Privacy Policy

Version Date: 13 November 2024

1. Introduction and Scope

Welcome to start.ai (the Labelling Platform) under Poligon Pte. Ltd. This Privacy Policy is part of our Terms of Conditions of the Labelling Platform (the “Terms”) , and describes how we collect, use, and share information. All capitalized terms not defined herein will have the meanings set forth in the Terms.

We respect the privacy of users of the Labelling Platform. When you use the services provided by us through the Labelling Platform, we will collect, use and transfer your personal information in accordance with this Privacy Policy. This Privacy Policy contains the terms of our collection, storage, use, transfer and protection of your personal information, and we hope that this Privacy Policy will give you a clear description of how we treat your personal information, so we advise you to carefully read this Privacy Policy to understand how to protect your privacy. If you have any questions about this Privacy Policy, you can contact us through the contact information published on the Labelling Platform.

2. What information we collect?

We may collect the following information about you:

2.1 Information you provide to us. We collect information from you when you fill out your information and submit any supporting document to us when you register for a Labelling Platform account, and through the related services that you provide via the Labelling Platform. Such information includes: your name, region, date of birth or age, educational level, occupation, phone number, email address, payment information and other additional information provided by you.

2.2 Information collected during your use of the service. For us to provide services to you and optimize the services that you need, we also collect information about your use of the services. When you access and use the Labelling Platform, we collect certain information about the device you use to access the Labelling Platform, such as your IP address, user agent, mobile carrier, time zone settings, identifiers for advertising purposes, model of your device, the device system, network type, device IDs, your screen resolution and operating system, app and file names and types, keystroke patterns or rhythms, battery state, audio settings and connected audio devices. Where you log-in from multiple devices, we will be able to use your profile information to identify your activity across devices. We may also associate you with information collected from devices other than those you use to log-in to the Labelling Platform.

In addition to the above information, we may also collect additional information about you to improve the quality of our services, including the information you provide when you contact our customer service team, information you sent to us when you participated in the survey, questionnaire responses and information we collect when you interact with the affiliates and partners of us.

2.3 Information collected from third parties

We may receive the information described in this Privacy Policy from other sources, such as:

• We may obtain information about you from certain affiliated entities within our corporate group, including about your activities on their platforms.
• We may receive information about you from others, including where you are included or mentioned in direct messages, in a complaint, appeal, request or feedback submitted to us, or if your contact information is provided to us. We may collect information about you from other publicly available sources.
• We may receive information from payment and transaction fulfilment providers about you, such as payment confirmation details.

3. How do we use your information

We collect your information to provide services to you and to improve the quality of the services and the Labelling Platform. We will use your information for the following purposes:

3.1 To provide, maintain and improve the services and experiences provided to you through the Labelling Platform;

3.2 We may use your personal information to prevent, detect, investigate frauds and other illegal acts that create security issues or violate any agreements or policies or rules of us or our affiliates. We may also use your information to protect the legitimate rights and interests of you, other users, us or our affiliates;

3.3 To improve and develop the Labelling Platform and conduct product development;

3.4 To understand how you use the Labelling Platform, including across your devices;

3.5 To verify your identity or age;

3.6 To facilitate any payment related transaction including sharing your information with payment and transaction fulfillment providers and other service providers to process the payment;

1. To communicate with you, including to notify you about changes in our services;
2. To send promotional materials, including by instant messaging or email, from us or on behalf of our affiliates and trusted third parties;

3.9 To fulfil requests for products, services, Labelling Platform functionality, support and information for internal operations, including troubleshooting, data analysis, testing, research, statistical, and survey purposes and to solicit your feedback;

3.10 To enforce our Terms of Service, Community Guidelines, and other conditions and policies; and

3.11 To train and improve our technology, such as our machine learning, models and algorithms.

4. How we share, disclose or transfer your personal information

We share your information with the following parties:

1. Service Providers. We provide information and content to service providers who support the Labelling Platform acting as agents on our behalf, as necessary for them to help us with the Labelling Platform operations. For example, these may include cloud service providers, customer support or auditing vendors.
2. In Connection with a Sale, Merger, or Other Business Transfer. We may share information in connection with a substantial corporate transaction, such as the sale, a merger, consolidation, or in the unlikely event of bankruptcy.
3. Our Corporate Group. We may also share your information with other members, subsidiaries, or affiliates of our corporate group, including to provide the Labelling Platform, to improve and optimise the Labelling Platform, to prevent illegal use.
4. For Legal Reasons. We will share your information with law enforcement agencies, public authorities or other organisations if legally required to do so, or if such use is reasonably necessary to:
• comply with legal obligation, process or request;
• enforce our Terms of Service and other agreements, 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 law (including exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction).
1. With Your Consent. We may disclose your information for other purposes pursuant to your consent or at your direction.

