CuddlePrivacy Policy

Last Updated: March 4, 2026

THIRD HUB GLOBAL PTE. LTD. (“Company,” “we,” “us,” or “our”) respects your privacy and is committed to protecting the personal information of individuals who access or use the Cuddle platform, mobile applications, website, and related services (collectively, the “Service”).

This Privacy Policy describes how we collect, use, disclose, and otherwise process personal information in connection with your access to and use of the Service.

This Privacy Policy applies to personal information collected through:

• the Cuddle website and platform;
• user accounts and profiles;
• communications conducted through the Service;
• customer support interactions; and
• other interactions with the Company relating to the Service.

By accessing or using the Service, you acknowledge that your personal information will be processed as described in this Privacy Policy. If you do not agree with this Privacy Policy, you should not access or use the Service.

Scope of This Privacy Policy

This Privacy Policy applies to personal information processed by the Company in connection with operating and providing the Service.

This Privacy Policy does not apply to:

• information collected by third-party websites or services not controlled by the Company;
• information collected by other users through interactions with you on the Service; or
• third-party services integrated with the Service (such as payment processors or analytics providers).

You should review the privacy policies of any third-party services you interact with through the Service.

Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, Service features, or applicable legal requirements.

When we update this Privacy Policy, we will revise the “Last Updated” date above. If we make material changes, we may provide additional notice where appropriate, including by email or through notices within the Service.

Your continued access to or use of the Service after any updates become effective constitutes your acceptance of the updated Privacy Policy.

1. Information We Collect

We collect personal information in connection with your access to and use of the Service. The types of personal information we collect depend on how you interact with the Service, the features you use, and the information you choose to provide.

For purposes of applicable privacy laws, including the California Consumer Privacy Act (CCPA) and other U.S. state privacy laws, the categories of personal information we collect may include identifiers, commercial information, internet or other electronic network activity information, geolocation data, profile and user-generated content, and other information described below.

We collect personal information from the following sources:

• information you provide directly to us;
• information collected automatically through your use of the Service; and
• information we obtain from third parties.

1.1 Information You Provide to Us

We collect personal information that you voluntarily provide when you create an account, build a profile, communicate with other users, purchase paid features, contact customer support, or otherwise interact with the Service.

This information may include the following categories:

Account Information

When you register for an account, we collect information necessary to create and maintain your account, which may include:

• name or nickname
• email address
• account credentials (such as passwords)
• account preferences
• age or date of birth
• authentication information.

We may also collect information necessary to verify eligibility for the Service, including confirmation that you meet the minimum age requirements.

Profile Information

The Service allows users to create profiles and share information with other users. Profile information may include:

• profile photographs or images
• profile descriptions or biographical information
• interests, preferences, and relationship intentions
• demographic information
• location or approximate location information
• other information you choose to include in your profile.

Profile information may be visible to other users of the Service depending on your account settings and the functionality of the platform.

Because the Service is designed to facilitate connections between individuals, profile information you choose to share may be viewed by other users and may be copied, saved, or redistributed by them outside the Service.

User Communications and Interactions

The Service enables users to communicate with one another through messaging and other interaction features.

We collect information associated with these communications, including:

• messages sent through the Service
• reactions, comments, or other interaction signals
• reports or feedback submitted by users.

The Company does not routinely monitor or review private communications between users. However, we may access, review, or preserve such communications where reasonably necessary to:

• enforce our Terms of Service or Community Guidelines
• investigate reports of misconduct, harassment, fraud, or abuse
• protect the safety and security of users
• comply with legal obligations or lawful requests by authorities.

Transaction and Payment Information

If you purchase subscriptions or paid features through the Service, payment information may be collected and processed by third-party payment processors.

We may receive limited information related to such transactions, which may include:

• transaction confirmation details
• subscription status
• billing identifiers
• payment method type.

We do not store full payment card numbers on our systems.

Customer Support and Communications with Us

If you contact us directly (for example, through customer support channels, email, or in-app reporting tools), we may collect information including:

• your contact information
• the contents of your communications
• records of support requests
• any attachments, screenshots, or additional information you choose to provide.

We use this information to investigate issues, respond to inquiries, and improve the Service.

