PRIVACY POLICY 
Last updated: 23 Nov 2023 

1. INTRODUCTION
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1.1 Bluente Pte Ltd (“Bluente”, "we", "us" or "our") operates a language learning application currently available on the website (app.bluente.com),Apple App Store and Google Play Store (the “App”) and a translation software currently available via the website (the “Tool”). This page informs you of our policies regarding the collection, use and disclosure of Personal Data we receive from users of the App and the Tool.
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1.2 Personal Data means any data that allows the identification of a natural person directly or indirectly. For example, combining various data may enable identifying a person even when each data separately would not allow that. Personal data can include many types of data, such as a name, location data, an online identifier, IP address or the like. We regularly review ourPrivacy Policy and may change it from time to time without any prior notice. 
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1.3 In order to allow you to use or access the App the Tool and all software and services offered through the App and the Tool (collectively referred to as the “Services”),it is necessary for Bluente to process your Personal Data in accordance with Clauses 2 to 4 of this Privacy Policy. By connecting to, accessing or using the Services (or any part there of), you hereby agree to the terms and conditions set forth in this Privacy Policy, including the collection and processing of your Personal Data as set forth in Clauses 2 to 4 of this Privacy Policy. If you disagree to any term provided in Clauses 2 to 4 of this Privacy Policy, you may not access and/or use the Services (or any part thereof) in any manner whatsoever.
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1.4 We are a private limited company registered under the laws of Singapore, which is located at 140 Paya Lebar Rd, #08-24,Singapore 409015.
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1.5 If you have questions about the Privacy Policy or want to exercise any of your rights mentioned in Clause 8, let us know by emailing our data protection officer at support@bluente.com.
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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 and the English version of this Privacy Policy, the English version shall be the authoritative version and will take precedence.
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1.7 We process your Personal Data in accordance with the Personal Data Protection Act 2012 in Singapore (“PDPA”) to the extent that such processing is necessary for the provision of our Services to you, or where we are legally obliged to do so (e.g., storage for the fulfilment of commercial or tax-related retention obligations, release in accordance with official or judicial orders, e.g. to a law enforcement authority).  Where any form of processing is not necessary for the provision of our Services to you and are for additional purposes (such as marketing or the sending of promotional emails), we will only conduct such processing with your specific and express consent.
 
2. WHAT INFORMATION IS COLLECTED
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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, email address or telephone number, nationality, gender, date of birth, marital status, photographs and other audio-visual information, employment information and financial information. For instance, when you signup for an account on the App 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 to the Mobile App through the following third-party social media services: 
(a) Apple; and 

(b) Google; and

(c) WeChat 

If you decide to register an account for theServices through or otherwise grant Bluente access to any of the above third party social media service, we may collect Personal Data that is associated with your third party social media service’s account, such as your name, your email address or contact list associated with the said account.

2.2 The Services may contain advertisements by third parties and/or links to independent third party websites or other applications (“Third Party Content”).If you wish to subscribe to data, software, services and/or applications provided by third parties (“Third Party Data”) as publicised in the Third Party Content available on the Services, these third parties may require that you enter into a legal contract with them to conclude a transaction for the Third Party Data. As part of the contracting process, they may ask you for additional Personal Data or request a confirmation of your identity. Any such information will be collected separately by these third parties and not by us, and we advise you to read and familiarize yourself with their privacy policies. However, if such third parties share your Personal Data with us, we will process the data in line with this Privacy Policy. 

2.3 In the course of providing our services, we utilize various third-party Software Development Kits (SDKs) to enhance user experience, offer additional functionalities, and maintain the efficiency and security of our services. These SDKs are integrated into our application and may collect certain types of information when you, as the user, engage with features or functionalities that rely on these SDKs.

2.4 Please be aware that the activation or use of these third-party SDKs within our application may result in the collection of information, which could include, but is not limited to, device identifiers, network information, usage data, and other relevant metrics. The specific types of information collected depend on the nature of the SDK and the functionality it provides can be found in Section 13 below.

