PRIVACY POLICY

1.1 Bluente Pte. Ltd. ("Bluente","we","us"or "our")operates the language learning application currently available on the website(Bluente ), Apple App Store and Google Play Store (the "App") and the document translation software currently available via the website (BluTranslate - AI-Powered Professional Document Translator for Industries )(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 or the Tool.

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 our Privacy Policy and may change it from time to time without any prior notice.

1.3 In order to allow you to use or access the App, the Tool and any related software, solutions and services offered by us through the App or the Tool (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 any part thereof), you hereby agree to the terms and conditions set forth in thisPrivacy 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.

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 to exercise 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 and the English version of this Privacy Policy, the English version shall be the authoritative 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.

2.1 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:

If you decide to register an account for the Services through or otherwise grant Bluente access to any of the above third-party social media services, we may collectPersonal 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-PartyData") as publicized 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 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.

3.1 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 personal 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).

3.2 Your Personal Data is collected by us when you sign up for an account on the App or the Tool and also when you update your personal information 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 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, the Tool and the Services on theApple App Store or the 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.

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 and the Tool do 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 or 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 or the Tool may also collect or be provided with anonymised information about your behaviour and interactions on 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 is provided to such third-parties insofar as such data does not constitutePersonal Data.

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:

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 or 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 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, crime ware, online graffiti taggers, droppers, root kits, key loggers, 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, theTool or 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.

6.1 We may disclose your Personal Data:

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. 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.

7.1 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 theServices to you for as long as you maintain a user account on the App or the Tool.

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 or the Tool 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.

"Confidential Information" shall mean all information you disclose, upload, submit, or otherwise make available to Bluente via the Tool, including but not limited to documents, text, files, and any other data provided for translation purposes.

"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.

"Processed Content" refers to any Content that has been processed usingBluente's translation tool.

8.1 When using the Tool, the Confidential Information you provide to Bluente is not permanently stored; they are kept temporarily only as needed for transmitting and producing the Processed Content. Once the translation services agreed upon in the contract are fully performed, all Confidential Information, Content and Processed Content will be deleted. Additionally, your Confidential Information, Content and Processed Content 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 translationprocess:

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.

10.1 Residents of California have the right to:

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

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.

13.1 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 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.