Sensitive or Discretionary Information

Because the Service is designed to facilitate private connections between individuals, users may choose to disclose information that could be considered sensitive in nature, including information about:

• relationship status
• personal preferences
• private communications
• personal photographs or media.

You should exercise caution when choosing to disclose personal or sensitive information through the Service, as other users may retain or share such information outside the platform.

The Company does not require users to disclose sensitive personal information beyond what is necessary to operate the Service.

Information You Choose to Provide Voluntarily

We may also collect information that you voluntarily provide through:

• surveys
• feedback submissions
• research participation
• promotional campaigns
• feature testing programs.

Providing such information is optional.

1.2 Information Collected Automatically

When you access or use the Service, we and our service providers may automatically collect certain information about your device, your use of the Service, and your interactions with the platform. This information is collected through technologies such as server logs, cookies, device identifiers, and similar tracking technologies.

The categories of information collected automatically may include the following.

Device Information

We may collect information about the device you use to access the Service, which may include:

• device type and model
• operating system and version
• browser type and version
• device identifiers
• mobile network information
• language settings
• application version and configuration.

This information helps us ensure compatibility, maintain system performance, and improve the functionality of the Service.

Log and Usage Data

We automatically collect certain information about how you access and interact with the Service. This information may include:

• IP address
• access times and session duration
• pages or features viewed
• search activity and interaction patterns
• links clicked
• referring or exit pages
• application crash reports and diagnostic data.

This information is used to operate the Service, analyze usage trends, troubleshoot technical issues, and improve the user experience.

Location Information

We may collect information about your general location when you access the Service.

Location information may include:

• approximate geographic location derived from IP address
• device-based location signals where permitted by device settings
• regional or country-level location data.

This information may be used to:

• enable location-based features of the Service
• display relevant profiles
• maintain platform safety and integrity
• comply with applicable legal or regulatory requirements.

We do not collect precise GPS location data unless you explicitly permit such collection through your device settings.

Cookies and Similar Technologies

We and our service providers may use cookies, local storage, and similar technologies to collect information about your interactions with the Service.

These technologies may be used to:

• authenticate user sessions
• remember user preferences and settings
• maintain security and fraud prevention systems
• analyze platform usage and performance
• improve functionality and user experience.

Additional details about our use of cookies and similar technologies are available in our Cookie Policy.

Platform Integrity and Fraud Prevention Signals

To protect the safety and integrity of the Service, we may automatically collect technical signals and behavioral indicators used to detect fraud, abuse, or unauthorized activity.

Such signals may include:

• device identifiers and device characteristics
• account activity patterns
• login attempts and authentication events
• indicators of automated or bot activity
• signals associated with suspicious or abusive behavior.

These measures help us prevent fraudulent accounts, enforce our Terms of Service, and maintain a safe environment for users.

Moderation and Safety Signals

To maintain community safety and enforce platform policies, we may collect information related to moderation and safety systems, including:

• reports submitted by users
• indicators of policy violations
• interactions associated with abusive or harmful conduct.

Where necessary, automated systems and internal review processes may analyze these signals to detect violations of our policies or risks to user safety.

Analytics Information

We may use analytics technologies to understand how users interact with the Service. Analytics providers may collect information such as:

• device identifiers
• IP address
• usage activity
• interaction events
• system performance metrics.

This information helps us analyze trends, improve product features, and optimize platform performance.

De-Identified and Aggregated Data

We may aggregate or de-identify information collected automatically so that it can no longer reasonably be used to identify an individual.

Such aggregated or de-identified information may be used for lawful business purposes, including analytics, product development, research, and service improvement.

1.3 Information We Receive from Third Parties

We may receive personal information about you from third parties in connection with your use of the Service, the operation of our platform, and the protection of user safety and platform integrity.

The categories of third-party sources from which we may receive information include the following.

Payment Processors and Transaction Providers

If you purchase subscriptions or other paid features through the Service, payment transactions may be processed by third-party payment processors.

These payment processors may provide us with limited transaction-related information, which may include:

• transaction confirmation details
• subscription status
• payment method type
• billing identifiers
• transaction timestamps.

We do not receive or store full payment card numbers or other sensitive payment credentials processed by third-party payment processors.

