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1. Introduction
This Privacy Policy sets out how We, Cuppa PTE LTD, with a registered address at 133 New Bridge Road, #19-09/10 Chinatown Point, Singapore 059413, collect and process your personal data and explains your rights in relation to your personal data. If you have any questions about this Privacy Policy or wish to exercise any of your rights in relation to your personal data, you can contact us at the address above or by email to hello@cuppa.so. Our preferred contact method is email.
This Privacy Policy affects your legal rights and obligations so please read it carefully. If you do not agree to be bound by this Privacy Policy, please do not provide your personal data to us or request that your employer does not do so.
We may update this Privacy Policy from time to time at our discretion and in particular to reflect any changes in applicable laws. If we do so, and the changes substantially affect your rights or obligations, we shall notify you through appropriate means. Otherwise, you are responsible for regularly reviewing this Privacy Policy to stay informed of any updates.
We may collect your personal data because you provide it to us, or because your employer or a colleague engages with our services and wishes to set up an account for you. In such circumstances, we are the controller of your personal data.
Alternatively, we may receive your personal data from other platforms or services that integrate with Cuppa PTE LTD. In such circumstances, we act as the processor of your personal data, processing it in accordance with the originating platform's instructions.
On certain occasions, we may allow certain developers or users access to the Cuppa API to develop specific applications enabling integration between third-party platforms and Cuppa PTE LTD services (referred to as "Integration App"). Every Integration App is developed independently. Hence, each developer of an Integration App shall be considered an independent controller of any personal data you may share by using such an Integration App. We urge you to read the terms and privacy policy of every Integration App you might use in conjunction with our services.
Our platform and website are not intended for children, and we do not knowingly collect data relating to children.
Our website may feature links to third-party websites, plug-ins, and applications (including Integration Apps). Activating those links or enabling those connections could let third parties gather or share data about you. We do not have control over these third-party platforms and cannot be held accountable for their privacy measures. When navigating away from our website, we strongly advise you to go through the privacy policy of every site you land on.
2. What personal data do we collect and from whom?
By personal data, we refer to any identifiable information about you, such as your name, email address, gender, date of birth, mobile and home telephone number, your IP address, or a photo you upload to our platform. Cuppa PTE LTD reserves the right to anonymize and/or pseudonymize such personal data, ensuring it's no longer personally identifiable. We may then use this anonymized and/or pseudonymized data for our internal business purposes, insights, or other occasional needs.
We might obtain special categories of personal data about you if you or a client opts to share such data. These special categories include data about your race, ethnic origin, political viewpoints, religious or philosophical beliefs, trade union membership, genetic or biometric data, health data, or data concerning your sex life or sexual orientation.
2.1 Data you provide to us
You might share personal data with Cuppa PTE LTD for various reasons:
• Navigating our website.• Using our mobile app.• Applying for a job at Cuppa PTE LTD.• Offering services to us.• Subscribing to receive updates or newsletters.• Contacting us for inquiries, feedback, or complaints.
This data might be shared directly via our platform, through our social media channels, or Integration Apps. Others might also provide your personal data, like when you're added to a team workspace.
We process all shared personal data in line with this Privacy Policy. Some personal data is essential for us to cater to your requests, and we'll specify this when collecting the data.
If legally required or contractually needed data isn't provided, we might not be able to serve you (like offering our services). In such cases, we may need to terminate a service or product agreement with you. You'll be informed if such a scenario arises.
Ensure that all data shared is accurate and truthful. If requested, kindly validate your identity. Sharing false or inaccurate data, especially when indicating fraud, will be recorded, and possibly reported. Communications, whether through emails or calls, may be archived.
2.2 Data we automatically collect
When visiting our website or using our mobile app, we automatically log information about your device and activities. This can include:
• Device specifics like its type, browser, and operating system.• Settings and preferences, including language and timezone.• Duration and manner of website/app use, along with used services and features.
This data collection might involve cookies and similar technologies. For a detailed understanding of our cookie usage, please review our Cookies Policy.
2.3 Data from third-party services, such as Google Services, Dropbox, Microsoft Outlook, and Microsoft OneDrive
When integrating with third-party services in the Cuppa PTE LTD application, we might collect and store:
• Third-party profiles.• Names.• Email addresses.• Email content, attachments, and metadata.• Calendar entries.• Files.
2.4 Data from other sources
Your colleagues or employer might occasionally share data related to you (like your email) for account creation on our platform. If your non-work email is provided by a third party, inform us, and we'll remove it.
Data might also come from Integration Apps, payment partners, security service partners, or in the event of platform misuse.
For job applications at Cuppa PTE LTD, data might be sourced from previous employers or other references.
3. Lawful use of your personal data
At Cuppa PTE Ltd, we value the trust you place in us by providing your personal data. We will only utilize your personal data when we have a legal basis for doing so. The legal reasons we depend on under this Privacy Policy include:
The way we handle your personal data largely depends on the rationale behind its collection.
3.1 Using data from your employer or colleague who uses Cuppa PTE LtdIf your data is sourced from your employer's use of Cuppa PTE Ltd or a colleague’s referral, we process your data in line with any existing agreements we have with them. This often involves creating a dedicated account for you within our system.