3. HOW INFORMATION IS COLLECTED
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3.1 We generally do not collect your personal data unless (a) it is provided to us voluntarily by you directly or via a third party who has been duly authorised by you to disclose your personal data to us(your “authorised representative”)after (i) you (or your authorised representative) have been notified of the purposes for which the data is collected, and (ii) you (or your authorised representative) have provided written consent to the collection and usage of your personal data for those purposes, or (b) collection and use of personal data without consent is permitted or required by the PDPA or other laws. We shall seek your consent before collecting any additional personal data and before using your personal data for a purpose which has not been notified to you (except where permitted or authorised by law).
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3.2 Your Personal Data is collected by us when you sign up for an account on the App and also when you update your personal information for your account or make any in-app purchases the Data from theApp. Certain aspects of the Services may also require the collection of yourPersonal Data should you elect to use them. For example, if you elect to utilise the speech-to-text recognition function in the App, your voice data will be collected and processed for the purpose of providing you with the said function. 
3.3 Payment data. When you subscribe to the access and use of the App and Services on the Apple App Store or Google Play Store or make other in-app purchases from the App and the Tool, your credit or debit card information (such as card type and expiration date)and other financial data that are needed to process your payment may be collected and stored by us and/or the payment processors with which we work.The payment processors generally provide us with some limited information related to you, such as a unique token that enables you to make additional purchases using the information that they have stored, and your card type, expiration date and certain digits of your card number.
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3.4 Product research and development. We may contact you from time to time to invite you to participate in product research activities, including but not limited to surveys, interviews, and other types of feedback sessions. When you participate in these product research activities, the information you provide will be used to test, improve, and develop our products, including the App, the Tool and the Services. We may collect and record the video, audio and text transcriptions of such product research activities that you participate in, together with any additional contact information you provide.

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

3.6 Your Personal Data may also be collected by analytics providers or other third party services used by the App and the Tool if you have given your specific and express consent for such collection. Other than Personal Data, third party analytics providers or other third party services used by the App and the Tool may also collect or be provided with anonymised information about your behaviour and interactions on the App and the Tool. We shall have the right to unilaterally amend this Privacy Policy from time to time to reflect the information and data that is provided to such third parties insofar as such data does not constitute Personal Data.

4 WHAT WE DO WITH YOUR INFORMATION
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4.1 We process your Personal Data to provide our Services, to comply with any applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority, and for any other purposes for which you have provided the information. Without prejudice to the generality of the foregoing, we may process your Personal Data for any or all of the following purposes:
(a) Provide you with a user account on the App and the Tool and allow you to access and use the App and Services;
(b) To verify your identity, update our records and generally maintain your account with us;
(c) Develop, operate, improve, deliver and maintain our Services;
(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 notifications in relation to any transactions;
(h) Sending you marketing information about our Services;
(i) Transmitting to any unaffliated third parties including our third party service providers and agents, and relevant governmental and/or regulatory authorities, whether in Singapore or abroad, for the aforementioned purposes; and
(j) Any other incidental business purposes related to or in connection with the above.

5. HOW IS THE PERSONAL DATA PROTECTED
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5.1 The security of your information is important to us. We use suitable technical and organizational security measures to protect against the loss, misuse and alteration of information under our control.  We also follow generally accepted industry standards to protect the information transmitted to us over the Internet, both during transmission and once we receive it via encryption techniques. Our security measures are continuously improved in line with technological developments.

5.2 However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your information, we cannot guarantee its absolute security. It is important that you protect against unauthorised access of your user account on the App and the Tool and information by choosing your password carefully, and keeping your password and user account secure. Further, it shall be your sole responsibility to ensure that your mobile device is free 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) that may track, collect, modify or use any and all Personal Data you provide to Bluente arising from or in connection with your access to and use of the App and the Tool and the Services (including but not limited to your identification information, contact information and payment-related information). To the maximum extent permitted by law, Bluente shall 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 or alteration to your Personal Data due to your failure to comply with this Clause 5.2.

6. WHETHER WE SHARE OR TRANSFER YOUR PERSONAL DATA
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6.1 We may disclose your Personal Data: 
(a) Where such disclosure is required for performing obligations in the course of or in connection with our provisions of the Services to you; or 
(b) To third party service providers, agents and other organisations we have engaged to perform any of the functions listed in Clause 4.1 above for or 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 do so by law, a court order or similar judgement, or unless we obtain your prior consent.

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. We will ensure that your information is transferred in accordance with this Privacy Policy and protected in accordance with applicable laws on personal data protection.

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7. HOW LONG PERSONAL DATA WILL BE STORED FOR
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7.1 We will retain your Personal Data for as long as it is relevant or necessary for the purpose for which it was collected and will delete any personal data that is no longer necessary for legal or business purposes. This means that we will keep your Personal Data that is necessary to provide the Services to you for as long as you maintain a user account on App.