App Store and Platform Providers

If you access the Service through a mobile application distributed via app stores or platform providers (such as Apple App Store or Google Play), those providers may share certain information with us, including:

• confirmation of application downloads or installations
• subscription purchase confirmations
• application version information
• device or platform identifiers.

The collection and processing of information by such platform providers is governed by their respective privacy policies.

Analytics and Technology Service Providers

We may receive information from analytics providers, infrastructure providers, and other technology partners that help us operate and improve the Service.

Such information may include:

• usage analytics
• performance and system diagnostics
• aggregated or pseudonymous identifiers
• device or technical signals associated with platform usage.

This information helps us analyze product performance, understand user behavior, and improve the functionality of the Service.

Identity Verification and Fraud Prevention Providers

To protect the integrity of the Service and reduce fraudulent or abusive activity, we may receive information from third-party service providers that assist with:

• identity verification
• account authentication
• fraud detection
• abuse prevention.

Such providers may supply risk signals, verification results, or other indicators that help us determine whether accounts comply with our Terms of Service and applicable policies.

Other Users of the Service

We may receive information about you from other users of the Service.

For example, users may provide information about you when they:

• interact with you through the platform
• report suspected misconduct or policy violations
• submit feedback or complaints involving your account.

We may review and process such information as part of our efforts to maintain user safety, investigate potential violations, and enforce our policies.

Advertising, Marketing, or Referral Partners

In certain circumstances, we may receive limited information from marketing partners, referral programs, or promotional campaigns that help users discover the Service.

This information may include:

• referral identifiers
• campaign attribution data
• aggregated engagement information.

We use such information to measure the effectiveness of marketing efforts and improve how we promote the Service.

Publicly Available Sources

In limited circumstances and where permitted by applicable law, we may obtain information from publicly available sources for purposes such as:

• preventing fraud or abuse
• verifying account authenticity
• protecting the safety and integrity of the Service.

Combination of Information

We may combine information received from third parties with information we collect directly from you or automatically through your use of the Service.

We use such combined information in accordance with this Privacy Policy, including to operate the Service, improve functionality, enforce our policies, and maintain platform security.

2. How We Use Personal Information

We use personal information for a variety of purposes related to operating, maintaining, securing, and improving the Service. The specific ways in which we use personal information depend on how you interact with the Service and the features you use.

In general, we process personal information for the following purposes.

2.1 Providing and Operating the Service

We use personal information to operate, maintain, and deliver the Service and its core functionality. This may include using personal information to:

• create, authenticate, and manage user accounts
• enable users to create and maintain profiles
• facilitate user matching, discovery, and interactions
• provide messaging and communication features
• enable subscriptions and paid features
• process transactions and manage billing relationships
• maintain platform functionality and system performance.

These activities are necessary to provide the Service and fulfill our contractual obligations to users.

2.2 Personalization and Matching Functionality

The Service is designed to facilitate connections between users. We may use personal information to personalize the user experience and enable relevant matching functionality.

This may include using personal information to:

• recommend profiles or connections
• personalize content, features, or search results
• display profiles to other users based on preferences or activity
• improve the relevance of user discovery features.

Matching and personalization features may rely on profile information, preferences, activity signals, and other information associated with your use of the Service.

2.3 Communications

We use personal information to communicate with users regarding the Service. Such communications may include:

• account-related notifications
• service announcements and updates
• responses to user inquiries or support requests
• notifications related to safety, moderation, or policy enforcement
• transactional or administrative messages.

Where permitted by applicable law, we may also send communications regarding new features, updates, or other information related to the Service.

Users may have the ability to manage certain communication preferences through account settings.

2.4 Safety, Security, and Platform Integrity

Protecting the safety of users and maintaining the integrity of the Service are important aspects of operating a platform that facilitates user interactions.

We may use personal information to:

• detect, investigate, and prevent fraud, abuse, harassment, or other harmful conduct
• identify and prevent automated accounts, bots, or unauthorized activity
• enforce our Terms of Service, Community Guidelines, and other policies
• investigate reports submitted by users
• protect the rights, property, and safety of the Company, our users, and the public.

These activities may involve automated systems and manual review processes designed to identify and address potential violations of platform policies.

