Privacy Policy

PRIVACY POLICY
Last updated: 6 March 2025

1. INTRODUCTION

1.1 Bluente Pte. Ltd. (“Bluente”,"we","us"or "our")operates the language learning application currently available on the website(app.bluente.com), Apple App Store and Google Play Store (the “App”) and the documenttranslation software currently available via the website (translate.bluente.com)(the “Tool”).This page informs you of our policies regarding the collection, use anddisclosure of Personal Data we receive from users of the App or the Tool.

1.2 Personal Data means anydata that allows the identification of a natural person directly or indirectly.For example, combining various data may enable identifying a person even wheneach data separately would not allow that. Personal data can include many typesof data, such as a name, location data, an online identifier, IP address or thelike. We regularly review our Privacy Policy and may change it from time totime without any prior notice.

1.3 In order to allow you to use or access the App, the Tool and anyrelated software, solutions and services offered by us through the App or theTool (collectively referred to as the “Services”),it is necessary for Bluente to process your Personal Data in accordance withClauses 2 to 4 of this Privacy Policy. By connecting to, accessing or using the Services (or anypart thereof), you hereby agree to the terms and conditions set forth in thisPrivacy Policy, including the collection and processing of your Personal Dataas set forth in Clauses 2 to 4 of this Privacy Policy. If you disagree to anyterm provided in Clauses 2 to 4 of this Privacy Policy, you may not accessand/or use the Services (or any part thereof) in any manner whatsoever.

1.4 We are a private limited company registered under the laws ofSingapore, having its principal place of business at 9 Battery Road, #28-01,MYP Centre, Singapore 049910.

1.5 If you have questions about the Privacy Policy or want toexercise any of your rights mentioned in Clause 8, let us know by emailing our DataProtection Officer at support@bluente.com.

1.6 To enhance the general accessibility of this Privacy Policy,Bluente may publish translations of this Privacy Policy in other languages.However, in the event of any inconsistency between the translated versions andthe English version of this Privacy Policy, the English version shall be theauthoritative version and will take precedence.

1.7 We process your Personal Data in accordance with the PersonalData Protection Act 2012 in Singapore (“PDPA”)to the extent that such processing is necessary for the provision of ourServices to you, or where we are legally obliged to do so (e.g., storage forthe fulfilment of commercial or tax-related retention obligations, release inaccordance with official or judicial orders, e.g. to a law enforcementauthority). Where any form of processing is not necessary for theprovision of our Services to you and are for additional purposes (such asmarketing or the sending of promotional emails), we will only conduct suchprocessing with your specific and express consent.

2. WHAT INFORMATION IS COLLECTED

2.1 Depending on the extent and manner of your use of the Services,some examples of Personal Data which we may collect from you include your name,identification information, contact information such as your address, emailaddress or telephone number, nationality, gender, date of birth, maritalstatus, photographs and other audio-visual information, employment informationand financial information. For instance, when you sign up for an account on theApp and the Tool, you will be required to minimally provide your email address,name and password. Bluente also allows you to create and account and log in tothe Mobile App through the following third-party social media services:

(a) Apple;

(b) Google; and

If you decideto register an account for the Services through or otherwise grant Bluenteaccess to any of the above third-party social media services, we may collectPersonal Data that is associated with your third-party social media service’saccount, such as your name, your email address or contact list associated withthe said account.

2.2 The Services may contain advertisements by third-parties and/orlinks to independent third-party websites or other applications (“Third-Party Content”). Ifyou wish to subscribe to data, software, services and/or applications providedby third-parties (“Third-PartyData”) as publicized in the Third-Party Content available onthe Services, these third-parties may require that you enter into a legalcontract with them to conclude a transaction for the Third-Party Data. As partof the contracting process, they may ask you for additional Personal Data orrequest a confirmation of your identity. Any such information will be collected separately by thesethird-parties and not by us, and we advise you to read and familiarize yourselfwith their privacy policies. However, if such third-parties share your PersonalData with us, we will process the data in line with this Privacy Policy.

2.3 In the course of providing our Services, we utilise variousthird-party Software Development Kits (SDKs) to enhance user experience, offeradditional functionalities, and maintain the efficiency and security of our Services.These SDKs are integrated into our application and may collect certain types ofinformation when you, as the user, engage with features or functionalities thatrely on these SDKs.