5. Use of cookies and network beacon

To enhance your user experience with the Labelling Platform, when you visit the related websites of the Labelling Platform or use any services provided by us through the Labelling Platform, we may identify you through a small data file, which will save you from having to repeatedly enter your registration information or help assess the security of your account. Such data file may include cookies, flash cookies, or other local storage provided by your browser or associated application (collectively, "Cookies").

Please understand that some of our services can only be implemented by using "cookies". You may modify the configuration of cookies or reject cookies of the Labelling Platform if your browser or add-on allows you to do so, but in some cases, this may affect your secure access to related websites of the Labelling Platform.

Webpages often contain electronic images which help websites to track users’ web-browsing or access of certain cookies. We collect information relating to your activities on webpages by means of web beacons. Such activities include information relating to the web address you visited, the address of the reference page you visited earlier, the time you stayed on the page, your browsing environment, display settings, and etc..

6. Where do we store your personal information

. The personal information we collect from you may be stored on a server located outside of the country where you live. We store the information we collect in secure servers located in Singapore. Where we transfer any personal information out of the country where you live, including for one or more of the purposes as set out in this Privacy Policy, we will do so in accordance with the requirements of applicable data protection laws.

7. Protection of your personal information

We take steps to ensure that your information is treated securely and in accordance with this policy. Unfortunately, the transmission of information via the internet is not completely secure. Although we will use reasonable measures to protect your personal information, for example, by encryption, we cannot guarantee the security of your information transmitted via the Labelling Platform; any transmission is at your own risk.

We have appropriate technical and organizational measures to ensure a level of security appropriate to the risk of varying likelihood and severity for the rights and freedoms of you and other users. We maintain these technical and organizational measures and will amend them from time to time to improve the overall security of our systems.

Please protect your personal information and provide it to others only when necessary. If you find that your personal information has been compromised, especially if your account and password are leaked, please contact the administrator of the Labelling Platform immediately so that we can handle the situation accordingly.

1. How long we keep your personal information

We retain information for as long as necessary to provide the Labelling Platform and for the other purposes set out in this Privacy Policy. We also retain information when necessary to comply with contractual and legal obligations, when we have a legitimate business interest to do so (such as improving and developing the Labelling Platform, and enhancing its safety, security and stability), and for the exercise or defence of legal claims.

The retention periods are different depending on different criteria, such as the type of information and the purposes for which we use the information.

1. Your rights and choices

You have rights and choices when it comes to your information. You may be afforded certain rights under applicable laws, which may include the right to access, delete, update, or rectify your data, to be informed of the processing of your data, to file complaints with authorities, and potentially other rights. You may submit a request to exercise your rights under applicable laws at [ ].

9. Changes to this Privacy Policy

We may update this Privacy Policy from time to time. When we update the Privacy Policy, we will notify you by updating the “Last Updated” date at the top of this policy, posting the new Privacy Policy, or providing any other notice required by applicable law. We recommend you review the Privacy Policy each time you visit to stay informed of our privacy practices.

10. Contact us

If you have any questions about about how we process your personal information, you may contact us: [ ]

Supplemental Terms – Jurisdiction Specific

In the event of a conflict between the provisions of the Supplemental Terms – Jurisdiction-Specific that are relevant to your jurisdiction from which you access or use the services, and the rest of policy, the relevant jurisdictions’ Supplemental Terms – Jurisdiction-Specific will supersede and control.

Philippines

If you are using our services in the Philippines, the following additional terms shall apply pursuant to the relevant laws, rules and regulations and issuances by the Philippines National Privacy Commission (“NPC”) on data privacy.

Your Rights. To the extent that the relevant laws, rules and regulations on data privacy recognize your rights and freedoms as data subjects, you shall have the right to information, object, access, rectification, erasure or blocking, lodge complaints before the NPC, damages and data portability. Before we can respond to a request to exercise one or more of the rights listed above, you may be required to verify your identity or your account details.

Vietnam

If you are using our services in Vietnam, the following additional terms apply. In the event of any conflict between the following additional terms and the provisions of the main body of this policy, the following terms shall prevail.

Methods of processing your personal data. We may process your personal data by manual or automated methods.

Data subject's rights and obligations. Subject to certain exceptions, you have statutory rights and obligations under applicable laws. In particular, you have the following statutory rights:

• Right to know;
• Right to consent and withdraw consent;
• Right to access;
• Right to delete data;
• Right to restrict data processing;
• Right to be provided with data;
• Right to object data processing;
• Right to complain, denounce or initiate lawsuits;
• Right to claim for damages; and
• Right to self-protection.

You may exercise these rights by contacting us through the details in the Contact section, and we will respond to your requests regardless of the location in which your data is stored.

You have the following statutory obligations:

• Protect your own personal data;
• Request other relevant organizations and individuals to protect your personal data;
• Respect and protect personal data of others;
• Provide complete and accurate personal data upon giving consent to the processing of your personal data; and
• Other obligations under applicable laws.