2.5 Service Improvement, Research, and Analytics

We use personal information to understand how users interact with the Service and to improve the functionality, reliability, and performance of the platform.

Such activities may include:

• analyzing usage patterns and feature engagement
• troubleshooting technical issues and diagnosing system errors
• conducting internal research and product development
• testing and improving product features and user experience
• measuring platform performance and service quality.

In some cases, these activities may involve the use of aggregated or de-identified information.

2.6 Fraud Prevention and Risk Management

We may process personal information to identify and mitigate risks associated with fraud, unauthorized access, account misuse, or other harmful activity.

This may include using information to:

• monitor account activity for suspicious behavior
• detect fraudulent transactions or payment abuse
• identify duplicate or fraudulent accounts
• enforce platform safeguards designed to maintain a trusted user environment.

2.7 Compliance with Legal Obligations

We may use personal information where necessary to comply with applicable laws, regulations, legal processes, or governmental requests.

This may include processing personal information to:

• comply with legal or regulatory obligations
• respond to lawful requests from courts, law enforcement, or government authorities
• maintain records required under applicable law
• enforce our legal rights or defend against legal claims.

2.8 Business Operations

We may use personal information to support our legitimate business operations, including:

• internal administration and recordkeeping
• financial reporting and audits
• corporate governance and compliance activities
• planning, analytics, and strategic decision-making.

In the event of a merger, acquisition, financing, restructuring, or other corporate transaction, personal information may be processed as part of evaluating or completing such transactions.

2.9 With Your Consent

In certain situations, we may process personal information for additional purposes with your consent or at your direction.

Where consent is required under applicable law, you may withdraw your consent at any time, subject to legal or contractual restrictions.

3. How We Share Personal Information

We may disclose personal information to third parties in connection with operating the Service, maintaining platform safety, conducting our business operations, and complying with legal obligations.

The categories of recipients to whom we may disclose personal information include the following.

3.1 Other Users of the Service

Because the Service is designed to facilitate connections between individuals, certain personal information is shared with other users of the Service as part of the platform’s core functionality.

You understand and agree that profile information and other content you choose to make available through the Service may be visible to other users of the Service.

For example, other users may be able to view information such as:

• your profile information
• photographs or media you upload
• profile descriptions and preferences
• approximate location information
• other content you choose to share through the Service.

Information you share through messaging, interactions, or other features of the Service may also be visible to the users with whom you communicate.

You acknowledge that information you voluntarily share with other users may be viewed, copied, saved, or redistributed by those users outside of the Service (including by taking screenshots or otherwise capturing content). The Company does not control and is not responsible for how other users may use information you choose to share with them.

You should exercise caution when sharing personal or sensitive information with others through the Service.

3.2 Service Providers

We may share personal information with third-party vendors, contractors, and service providers that perform services on our behalf.

These service providers are authorized to use personal information only as necessary to provide services to the Company and in accordance with our instructions.

Such service providers may include, for example:

• cloud hosting and infrastructure providers
• payment processing providers
• customer support service providers
• analytics and technology providers
• fraud detection and security service providers
• communications and notification providers.

We may require service providers to implement appropriate safeguards designed to protect personal information.

3.3 Corporate Affiliates

We may share personal information with our corporate affiliates, subsidiaries, or related entities for purposes consistent with this Privacy Policy, including operational, administrative, security, or compliance purposes.

Such affiliates may process personal information in accordance with this Privacy Policy and applicable law.

3.4 Business Transfers

Personal information may be disclosed or transferred in connection with a corporate transaction, including:

• a merger
• acquisition
• financing
• asset sale
• restructuring
• bankruptcy or similar proceeding.

In such circumstances, personal information may be transferred as part of the transaction and may become subject to a different privacy policy.

3.5 Legal Obligations and Protection of Rights

We may disclose personal information where we believe disclosure is necessary to:

• comply with applicable laws, regulations, legal processes, or governmental requests
• respond to lawful requests by courts, law enforcement, or regulatory authorities
• enforce our Terms of Service or other policies
• investigate suspected fraud, abuse, or violations of our policies
• protect the rights, property, or safety of the Company, our users, or the public.

