Analemma Privacy Policy

This Privacy Policy (the "Policy") explains how we collect, use, store, disclose and share (collectively, "process") your personal data when you use the websites, Apps, software, and related services provided by Analemma (collectively, the "Services"). We respect your privacy and will take security protection measures to protect your personal data. Please note, our Services may involve integrations with websites, applications, and services managed by third parties. By interacting with these third parties, you are providing information directly to the third party and not us and are subject to the third party's privacy policy. Please read their data usage policies or other documentation. Our linking to another site or service doesn't mean we endorse that third party.

In this Policy, "Analemma", "we", "us" or "our" refers to ANALEMMA INTELLIGENCE PTE. LIMITED, a company registered at 67 AYER RAJAH CRESCENT, #02-10, SINGAPORE 139950.

This Policy may be updated from time to time and therefore please check back periodically for the latest version of the Policy, as indicated below.

Here is a summary of the information contained in this Policy. This summary is to help you navigate the Policy and it is not a substitute for reading everything. You can view the particular sections for more detailed information.

• What data do we collect about you? If you register an account to use the Services, we will need some personal data from you to set this up. We will also collect and create personal data about you when you use certain functions of the Services. We also use cookies necessary for the provision of our Services, and you may control these cookies in your search browser. For more information, please refer to 1 What data do we collect about you?.
• How do we use your data? We process your personal data to manage the contract you have entered into / agreed to and to provide functions related to account management, interaction with AI chatbot, and other Services. We also process your personal data to identify the abnormal status, ensure the stability and security of our Services, and to meet governmental and institutional policy obligations. For more information, please refer to 2 How do we use your data?.
• How do we retain and protect your data? Your personal data is stored on servers located in Singapore, and we take every reasonable step to ensure that your personal data is only processed for the minimum period necessary for the purposes set out in this Policy. For more details on the location and duration of the retention of your personal data, please refer to 3 How do we retain and protect your data?.
• How will we disclose and transfer your data globally? We may disclose your personal data to affiliates and some third-party service providers (e.g., payment services and IT services) who help us deliver the Services. We may also be required to disclose certain personal data about you in response to any legal procedures or requests from regulatory authorities, for audit purposes, in the event of mergers, acquisitions, sale of assets, or transfer of services, and in other circumstances specified under 4 How will we disclose your data?. Due to the international operation of our business, your personal data may be accessed from and transferred to jurisdictions outside of where you are located. In the event of a cross-border transfer of personal data, we take appropriate measures to provide an adequate level of protection for your personal data. For more information, please refer to 5 How will we transfer your data around the world?.
• What are your rights regarding the processing of your personal data? Depending on where you are, you may have certain rights with respect to your personal data, such as rights of access and data portability, to correct or delete your personal data, to withdraw your consent, restrict or object to our processing of your personal data, or to lodge complaints with an applicable authority for any breach of data protection laws. For more information, please refer to 6 What are your data subject rights and choices?. In particular, if you are a California resident, certain state data privacy legislation may entitle you to additional rights as detailed under 8 Notice to California Residents.
• How do we protect minors? We do not aim to provide Services for minors, and we do not intentionally collect or maintain information from minors. For more information, please refer to 7 How do we protect minors?.
• Contact Us. If you have any questions or comments regarding this Policy and/or other privacy practices, want to exercise any rights you may have, please contact us by using the information detailed under 9 How to contact us?.

1. What data do we collect about you?
2. How do we use your data?
3. How do we retain and protect your data?
4. How will we disclose your data?
5. How will we transfer your data around the world?
6. What are your data subject rights and choices?
7. How do we protect minors?
8. Notice to California Residents
9. How to contact us?
10. How do we update this Policy?

1 What data do we collect about you?

For the purpose of this Policy, "personal data" means any information relating to an identified or identifiable individual. To the extent that our processing of your personal data is subject to certain data privacy protection laws (including, but not limited to the General Data Protection Regulation ("GDPR"), the California Consumer Privacy Act of 2018 ("CCPA") and California Privacy Rights Act of 2020 ("CPRA"), collectively hereafter "applicable laws"), we will also notify you about the legal basis on which we process your personal data and your rights under such laws.