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

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

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8. PROCESSING OF SUBMITTED FILES FOR TRANSLATION

8.1 When using Blu Translate, the texts or documents you submit are not permanently stored; they are kept temporarily only as needed for producing and transmitting the translation. Once the translation services agreed upon in the contract are fully performed, all submitted texts, documents, and their translations will be deleted. Additionally, your texts will not be utilized to enhance the quality of our services, nor will they or the processed content be permanently stored on Bluente’s servers or returned to you.

8.2 The following data is stored temporarily for each translation process:

- MD5 hash of the file content

- File name, including the file extensions

- Number of pages

- File size

- Status/ progress of the translation progress

- Selected language pair for translation

9. YOUR RIGHTS
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9.1 You have rights in relation to your PersonalData. To exercise any of your rights, please send us a written request in accordance with paragraph Clause 1.5 of this Privacy Policy.

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(a) Right to access your Personal Data: You have the right to obtain confirmation from us whether your Personal Data is being processed. You also have the right to access your Personal Data and to obtain certain information, such as the purposes of processing your Personal Data, the types of Personal Data involved, the duration of the retention, the source of the Personal Data, safeguards relating to the transfer, and a copy of thePersonal Data. 
(b) Right to rectification: You have the right to request us to correct in accurate Personal Data about you. 
(c) Right to erasure: You have the right to request us to erase PersonalData about you in certain situations, such as if the Personal Data is no longer necessary for the purposes for which it was collected, if processing suchPersonal Data is unlawful or if the data was processed based on consent and you withdraw your consent. 
(d) Right to restriction of processing your Personal Data: You have the right to restrict processing of your Personal Data in certain situations. If you exercise this right, we are generally only allowed 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 is inaccurate, in which case your right to restriction of processing would apply for the time that it takes us to verify whether your belief is correct.
(e) Right to data portability: You have the right to obtain your Personal Data in a structured, commonly used and machine-readable format and to transfer the Personal Data to another controller, if we process your Personal Data based on your consent or because of a contract that we have entered with you. For this right to be available to you, our processing of your Personal Data must take place by automated means. 
(f) Right to withdraw your consent: To the extent we process your Personal Data based on your consent, you have the right to withdraw your consent at any time. You can do so by sending an email to support@bluente.com.The consent you provide for the processing of your Personal Data will remain valid until such time it is being withdrawn by you in the aforesaid manner.Withdrawing your consent does not affect the lawfulness of processing of yourPersonal Data based on consent before its withdrawal, and does not affect our right to process your Personal Data where such processing without consent is permitted or required under applicable laws. We will endeavour to process the withdrawal request within ten (10-) business days of receipt of the withdrawal email. Whilst we respect your decision to withdraw your consent, please note that depending on the nature and scope of your request, we may not be in a position to 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 supervisory authority: You have the right to lodge a complaint with the relevant data protection supervisory authority in your country, if you consider that the processing of your Personal Data infringes your rights under the laws applicable to you.


10. CALIFORNIA PRIVACY RIGHTS

10.1 Residents of California have the right to:
- Know what personal information we collect about you and from where we collect it.
- Access a copy of the personal information we hold about you.
- Understand how we process your personal information and how it may be shared.
- Opt out of having your personal information shared with certain third parties.
- Request that we delete your account and personal information. To make such a request, please send an email to support@bluente.com

11. DO NOT TRACK

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

12. AMENDMENTS TO THIS PRIVACY POLICY
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12.1 We will need to amend this Privacy Policy on a regular basis and without any prior notice. Please check back regularly to view the latest version of this Privacy Policy online and we will keep you informed of important changes through the App and the Tool. Your continued use of the App, the Tool and the Services constitutes your acknowledge and acceptances of any such 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 commitment to privacy and data security. The collected information is utilized strictly for 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 and occurs only when you engage with the particular function they support or when logging in using the services of the SDK provider. For example, information will only be collected by a payment SDK if you are conducting a transaction, or by a social media SDK if you are sharing content via that platform.

13.3 For detailed information on the types of data collected by each third-party SDK, their privacy practices, and how they handle your data, please refer 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 the potential collection of information by these third-party SDKs as part of our service provision. We recommend that you familiarize yourself with the privacy policies of these third-party services to better understand how your data is handled.

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