2.4 Please be awarethat the activation or use of these third-party SDKs within our application mayresult in the collection of information, which could include, but is notlimited to, device identifiers, network information, usage data, and otherrelevant metrics. The specific types of information collected depend on thenature of the SDK and the functionality it provides can be found in Section 13 below.

3. HOW INFORMATION IS COLLECTED

3.1 We generally do not collect your personal data unless (a) it isprovided to us voluntarily by you directly or via a third-party who has beenduly authorised by you to disclose your personal data to us (your “Authorised Representative”)after (i) you (or your Authorised Representative) have been notified of thepurposes for which the personal data is collected, and (ii) you (or your AuthorisedRepresentative) have provided written consent to the collection and usage ofyour personal data for those purposes, or (b) collection and use of personaldata without consent is permitted or required by the PDPA or other laws. We shallseek your consent before collecting any additional personal data and beforeusing your personal data for a purpose which has not been notified to you(except where permitted or authorised by law).

3.2 Your Personal Data is collected by us when you sign up for anaccount on the App or the Tool and also when you update your personalinformation for your account or make any in-app purchases from the App or theTool. Certain aspects of the Services may also require the collection of your PersonalData should you elect to use them. For example, if you elect to utilise thespeech-to-text recognition function in the App, your voice data will becollected and processed for the purpose of providing you with the saidfunction.

3.3 Payment data. When yousubscribe to the access and use of the App, the Tool and the Services on theApple App Store or the Google Play Store or make other in-app purchases fromthe App and the Tool, your credit or debit card information (such as card typeand expiration date) and other financial data that are needed to process yourpayment may be collected and stored by us and/or the payment processors withwhich we work. The payment processors generally provide us with some limitedinformation related to you, such as a unique token that enables you to makeadditional purchases using the information that they have stored, and your cardtype, expiration date and certain digits of your card number.

3.4 Product research and development. We may contactyou from time to time to invite you to participate in product researchactivities, including but not limited to surveys, interviews, and other typesof feedback sessions. When you participate in these product researchactivities, the information you provide will be used to test, improve, anddevelop our products, including the App, the Tool and the Services. We maycollect and record the video, audio and text transcriptions of such productresearch activities that you participate in, together with any additionalcontact information you provide.

3.5 Online tracking. Please notethat the App and the Tool do not support “Do Not Track” browser settings and donot currently participate in any “Do Not Track” frameworks that would allow usto respond to signals or other mechanisms from you regarding the collection ofyour personal or non-personally identifiable information.

3.6 Your PersonalData may also be collected by analytics providers or other third-party servicesused by the App or the Tool if you have given your specific and express consentfor such collection. Other than Personal Data, third-party analytics providersor other third-party services used by the App or the Tool may also collect orbe provided with anonymised information about your behaviour and interactionson the App or the Tool. We shall have the right to unilaterally amend thisPrivacy Policy from time to time to reflect the information and data that isprovided to such third-parties insofar as such data does not constitutePersonal Data.

4. WHAT WE DO WITH YOUR INFORMATION

4.1 We process your Personal Data to provide our Services, to complywith any applicable laws, regulations, codes of practice, guidelines, or rules,or to assist in law enforcement and investigations conducted by anygovernmental and/or regulatory authority, and for any other purposes for whichyou have provided the information. Without prejudice to the generality of theforegoing, we may process your Personal Data for any or all of the followingpurposes:

(a) Provide you with a user account on the App or the Tool and allowyou to access and use the App, the Tool or Services;

(b) To verify your identity, update our records and generallymaintain your account with us;

(d) To process transactions;

(e) To process or arrange payment;

(f) To detect or monitor any frauds or other prohibited content,businesses or activities;

(g) To facilitate, confirm and/or provide updates or notificationsin relation to any transactions;

(h) Sending you marketing information about our Services;

(i) Transmitting to any unaffliated third-parties including our third-partyservice providers and agents, and relevant governmental and/or regulatoryauthorities, whether in Singapore or abroad, for the aforementioned purposes;and

(j) Any other incidental business purposes related to or inconnection with the above.

