any purposes disclosed to you at the time we collect your information or pursuant to your express consent;

• • any other purpose relating to any of the above.

6.3. We may also generate generic data out of any Personal Data we collect and use it for our own statistical and analytical purposes to better understand our Users’ profile and improve our Products and Services. We may also use such data to communicate with you in relation to other products or services offered by us, our partners and/or affiliates, subject to Data Protection Laws.

6.4. We have developed and use algorithms and artificial intelligence (AI) technologies and system to process Personal Data (as mentioned above) we collect from you (including without limitation, information you provide in your profile, distance, gender, preferences, and your responses to personality tests) and predict your compatibility with other Users. We may use your Personal Data for the development, testing, and improvement of our algorithms and AI technology. Such use includes, but is not limited to, training machine learning models, testing AI algorithms and improving the functionality of our AI technologies and systems. We may utilise your Personal Data to deliver personalised insights and recommendations to you. We may also use AI systems and AI algorithms to provide services to you in connection with our Products and Services. 

6.5. The purposes listed above may continue to apply even in situations where your relationship with us (for example, pursuant to a contract) has been terminated or altered in any way, for a reasonable period thereafter (including, where applicable, a period to enable us to enforce our rights under any contract with you).

7. DISCLOSURE OF INFORMATION TO THIRD PARTIES

7.1. We may share your Personal Data with other Users when you voluntarily disclose information on our Products and Services for others to see (for example, on your public profile). If a User submits a report involving you (such as a claim that you have violated any of our terms of use of our Products and Services), we may inform the relevant User who made the report of actions we took, if any, as a result of their report. The same applies if you submit a report involving another member. 

7.2. We may disclose your Personal data to the government, government agencies, regulators, law enforcement agencies and/or such other persons as may be necessary to comply with Data Protection Laws and such other applicable laws. 

7.3. We may from time to time and in compliance with Data Protection Laws, disclose your Personal Data to and receive Personal Data from, any personnel of YouApp Pte. Ltd., any of our related corporations, affiliates and branches, in order to carry out the purposes set out above. 

7.4. In addition, we may also disclose and share your Personal Data with our partners and vendors, who provide services including without limitation data hosting and maintenance, analytics, customer care, marketing, advertising, payment processing, legal support and security operations or to carry out any of the purposes listed above.

7.5. We may transfer your Personal Data if we are involved, whether in whole or in part, in a transfer of business, merger, sale, acquisition, divestiture, restructuring, reorganisation, dissolution, bankruptcy or other change of ownership or control. 

7.6. Please be assured that when we disclose your Personal Data to third parties, we require them to ensure that any Personal Data disclosed to them are kept confidential and secure and in accordance with Data Protection Laws. 

7.7. Users are allowed to use our Products and Services in conjunction with third-party services, however we may receive information about you from them (for example, if you use the share button to share with your contacts and groups on other apps. Please note that when you use third-party services, their own terms and privacy policies will govern your use of their services and products.

7.5. Additionally, we have implemented international standards to prevent money-laundering, terrorist financing and circumventing trade and economic sanctions and will implement final digital asset rules and regulations when effective, which will likely require us to undertake due diligence on our Users. This may include the use of third-party data and service providers, which we will cross-reference with your Personal Data.

8. SHARING WITH FACEBOOK

We may utilize the Facebook Graph API to enhance and personalize your experience on our Products and Services. This section of our Privacy Policy aims to provide you with clear and transparent information about how we collect, use, and protect your data when you interact with our application through the Facebook Graph API. By using our Products and Services and connecting to our Products and/or Services with your Facebook account, you consent to the practices described below.

8.1. Data Collection

When you access YouApp or our Products and Services using the Facebook Graph API, we may collect the following types of information from your Facebook account:

• • Public Information:We may access the public information available on your Facebook profile (such as your name, profile picture, cover photo, gender, and other publicly shared information);

• • Authorized Data: If you grant us specific permissions through the Facebook Graph API, we may access additional information from your Facebook account, such as your email address, friends list, birthday, and other data you choose to share.