We collect the following categories of personal data from you:

1.1 Personal data you provide to us directly

• Account Information: when you create an account and/or log in to our Services, we will collect your email address, verification code, password, and username.
• Interaction Information: when you interact with the Services, we will collect your input data ("Inputs"), including text messages, code, and files, which will generate responses and actions ("Outputs") based on your Inputs.
• Integration Credentials: when you choose to connect the Services with third-party tools (such as GitHub, Hugging Face, and WandB), we will collect the access tokens, passwords, and API keys you provide.
• Payment Information: when you make a purchase, we will collect and process your payment method information, gift card code, and transaction records.
• Credits Information: when you obtain or use credits in your account, we will collect your current credit balance, and details of your credit history.
• Feedback Information: when you provide feedback about our Services, we will collect your feedback content in inquiries, complaints, and surveys.

1.2 Personal data collected by automated means

In order to provide secure and continuous services and guarantee service quality and personalized services, we will also collect the following information when you use the Services:

• Device Information: information about your device, including MAC address, device identifiers (such as IMEI, Android ID, IDFA, OPENUDID, GUID, SIM card information, MSI information), and device connection information (such as browser type, and language settings).
• Network Information: information about your network, including IP address, and telecommunications operator.
• Services Usage Information: information about your use of the Services, including User ID, diagnostic information, performance information, operation logs, and service logs.

We may also use the following technologies to collect the above data when you access our Services via the website:

• Cookies, which are text files stored on your device to uniquely identify your browser or to store information or settings in the browser to help you navigate between pages efficiently, remember your preferences, enable functionality, help us understand user activity and patterns, and facilitate online advertising.
• Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked.

Most browsers accept cookies automatically but allow you to disable them through your browser settings or notify you when a cookie is being sent. However, disabling cookies entirely may limit your access to certain features of the Services.

1.3 Personal data collected from Third Parties

• Third Parties Account Information: when you use a third-party account to register or log in to our Services (Google, GitHub, etc.), we collect certain information related to your third-party account, including your name, account name, email address, profile photo, and profile information under such third-party account.

2 How do we use your data?

We will only use your personal data when the applicable laws allow us to. Our legal bases for collecting and using the personal data described in this Policy depend on the personal data we collect and the specific context in which we collect the information:

• We need to perform a contract with you;
• You have given us consent to do so;
• Processing your personal data is in our legitimate interests, including
  • providing, maintaining and marketing our Services;
  • detecting, preventing and enforcing violations of our Terms of Service including misuse of services, fraud, abuse, and other trust and safety protocols; and
  • protecting our legal rights and the rights of others.
• We need to comply with our legal obligations under the applicable laws.

The purposes for which we process personal data, subject to applicable laws, and the legal basis on which we perform such processing, are as follows:

3 How do we retain and protect your data?

3.1 Where do we keep your data

We will process your personal data on servers located in Singapore. To support our global operations, we may allow remote access from other countries/regions for troubleshooting and other technical support, and use computing resources in other countries/regions to generate Outputs. In addition, your personal data may also be transferred to third-party service providers and business partners, in connection with the purposes set out in this Policy.

In the course of the above activities, we may transfer personal data to other jurisdictions that may have different laws and data protection compliance requirements to those that apply in the jurisdiction in which you are located.

3.2 How long do we store your data

We adhere to retention policies for the personal data we collect to ensure that it is not retained longer than necessary for the intended purpose. Different retention periods are applied to the various types of personal data collected by us in accordance with the service needs and regulatory requirements.

Upon expiration of the retention period, we will either delete or anonymize your personal data. Measures will be taken to render the information irrecoverable or irreproducible.

When assessing how long your personal data is retained, we consider criteria such as: (i) the nature of the personal data and the activities involved; (ii) the time when and for how long you use the Services; and (iii) our legitimate interests and our legal obligations.

3.3 How do we protect your data

We have implemented appropriate technical and organizational security measures designed to protect your personal data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, unauthorized access, and other unlawful or unauthorized forms of processing, in accordance with applicable laws.

Your account is protected by a password for your privacy and security. You must prevent unauthorized access to your account and personal data by selecting and protecting your password appropriately and limiting access to your computer or device and browser by signing off after you have finished accessing your account. If you have any concerns that your account or personal data has been put at risk, for example if someone could have found out your password, please contact us by using the contact details provided in Section 9 below.

Please note, the Internet is an open system, the transmission of information via the internet is not completely secure. Although we will implement all reasonable measures to protect your personal data, we cannot guarantee the security of your data transmitted to us using the internet — any such transmission is at your own risk, and you are responsible for ensuring that any personal data that you send to us are sent securely.