5. HOW IS THE PERSONAL DATA PROTECTED

5.1 The security of your information is important to us. We usesuitable technical and organizational security measures to protect against theloss, misuse and alteration of information under our control. We alsofollow generally accepted industry standards to protect the informationtransmitted to us over the Internet, both during transmission and once wereceive it via encryption techniques. Our security measures arecontinuously improved in line with technological developments.

5.2 However, no method of transmission over the Internet, or methodof electronic storage, is 100% secure. Therefore, while we strive to usecommercially acceptable means to protect your information, we cannot guaranteeits absolute security. It is important that you protect against unauthorisedaccess of your user account on the App or the Tool and information by choosingyour password carefully, and keeping your password and user account secure.Further, it shall be your sole responsibility to ensure that your device isfree from all types of viruses, malware, contamination, or destructive features(including but not limited to all viruses, malware, trojan horses, worms,adware, spyware, crimeware, online graffiti taggers, droppers, rootkits,keyloggers, bots, or other harmful software program or program elements) thatmay track, collect, modify or use any and all Personal Data you provide toBluente arising from or in connection with your access to and use of the App, theTool or the Services (including but not limited to your identificationinformation, contact information and payment-related information). To themaximum extent permitted by law, Bluenteshall not be responsible, and you expressly agree to not hold Bluente liable,for any loss or damages arising from or in connection with any loss, misuse oralteration to your Personal Data due to your failure to comply with this Clause5.2.

6. WHETHER WE SHARE OR TRANSFER YOUR PERSONALDATA

6.1 We may disclose your Personal Data:

(a) Where such disclosure is required for performing obligations inthe course of or in connection with our provisions of the Services to you;or

(b) To third-party service providers, agents and other organisationswe have engaged to perform any of the functions listed in Clause 4.1 above foror on our behalf.

6.2 Save as stated in Clause 6.1 above, we will generally not show,sell or rent your Personal Data to third-parties, unless we are required to doso by law, a court order or similar judgement, or unless we obtain your priorconsent.

6.3 By using our Services and the App, you authorise us to use your information in all countries where Bluente operates for the purposes mentioned above. In instances where we may transfer any Personal Data to another country, in accordance with Section 26 of the PDPA, we will ensure that any recipient of such Personal Data located outside Singapore is legally bound by enforceable obligations to provide a standard of protection that is comparable to the protection under the PDPA. These obligations may take the form of laws, contracts, or binding corporate rules. Where such protections are not available, we will obtain your consent or ensure that the transfer is otherwise permitted under the PDPA or applicable laws.

7. HOW LONG PERSONAL DATA WILL BE STORED FOR

7.1 We will retain your Personal Data for as long as it is relevantor necessary for the purpose for which it was collected and will delete anypersonal data that is no longer necessary for legal or business purposes. Thismeans that we will keep your Personal Data that is necessary to provide theServices to you for as long as you maintain a user account on the App or theTool.

7.2 We will also comply with any applicable laws or statutes whichobligate us to retain your Personal Data for a specific time period, such asthe mandatory retention periods under accounting laws and regulations. Inregards to any Personal Data that we process based on your consent, we willretain such Personal Data for as long as it is relevant for the purpose forwhich the data was collected, unless you withdraw your consent beforethat.

7.3 You may request to close your account on the App or the Tool atany time. We will delete all your Personal Data or remove the means by whichthe data can be associated with you when your account is closed within areasonable time period, unless there are applicable laws or statutes whichobligate or allow us to retain your Personal Data longer.

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8. PROCESSING OF SUBMITTEDFILES FOR TRANSLATION

"ConfidentialInformation" shall mean all information you disclose, upload,submit, or otherwise make available to Bluente via the Tool, including but notlimited to documents, text, files, and any other data provided for translationpurposes.
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“Content”refers to text of the documents you disclose, upload, submit, or otherwise makeavailable to Bluente via the translation tool, in order to have it processed bythe machine translation infrastructure operated by Bluente.
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“ProcessedContent” refers to any Content that has been processed usingBluente’s translation tool.

8.1 When using the Tool, the Confidential Information you provide toBluente is not permanently stored; they are kept temporarily only as needed fortransmitting and producing the Processed Content. Once the translation servicesagreed upon in the contract are fully performed, all Confidential Information,Content and Processed Content will be deleted. Additionally, your ConfidentialInformation, Content and Processed Content will not be utilized to enhance thequality of our services, nor will they or the processed content be permanentlystored on Bluente’s servers or returned to you.