3.2 Using data from connected Google ServicesIf you've used a Google sign-in with us, it aids in granting you access to our application. Whenever data is sourced from Google Drive, Calendar, or Gmail, it's geared towards optimizing your experience on Cuppa PTE Ltd, especially concerning email, file, and contact management. We also abide by guidelines regarding the use of data from Google, as detailed above.
3.3 Using data you uploaded or entered into the Cuppa PTE Ltd applicationIf you've imported data into our system, we handle that data based on the lawful grounds mentioned above and following your guidance.
3.4 Using data for our legitimate interestsYour data may also be utilized in line with our genuine business interests, covering areas like customer support, legal and regulatory obligations, audits, and to apprise you of modifications to this policy.
3.5 Using data to provide Product Update E-Mails (Marketing)Your data aids us in forwarding marketing communications that align with your preferences. Should you wish to discontinue receiving such communications, you have the option to opt-out as explained above.
3.6 Using data to enhance our serviceWe frequently examine user data to refine and enhance our platform's offerings. For an exhaustive understanding, kindly refer to our Cookies Policy.
3.7 Using data to process job applicationsShould you apply for a role at Cuppa PTE Ltd, the personal data you provide assists us in processing your application and responding appropriately.
3.8 Change of purpose At Cuppa PTE Ltd, we're steadfast in using your data solely for the purposes it was gathered for. If there's a necessity to use it differently, rest assured we will inform you and elucidate the legal foundation permitting such a use. It's worth noting that in certain scenarios, we might process your data without needing to notify you or seek your consent, especially if mandated or allowed by law.
4. Who do we share your data with?At Cuppa PTE LTD, for our legitimate business operations, we may share your personal data with our trusted third-party service providers, sub-contractors, and agents. This encompasses entities such as payment gateways, IT infrastructure providers, accountancy firms, audit firms, and legal consultants. We ensure these third parties have access only to the data they require to offer their services and remain compliant with data protection laws. Should our association with any of these entities end, we will direct them to either anonymize your personal data or delete it.
If compelled by Singaporean law, we might have to disclose your personal data, such as during legal investigations or to safeguard third-party rights, assets, or safety.
Your data may also be shared during corporate activities like mergers, asset sales, restructurings, financings, or if a section or entirety of Cuppa PTE LTD is acquired by another entity. Users will be informed should such an event transpire.
5. Where we hold and process your personal dataWhile Cuppa PTE LTD primarily stores your data in Singapore, certain situations might necessitate transferring or storing a part or all of your personal data outside Singapore. This can occur especially when working with third-party service providers like:
Whenever your data is transferred outside Singapore, we ensure it aligns with the PDPA's standards and international data protection best practices to safeguard your data.
To know more about our international data transfer mechanisms, please connect with us via the email mentioned in clause 10.
6. SecurityCuppa PTE LTD is committed to maintaining the integrity and confidentiality of your personal data. We implement rigorous measures against unauthorized access, unlawful data processing, and inadvertent loss or damage. For instance, we employ secure servers and instruct our employees to respect data protection regulations.
It's vital to recognize that despite our best efforts, no system is entirely invulnerable. Should a security breach arise, we pledge to take immediate action to mitigate the breach and limit data loss.
7. Your rights
Your rights concerning your personal data are protected under the Personal Data Protection Act (PDPA) of Singapore. The PDPA safeguards individuals' personal data against misuse and promotes proper management of personal data in organizations. Under the PDPA, you are entitled to:
Access: You can request information about the personal data we hold about you, its origin, its use, and to whom it has been disclosed.
Rectification: If you find that your personal data with us is inaccurate or incomplete, you have the right to request corrections.
Data Portability: This allows you to receive your personal data in a structured, commonly used, and machine-readable format, and you have the right to transmit this data to another organization.
Restriction of Processing: Under certain circumstances, you can request the restriction of processing your personal data.
Right to be Forgotten: You can request that we erase your personal data under certain conditions.
Objection to Processing: You can object to the processing of your personal data under specific situations.
For any questions or to exercise any of these rights, please contact us using the contact details provided. Do note, if we are processing your data on behalf of a client, you may need to contact that client directly.
If you have concerns regarding our handling of your personal data, please let us know. We strive to address all concerns promptly and efficiently. Moreover, as we are governed by Singapore's data protection laws, you have the right to lodge a complaint with the Personal Data Protection Commission (PDPC) of Singapore.
8. Retention of personal data
Cuppa PTE Ltd adheres to the relevant laws when retaining personal data. The exact duration depends on the nature of our relationship with you, any legal or auditing requirements, and our clients' instructions if they provided your data.
You also have the right, in specific situations, to ask us to erase your data, as outlined in the 'Your rights' section.
9. General
This Privacy Policy is governed by the laws of Singapore. In the case of any clause being deemed unenforceable by a competent authority, the rest of the policy remains valid.
10. How to contact us
You can contact us with any questions or comments about your Personal Data, this Policy, or any other privacy-related enquiries by emailing hello@cuppa.so
Address:Cuppa PTE LTD133 New Bridge Road,#19-09/10 Chinatown Point,Singapore 059413