8.2. Use of Facebook Graph API Data

The data collected from the Facebook Graph API is used to provide and improve our services, enhance your user experience, and personalize the content and recommendations you receive on YouApp, or our Products and Services. We may use your Personal Data for the following purposes:

• • Account creation and Authentication: We may your Facebook account information to create and authenticate your account on our Products and Services.

• • Personalisation: By analysing the data retrieved from the Facebook Graph API, we can tailor content, recommendations, and advertisements to match your interests and preferences.

• • Social Features: We may offer social features that allow you to share content or interact with other Users through your Facebook account.

• • Communication: We may use your email address (if provided) to send you important notifications, updates, and marketing communications related to our Products and Services. You can opt-out of marketing communications as outlined in our main Privacy Policy.

8.3. Data Sharing and Security

8.3.1. We prioritise the security of your data and will continue to implement appropriate measures to protect it from unauthorized access, disclosure, or misuse. We do not sell any of your Personal Data obtained through the Facebook Graph API to third parties.

8.3.2. However, please be aware that when you interact with our application through the Facebook Graph API, some of your Personal Data may be shared with Facebook in accordance with their data practices and policies. We recommend reviewing Facebook’s Privacy Policy to understand how they handle your data.

8.4. User Controls and Choices

8.4.1. You have control over the data you share through the Facebook Graph API. You can review and modify your Facebook privacy settings to manage what information is accessible to YouApp through the API. Additionally, you can revoke the permissions granted to our application at any time through your Facebook account settings.

9. HOW WE STORE YOUR PERSONAL DATA

9.1. Your Personal Data may be transferred to, and stored at, a destination outside of Singapore. If we transfer your Personal Data to a country or territory outside Singapore, we will do so in accordance with Data Protection Laws and applicable laws and we will take reasonable steps to ensure that your Personal Data continues to receive a standard of protection that is at least comparable to the protection under the PDPA. 

9.2. We may pseudonymise and aggregate certain Personal data of Users — such that individual Users cannot be identified — to analyse and improve our Products and Services. Your Personal Data may also be processed by staff operating outside of Singapore who work for us or for one of our suppliers. 

9.3. By submitting your Personal Data, you consent to this transfer, storing or processing of data, except Users located in the EEA as detailed above. All your Personal Data is stored on our and/or a third-party’s cloud servers.

10. ACCESS, CORRECTION, AND DELETION OF YOUR PERSONAL DATA

10.1. Subject to compliance with Data Protection Laws, you have the right to obtain a copy of your Personal Data that we hold about you upon request and ascertain whether the information we hold about you is accurate and up-to-date. If any of your Personal Data is inaccurate, you may request to update, rectify or correct your information. 

10.2. You may also request to delete your Personal Data, with the exception that we may refuse your deletion request in certain circumstances, such as in compliance with the law or for other legal purposes. 

10.3. Some data may be accessed, corrected and/or deleted directly by logging into your account with us. Otherwise, you may also submit your request in writing or via email to our Data Protection Officer at the contact details provided below.

10.4. In response to data access, correction, or deletion requests, we will verify the requesting party’s identity to ensure that he or she is legally entitled to make such a request. While we aim to respond to these requests free of charge, we reserve the right to charge you a reasonable fee. If so, we will inform you of the fees before processing your request.

10.5. We will respond to your access, correction or deletion request as soon as reasonably possible. If we are unable to respond to your request within thirty (30) days after receiving your request, we will inform you in writing within such time of the time by which we will be able to respond to your request. 

10.6. If we are unable to provide you with access or to make a correction or deletion requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to or prohibited from doing so under Data Protection Laws or other applicable laws). 

10.7. We generally rely on you (or your Authorised Representative) for the accuracy of your Personal data. If you use our Product or Services or choose to provide your Personal Data, you agree to submit Personal Data which is current, complete, accurate and not misleading and to keep it up to date and inform us of any changes to the Personal Data that you have provided to us. 