8.2 The following data is stored temporarily for each translationprocess:

(a) MD5 hash of the file content

(b) File name, including the file extensions

(d) File size

(e) Status/ progress of the translation progress

(f) Selected language pair for translation

9. YOUR RIGHTS

9.1 You have rights in relation to your Personal Data. To exerciseany of your rights, please send us a written request in accordance withparagraph Clause 1.5 of this Privacy Policy.

(a) Right to access your Personal Data: You havethe right to obtain confirmation from us whether your Personal Data is beingprocessed. You also have the right to access your Personal Data and to obtaincertain information, such as the purposes of processing your Personal Data, thetypes of Personal Data involved, the duration of the retention, the source ofthe Personal Data, safeguards relating to the transfer, and a copy of the PersonalData.

(b) Right to rectification: You have theright to request us to correct in accurate Personal Data about you.

(c) Right to erasure: You have theright to request us to erase Personal Data about you in certain situations,such as if the Personal Data is no longer necessary for the purposes for whichit was collected, if processing such Personal Data is unlawful or if the datawas processed based on consent and you withdraw your consent.

(d) Right to restriction of processing yourPersonal Data: You have the right to restrict processing of your PersonalData in certain situations. If you exercise this right, we are generally onlyallowed to store the Personal Data in question. You might exercise this right,for example, if you believe that the Personal Data we hold about you isinaccurate, in which case your right to restriction of processing would applyfor the time that it takes us to verify whether your belief is correct.

(e) Right to data portability: You have theright to obtain your Personal Data in a structured, commonly used andmachine-readable format and to transfer the Personal Data to anothercontroller, if we process your Personal Data based on your consent or becauseof a contract that we have entered with you. For this right to be available toyou, our processing of your Personal Data must take place by automatedmeans.

(f) Right to withdraw your consent: To theextent we process your Personal Data based on your consent, you have the rightto withdraw your consent at any time. You can do so by sending an emailto support@bluente.com. The consentyou provide for the processing of your Personal Data will remain valid untilsuch time it is being withdrawn by you in the aforesaid manner. Withdrawingyour consent does not affect the lawfulness of processing of your Personal Databased on consent before its withdrawal, and does not affect our right toprocess your Personal Data where such processing without consent is permittedor required under applicable laws. We will endeavour to process the withdrawalrequest within ten (10) business days of receipt of the withdrawal email.Whilst we respect your decision to withdraw your consent, please note thatdepending on the nature and scope of your request, we may not be in a positionto continue providing the Services to you and we shall, in such circumstances,notify you before completing the processing of your request.

(g) Right to lodge complaint with supervisoryauthority: You have the right to lodge a complaint with the relevant dataprotection supervisory authority in your country, if you consider that theprocessing of your Personal Data infringes your rights under the lawsapplicable to you.

10.CALIFORNIA PRIVACY RIGHTS

10.1 Residents of California have the right to:

(a) Know what personal information we collect about you and fromwhere we collect it.

(b) Access a copy of the personal information we hold about you.

(d) Opt-out of having your personal information shared with certainthird parties.

(e) Request that we delete your account and personal information. Tomake such a request, please send an email to support@bluente.com

11.DO NOT TRACK

11.1 The Service is not designed to respond to “do not track” signalssent by some browsers.

12.AMENDMENTS TO THIS PRIVACY POLICY

12.1 We will need to amend this Privacy Policy on a regular basis andwithout any prior notice. Please check back regularly to view the latestversion of this Privacy Policy online and we will keep you informed ofimportant changes through the App and the Tool. Your continued use of the App,the Tool or the Services constitutes your acknowledge and acceptances of anysuch amendments to the Privacy Policy from time to time.

13.USE OF THIRD-PARTY SDKs

13.1 We assure you that the use of these SDKs is in line with our commitmentto privacy and data security. The collected information is utilized strictlyfor the purpose it is intended for, such as facilitating specific features(like payment processing, social media sharing, analytical insights, etc.),improving user experience, or ensuring the smooth operation of our services.