4 How will we disclose your data?

In order to provide you with more comprehensive and high-quality Services, we will authorize our commercial partners to provide certain services to you. In such cases, we may share some of your personal data with these partners.

We will only share your personal data for lawful, legitimate, necessary, specific, and explicit purposes, and we will only share the personal data required to provide the Services. We will require our partners, through agreements, to retain data only for the necessary period and to implement adequate security measures to protect data security.

We will disclose personal data to the following categories of third parties for the purposes explained in this Policy:

• Analemma affiliates. We disclose the categories of personal data described above between and among our affiliates and related entities, for legitimate business purposes and the operation of the Services, in accordance with applicable laws.
• Service providers and business partners. Third-party service providers offering payment services, and IT services (such as cloud storage services and AI services) may need to process your data. These third parties will process your personal data on our behalf under relevant contracts.
• Law enforcement agencies, public authorities or other judicial bodies and organizations. We disclose information if we are legally required to do so, or if we have a good faith belief that such use is reasonably necessary to comply with a legal obligation, process or request; enforce our Terms of Service and other terms, policies, and standards, including investigation of any potential violation thereof; detect, prevent or otherwise address security, fraud or technical issues; or protect the rights, property or safety of us, our users, a third party or the public as required or permitted by applicable laws (including exchanging information with other companies and organizations for the purposes of fraud protection).
• Change of corporate ownership. If we are involved in a merger, acquisition, bankruptcy, reorganization, partnership, asset sale or other transaction, we may disclose your information as part of that transaction.

5 How will we transfer your data around the world?

We will process your personal data on servers located in Singapore, therefore your personal data may be processed on servers located outside of the country where you reside. To support our Services, we may also use computing resources in other countries/regions to generate Outputs. Meanwhile, due to the international nature of our business, your personal data may also be accessed by our affiliates or third-party service providers and business partners, in connection with the purposes set out in this Policy. Accordingly, your personal data may be transferred to and processed in jurisdictions that may have different laws and data protection compliance requirements to those that apply in the jurisdiction in which you are located.

In the event of an international transfer of personal data, when required by applicable laws, we will provide an adequate level of protection for your personal data using various means to enable lawful transfer of personal data from those countries. If you would like to have an overview of the safeguards which are in place, please contact us by using the contact details provided in Section 9 below.

6 What are your data subject rights and choices?

Subject to applicable law and depending on where you reside, you may have some rights regarding your personal data, as described further below. You may exercise some of your rights in the Services via "Settings > Account". If you have any other requests relating to your personal data, please contact us by using the contact details provided in Section 9 below.

6.1 Data Access.
You may have the right to know what personal data we process about you, including the categories of personal data, the business or commercial purposes for collection, and the categories of third parties to whom we disclose it, and other information according to the applicable law.

6.2 Data Correction.
You may have the right to request that we correct inaccurate personal data that we retain about you, subject to certain exceptions. Please note that we cannot guarantee the factual accuracy of Outputs. If Outputs contain factually inaccurate personal data relating to you, you can submit a correction request and we will make a reasonable effort to correct this information — but due to the technical complexity of the large language models underlying the Services, it may not always be possible for us to do so.

6.3 Data Portability.
You may contact us to request the personal data you have provided to us in a structured, commonly used and machine-readable format and have it transferred to another controller, to the extent applicable.

6.4 Data Deletion.
You have the right to delete your account and erase your personal data. Upon deleting your account, all your personal data will be deleted promptly. Additionally, you may also request deletion of the personal data you provide by contacting us. If some of your personal data cannot be deleted, we will inform you of the reasons for not taking action. Please note that we reserve the right to retain some of your personal data where there are valid grounds for us to do so under applicable laws.

6.5 Withdrawal of Consent.
Where we process your personal data on the basis of your consent, you may withdraw your consent by contacting us. The withdrawal of consent will not affect the lawfulness of processing based on consent before its withdrawal. At present, we do not use your personal data for marketing purposes. In the event that we use your personal data for marketing in compliance with legal requirements, you will have the right to opt out of future direct marketing messages through the unsubscribe mechanism at the bottom of such communications, or contacting us.

6.6 Objection to the Processing.
Subject to applicable laws, you may object to the processing of your personal data based on our legitimate interests where there are grounds relating to your particular situation by contacting us. Please note that we may have an overriding legitimate interest to keep processing your personal data, but we will let you know where this is the case.