11. PERSONAL DATA OF CHILDREN

11.1. We are especially sensitive about children’s information. Our Products and Services are not targeted towards children, and Users must be of legal age to use our Products and Services. We may require consent from a User’s parent or guardian, or at our discretion, deny Users the use of our Products and/or Services, if a User is regarded as a minor for the purposes of Data Protection Laws. For the avoidance of doubt, we do not, in any case, knowingly solicit or collect Personal Data from children under the age of 13.

11.2. If you are a parent or legal guardian of a minor child, we will treat any information that you directly provide us on behalf of your minor child as Personal Data of your minor child. By providing any information to us on behalf of your minor child, you hereby represent that such information is true and accurate, and you consent to our collection, use, disclosure and processing of such Personal Data for the purposes stated in this Privacy Policy or notified to you. 

11.3. If you have questions concerning our Personal Data collection practices with respect to children, or if you learn that a child under the age of 13 has used our Products and Services, created a user account with us, or provided us with Personal Data without parental or guardian consent, please contact us. We will remove the relevant information and unsubscribe the child from our Products and Services.

12. MARKETING COMMUNICATIONS

12.1. We may communicate company news, promotions, and information relating to our Products and Services. We may share your Personal Data with third parties to help us with our marketing and promotional projects or with sending marketing communications. Marketing communications may be sent to you in various modes including but not limited to electronic mail, direct mailers, short message service, telephone calls, facsimile and other mobile messaging services. In doing so, we will comply with Data Protection Laws. 

12.2. In respect of sending telemarketing messages to your Singapore telephone number via short message service, telephone calls (voice or video) and other mobile messaging services, please be assured that we shall only do so if: 

• • you have provided your clear and unambiguous consent in writing or other recorded form for us to do so; and 

• • you have not indicated to us in our ongoing relationship that you do not wish to receive telemarketing messages sent to your Singapore telephone number and you have not registered that number with the National Do Not Call Registry. 

12.3. Customers can opt out from receiving these marketing and promotional communications/material at any time. If you no longer wish to receive these communications, please contact us. 

12.4. However, you will still receive communications relating to our Products and Services, such as policy/terms updates and administrative notifications (for example, transaction confirmations) and as part of our ongoing relationship with you and nothing in this Clause 12 shall vary or supersede the other terms that govern our relationship with you. 

13. USE OF COOKIES

13.1. We may place and access certain cookies on your computer browser or other devices used to access our Products and Services. Cookies are used to track your use of our Products and Services to better personalise our Products and Services and enhance your user experience. We may also use the information collected to ensure compliance with our compliance program, and to ensure your account security has not been compromised by detecting irregular or suspicious account activities.

13.2. Most browsers accept cookies automatically. Some Cookies expire when you finalize the session and other Cookies remain on your computer or other devices until deleted or expired. You have the option to delete or decline the use of our Cookies at any time, but this may limit the features and functionality of our Products and Services and affect your overall user experience.

14. INFORMATION SECURITY

We strive to protect our Products and Services and you from unauthorized access, alteration, disclosure, or destruction of Personal Data that we collect and store. We take various measures to ensure information security, including without limitation:  encryption of the YouApp communications with SSL; requiring two-factor authentication for all sessions; periodic review of our Personal Data collection, storage, and processing practices; and restricted access to your Personal Data on a need-to-know bases for our employees and vendors who are subject to strict contractual confidentiality obligations.

15. GOVERNING LAW

This Privacy Policy shall be governed in all respects by the laws of Singapore. 

16. EFFECT OF NOTICE AND CHANGES TO NOTICE

16.1. This Privacy Policy applies in conjunction with any other notices, contractual clauses and consent clauses that apply in relation to our collection, use, disclosure and/or processing of your Personal Data.

16.2. We shall have the sole discretion to update, amend and revise this Privacy Policy at any time without prior notice, save as required by Data Protection Laws or applicable laws. Users may determine if any such revision has taken place by referring to the date on which this Notice was last updated. 