13.2 The use of these SDKs is context-specific andoccurs only when you engage with the particular function they support or whenlogging in using the services of the SDK provider. For example,information will only be collected by a payment SDK if you are conducting atransaction, or by a social media SDK if you are sharing content via thatplatform.

13.3 For detailed information on the types of data collected by eachthird-party SDK, their privacy practices, and how they handle your data, pleaserefer to the table below and the respective privacy policies of these SDKs,which are accessible through our application.

13.4 By using our services, you acknowledge and consent to thepotential collection of information by these third-party SDKs as part of ourservice provision. We recommend that you familiarize yourself with the privacypolicies of these third-party services to better understand how your data ishandled.

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Third-Party SDKList

SDK Name: QQInterconnect SDK

l ProviderName: Shenzhen Tencent Computer SystemCo., Ltd.

l CommunicationFeedback Channel: dataprivacy@tencent.com

l PrivacyPolicy Link: Privacy Policy

l BasicFunction of SDK: Sharing Service

l RelatedBusiness Requirements: QQ Sharing

l Purposeof Use: Sharing content to QQ

l InformationCollected: Android ID, APP information, WIFI name, Memory capacity, Emulatordetection, Network information, Device identification information (such asOAID, IMEI number, MAC address, Android ID, IDFA)

l OtherServices Included in SDK: com.tencent.tauth (QQ Login), com.tencent. connect,com.tencent.open

SDK Name:WeChat Open Platform

l ProviderName: Shenzhen Tencent Computer System Co., Ltd.

l CommunicationFeedback Channel: dataprivacy@tencent.com

l PrivacyPolicy Link: Privacy Policy

l BasicFunction of SDK: Content sharing to WeChat, WeChat Pay, WeChat Login services

l RelatedBusiness Requirements: WeChat Sharing, WeChat Login, WeChat Pay, etc.

l Purposeof Use: Sharing content to WeChat, using WeChat login and payment, etc.

l OtherServices Included in SDK: com.tencent.tauth (QQ Login), com.tencent.connect,com.tencent.open

SDK Name:Alipay Payment SDK

l ProviderName: Alibaba

l CommunicationFeedback Channel: 95188

l PrivacyPolicy Link: Privacy Policy

l BasicFunction of SDK: Payment Service

l RelatedBusiness Requirements: Alipay Payment

l Purposeof Use: To provide payment services to users

l InformationCollected: BSSID, WIFI name, Application version, Language, Network method,Carrier information, System version, Device model, UTDID, Android ID, APPinformation, WIFI name, Memory capacity, Emulator detection, Networkinformation, Device identification information (such as OAID, IMEI number, MACaddress, Android ID, IDFA), Payment amount (only in payment scenarios)

l OtherServices Included in SDK: com.alipay

SDK Name:WeChat Payment SDK

l ProviderName: Tencent

l CommunicationFeedback Channel: 95017-2

l PrivacyPolicy Link: Privacy Policy

l BasicFunction of SDK: Payment Service

l RelatedBusiness Requirements: WeChat Payment

l Purposeof Use: To provide payment services to users

l InformationCollected: APP information, Device model, Operating system version, Uniquedevice identifier, IP address, Service log information, Communication loginformation, Geographical location information

l OtherServices Included in SDK: com.tencent.open

SDK Name:RevenueCat SDK

l ProviderName: RevenueCat

l CommunicationFeedback Channel: compliance@revenuecat.com

l PrivacyPolicy Link: Privacy Policy

l BasicFunction of SDK: Payment Service

l RelatedBusiness Requirements: iOS In-App Purchases

l Purposeof Use: To provide payment services to users

SDK Name:BranchIO SDK

l ProviderName: BranchIO

l CommunicationFeedback Channel: support@branch.io

l PrivacyPolicy Link: PrivacyPolicy

l Basic Functionof SDK: Data Analytics

l RelatedBusiness Requirements: Data collection and statistical analysis

l Purposeof Use: Data collection and statistical analysis

SDK Name:Amplitude SDK

l ProviderName: Amplitude

l CommunicationFeedback Channel:privacy@amplitude.com

l PrivacyPolicy Link: Privacy Policy

l BasicFunction of SDK: Data Analytics

l RelatedBusiness Requirements: Data collection and analysis

l Purposeof Use: To provide payment services to users

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