1. Introduction

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This Privacy Policy outlines how Cuppa PTE LTD, with a registered address at 133 New Bridge Road, #19-09/10 Chinatown Point, Singapore 059413, collects, processes, and protects your personal data. It also explains your rights regarding your personal data. If you have any questions about this Privacy Policy or wish to exercise any of your rights, contact us via email at hello@cuppa.so (preferred contact method) or at the address above.

This Privacy Policy is legally binding, so please read it carefully. If you disagree with any part of this policy, refrain from providing personal data to us or request that your employer does not do so. Updates to this Privacy Policy may occur from time to time to reflect changes in applicable laws. Substantial updates will be communicated appropriately; otherwise, it is your responsibility to review this policy regularly.

We collect personal data:

• Directly from you.
• From your employer or colleagues when they engage with our services.
• From third-party platforms or services integrated with Cuppa PTE LTD.

We also allow developers or users access to the Cuppa API for developing Integration Apps. Each developer is considered an independent controller of personal data shared via these apps. Please review the terms and privacy policies of any Integration Apps you use.

Our platform is not intended for children, and we do not knowingly collect data from them. Links to third-party websites, plug-ins, and applications may be present on our website. Engaging with these could allow third parties to collect your data. Review their privacy policies before proceeding.

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2. What Personal Data Do We Collect and From Whom?

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2.1 Definition of Personal Data

Personal data refers to identifiable information, such as:

• Name, email address, gender, date of birth, phone numbers.
• IP address or photos uploaded to our platform.

We reserve the right to anonymize or pseudonymize this data for internal purposes.

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2.2 Special Categories of Personal Data

Special categories include data about race, ethnic origin, political views, religion, health, or sexual orientation. We process such data only if voluntarily shared by you or a client.

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2.3 Data You Provide

We may collect data from:

• Navigating our website or app.
• Applying for a job.
• Offering services to us.
• Subscribing to newsletters or updates.
• Inquiries, feedback, or complaints.

This data may come from:

• Direct submissions.
• Social media channels.
• Integration Apps.

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2.4 Data We Automatically Collect

When you use our website or app, we may log:

• Device type, browser, operating system.
• Language, timezone, and preferences.
• Duration and behavior during usage.

Cookies or similar technologies are used to collect this data. Review our Cookies Policy for details.

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2.5 Data from Third-Party Services

When integrating with third-party services like Google Services, Dropbox, or Microsoft Outlook, we may collect:

• Third-party profiles.
• Email content, attachments, and metadata.
• Calendar entries and files.

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2.6 Data from Other Sources

Your employer or colleagues may provide your email for account setup. Data may also be sourced from Integration Apps, payment partners, or references during job applications.

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3. Lawful Use of Personal Data

We process your data based on the following legal bases:

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3.1 Consent

Example: Sharing data via Integration Apps.

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3.2 Contract Fulfillment

To deliver services as per agreements with you, your employer, or a colleague.

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3.3 Legal Obligations

To comply with regulatory requirements.

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3.4 Legitimate Business Interests

For activities like customer support, audits, and platform improvements, provided they don’t infringe on your rights.

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3.5 Marketing Communications

We may use your data to send product updates. You can opt out anytime.

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3.6 Service Enhancements

User data helps refine our offerings. Refer to our Cookies Policy for more details.

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3.7 Job Applications

We use provided data to process applications.

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3.8 Change of Purpose

We use your data solely for its collected purpose. If required for another purpose, we will notify you, unless legally exempt.

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4. Who Do We Share Your Data With?

We share your data with trusted third parties for legitimate business operations, including:

• Payment processors, IT service providers, legal advisors.

These entities access only the necessary data and comply with data protection laws. Data may also be disclosed:

• During legal investigations.
• For safeguarding rights, assets, or safety.
• During corporate activities like mergers or acquisitions.

Users will be notified of significant changes involving their data.

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5. Where We Hold and Process Your Data

Your data is primarily stored in Singapore but may be transferred internationally to:

• Email marketing platforms (e.g., Mailchimp).
• Analytics services (e.g., Google Analytics).
• User experience tools (e.g., Hotjar).

We ensure compliance with Singapore’s PDPA and international standards.

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6. Security

We employ measures like secure servers and staff training to protect your data. While we strive to ensure security, no system is infallible. In case of a breach, immediate mitigation steps will be taken.

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7. Your Rights

Under Singapore’s PDPA, your rights include:

• Access: Request details of your personal data.
• Rectification: Correct inaccurate data.
• Data Portability: Receive your data in a structured format.
• Restriction of Processing: Limit data processing in certain scenarios.
• Right to be Forgotten: Request data erasure.
• Objection to Processing: Raise concerns over specific uses.

Contact us to exercise these rights. If we process your data on behalf of a client, direct inquiries to them. Complaints can also be lodged with Singapore’s Personal Data Protection Commission (PDPC).

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8. Retention of Personal Data

We retain your data as required by law or for our business relationship. Specific retention periods depend on:

• The nature of the relationship.
• Legal and auditing requirements.
• Client instructions.

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9. General

This policy is governed by Singaporean law. If any clause is deemed unenforceable, the remaining terms remain valid.

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10. How to Contact Us

For inquiries or concerns about your data, contact us:

Email: hello@cuppa.so
Address:
Cuppa PTE LTD
133 New Bridge Road,
#19-09/10 Chinatown Point,
Singapore 059413

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