16.3. Subject to applicable laws, by using our services, you acknowledge and agree that it is your responsibility to review this Privacy Policy periodically and become aware of any modifications. Your continued use of our Products and Services constitutes your acknowledgement and acceptance of such changes.

17. DATA RETENTION

17.1. We will retain your Personal Data only to the extent necessary to fulfil the purpose for which it was collected, for legal and business purposes, or as required or permitted by applicable laws.

17.2. We will retain your Personal Data (including transactional data and Know Your Customer (KYC) data) for up to 7 years, to the extent necessary for our business purpose or as required under applicable laws. By maintaining this information, YouApp is able to comply with various legal and regulatory requirements and ensure the security and integrity of our financial transactions. We take the protection of your personal information very seriously and have implemented appropriate measures to safeguard it. 

17.3. When there is no longer any business or legal purpose for us to retain your Personal Data, or the statutory retention period expires according to applicable laws, we will cease to retain your Personal Data and take reasonable steps to dispose or anonymise your Personal Data. 

18. MANAGEMENT OF PERSONAL DATA 

18.1. Reasonable security arrangements including the use of various hardware and software technologies have been put in place by us to ensure that your Personal Data are protected against unauthorised access, use, disclosure, copying, modification and disposal. 

18.2. 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 information security measures. You should be aware of risks associated with using our Products and Services as we cannot completely guarantee that no harmful code will enter our Products and/or Services (for example, viruses, bugs, Trojan horses, spyware or adware). 

18.3. We urge you to take every precaution to protect your Personal Data when you are on the Internet. We also recommend that you change your passwords often, using a combination of letters and numbers, and ensure that you use a secure browser. You further agree to keep your username and password secure and confidential and shall not disclose or permit it to be disclosed to any unauthorised person, and to inform us as soon as reasonably practicable if you know or suspect that someone else knows your username and password or believe the confidentiality of your username and password has been lost, stolen or compromised in any way or that actual or possible unauthorised transactions have taken place. We are not liable for any damages resulting from any security breaches, on unauthorised and/or fraudulent use of your username and password. 

18.4. If a data breach occurs, we will take reasonable and expeditious steps to assess whether the data breach is notifiable under the PDPA. If we determine that the breach is so notifiable: 

• • we will notify the PDPC as soon as possible, but in any case not later than 3 calendar days from the date that we determine that the data breach is notifiable; and 
  • we will notify each affected individual affected by the notifiable data breach in a manner that is reasonable in the circumstances and within reasonable time, unless we are not required to do so under Data Protection Laws, or if such requirement is otherwise waived by the PDPC. 

19. THIRD PARTY SITES

19.1. Our website, Products and Services may contain links to sites operated by third parties independent of YouApp. We are not responsible for the content and privacy practices of these other websites even though it is linked to our website(s) or found in our Products and/or Services. 

19.2. We encourage you to learn about the privacy policies of such third party site(s) by checking the policy of each site to determine how they will handle any information they collect from you and to contact its owner or operator if you have any questions or concerns. 

20. CONTACTING US 

20.1. If you:

• • have any questions, requests or feedback relating to your Personal Data or about this Privacy Policy;
  • would like to withdraw your consent to any use of your Personal Data as set out in this Privacy Policy; or
  • would like to obtain access, review  and make correction to your Personal Data records, 

please contact our Data Protection Officer by email at:

[email protected]
Attention: Data Protection Officer

20.2. Please note that if your Personal Data has been provided to us by a third party (e.g. your employer), you should contact that organisation or individual to make such queries, complaints, access and correction requests to YouApp on your behalf.

Please review the above terms and conditions concerning your use and access to our Products and Services. By using or accessing our Products and Services, you agree to be bound by the following terms and conditions. If you do not agree with these terms and conditions, you are prohibited from using our Products and Services and you should immediately cease to access our website, Products and Services.

We may change the terms of this Privacy Policy from time to time, on a prospective basis, and modify, add or discontinue any aspect, content or feature of the services, at its sole discretion. Your continued use or accessing of our Products and/or Services following the posting and/or notification of any changes to this Privacy Policy constitutes your acceptance of such changes.