6.7 Restriction on Processing.
If you would like to restrict our processing of your personal data, you may contact us. You have the right to restrict the processing of your data where one of the following applies:

• the processing is unlawful and you oppose the erasure of relevant personal data;
• for the purpose of establishment, exercise or defense of legal claims, you request us to retain your personal data that we were supposed to delete;
• your objection regarding the accuracy of your personal data is pending our verification;
• your request to object to the processing of your personal data is pending our verification.

6.8 Other Rights.
Depending on your jurisdiction, you may be entitled to additional rights in relation to your personal data. For example, you may also have the right to lodge complaints with an applicable data protection authority if you consider that the processing of your personal data infringes any applicable data protection laws (for example, the EU General Data Protection Regulation). For California residents, please find more details of your rights in Section 8 below.

If you would like to contact us to exercise one or more of these rights, to ask a question about these rights or any other provision of this Policy or about our processing of your personal data, or to file a complaint about how we process your personal data, you may use the contact details provided in Section 9 below. When submitting a right request, please specify the scope and basis of your request and provide us with the necessary information to verify your identity. We may contact you to confirm your identity in order to handle your request. We will respond to your request or complaint in due course under applicable data protection laws.

7 How do we protect minors?

Our Services are not intended for, and we do not knowingly collect, sell, or share any information about, minors under the age of 18. If you become aware that a minor under the age of 18 has provided any personal data to us while using our Services, please email us at the contact details provided in Section 9 below, and we will investigate the matter and, if appropriate, delete the personal data.

8 Notice to California Residents

If you are a California resident, the California Consumer Privacy Act ("CCPA") requires us to provide you with the following additional information:

8.1 Collection and Use of Your Personal Data

We collect personal data from and about you in the preceding 12 months as described in Section 1 above, primarily including the following categories of personal information enumerated under the CCPA definition of "personal information":

• Identifiers, such as email address, username, User ID, IP address
• Personal information categories listed in the California Customer Records statute, such as name and phone number
• Internet and similar network activity information, such as Interaction Information
• Geolocation information, such as IP address
• Commercial information, such as your transaction records
• Sensitive personal information, such as your account password

8.2 Disclosure of Personal Data

We disclose personal data with third parties for business purposes in the preceding 12 months as described in Section 4 above. The details are as follows:

In addition to the personal data rights listed in Section 6 above, you are also entitled to the following:

• Limit the Use of Sensitive Personal Data. You also have the right to request limitation of use and disclosure of your sensitive personal data, subject to certain exceptions. If you would like to limit the use of your sensitive personal data, please contact us by using the contact details provided in Section 9 below. We do not "sell" or "share" (as defined under the CPRA) your sensitive personal data.
• Do Not Sell or Share My Personal Data. Based on the definition of "sell" and "share" under the CPRA, we do not believe that we engage in such activity and have not engaged in such activity in the past 12 months from the effective date of this Policy.
• Direct Marketing. We do not disclose personal information to third parties for their direct marketing purposes.
• Appeal. You may appeal our refusal to take action on a request by contacting us using the contact details provided in Section 9 below. If your appeal is denied and you are a California resident, you may contact the California Attorney General about the results of the appeal by submitting a complaint by clicking here.
• Right not to be subject to automated decision-making. You shall have the right not to be subject to automated decision-making. You also have the right to obtain your personal information used for automated decision-making, to be informed of the reasons of the resulting decision, and to be informed of what actions you can take to secure a different decision.
• The Right to Non-discrimination. You have the right not to be discriminated against for exercising any of your rights.

If you would like to contact us to exercise one or more of these rights, to ask a question about these rights or any other provision of this Policy or about our processing of your personal information, or to file a complaint about how we process your personal information, you may use the contact details provided in Section 9 below. According to applicable laws, we may request you to provide documents such as application form and proof of identity. We may contact you to confirm your identity in order to handle your request. We will respond to your request or complaint in due course under the applicable laws.

9 How to contact us?

For more information about your data subject rights, or how we process your personal data, please contact us by using the information below:

ANALEMMA INTELLIGENCE PTE. LIMITED

Address: 67 AYER RAJAH CRESCENT, #02-10, SINGAPORE 139950

Email: contact@analemma.ai

10 How do we update this Policy?

We will update this Policy in a timely manner, and we recommend that you regularly check the latest version of this Policy at the bottom of our website. If there are any substantial changes to this Policy, depending on the nature of such changes, we will notify you in advance through pop-ups, push notifications, emails, and other appropriate means.