3.6 Safety and Platform Integrity

To maintain a safe and trusted platform environment, we may disclose personal information to third parties where reasonably necessary to:

• investigate reports of misconduct or harmful activity
• address safety risks affecting users
• enforce platform rules and policies
• prevent fraud, harassment, or other abusive conduct.

Such disclosures may occur in cooperation with service providers, security partners, or relevant authorities where appropriate.

3.7 With Your Consent or Direction

We may disclose personal information to third parties with your consent or at your direction.

For example, if you choose to interact with third-party services integrated with the Service, we may share information as necessary to enable those interactions.

3.8 Aggregated or De-Identified Information

We may share aggregated, anonymized, or de-identified information that cannot reasonably be used to identify an individual.

Such information may be used for purposes such as analytics, research, product development, or improving the Service.

3.9 No Sale of Personal Information

The Company does not sell personal information as defined under applicable privacy laws.

We also do not share personal information for cross-context behavioral advertising or similar targeted advertising purposes.

4. Cookies and Tracking Technologies

We and our service providers may use cookies and similar technologies to collect information about your interactions with the Service, to operate and secure the platform, and to improve the functionality and performance of the Service.

This section explains the types of technologies we use and how they may be used in connection with the Service.

4.1 Cookies

Cookies are small text files that are stored on your device when you visit a website or use an online service.

Cookies allow us to recognize your device and store certain information about your preferences or past actions in order to improve your experience.

We may use cookies for purposes such as:

• maintaining user sessions and authentication
• remembering user preferences and settings
• enabling core functionality of the Service
• maintaining platform security and fraud prevention systems
• analyzing usage patterns and improving platform performance.

Cookies may be set by the Company or by third-party service providers acting on our behalf.

4.2 Types of Cookies We Use

We may use several categories of cookies and similar technologies.

Essential Cookies

These cookies are necessary for the operation of the Service and enable core functionality such as:

• account authentication
• security features
• network management
• platform stability.

Because these cookies are essential to the operation of the Service, they cannot be disabled through our systems.

Performance and Analytics Cookies

These cookies collect information about how users interact with the Service, such as which pages are visited most frequently and whether users encounter errors.

These cookies help us:

• understand how the Service is used
• measure platform performance
• improve system functionality and user experience.

Information collected through these cookies is generally aggregated or pseudonymous.

Functionality Cookies

These cookies allow the Service to remember choices you make, such as:

• language preferences
• display settings
• account preferences.

These cookies help provide a more personalized experience when you use the Service.

4.3 Similar Tracking Technologies

In addition to cookies, we may use other technologies to collect information about how users interact with the Service.

These technologies may include:

• local storage technologies
• device identifiers
• log files
• application programming interfaces used for analytics or performance monitoring.

These technologies help us maintain platform functionality, analyze usage patterns, and protect the integrity of the Service.

4.4 Analytics Providers

We may use third-party analytics services to help us understand how users interact with the Service.

These analytics providers may collect information such as:

• IP address
• device identifiers
• browser type
• pages visited
• interaction events and usage patterns.

This information helps us analyze trends, improve product features, and optimize the performance of the Service.

Analytics providers may use cookies or other technologies to collect such information in accordance with their own privacy policies.

4.5 Managing Cookies

Most web browsers allow users to control cookies through their browser settings.

Depending on your browser, you may be able to:

• block or delete cookies
• receive notifications when cookies are used
• limit certain types of tracking technologies.

Please note that disabling certain cookies may affect the functionality or availability of some features of the Service.

4.6 Global Privacy Controls

Some browsers or browser extensions may transmit signals indicating a user’s preference regarding tracking technologies.

Where required by applicable law, we will process such signals in accordance with applicable legal requirements.

4.7 Additional Information

Additional details regarding our use of cookies and similar technologies may be provided in our Cookie Policy or other supplemental notices.

For more information about how we process personal information collected through cookies and similar technologies, please refer to the other sections of this Privacy Policy.

5. Data Retention

We retain personal information for as long as reasonably necessary to fulfill the purposes described in this Privacy Policy, including to provide the Service, maintain user accounts, comply with legal obligations, resolve disputes, and enforce our agreements.

The length of time for which we retain personal information depends on a variety of factors, including the nature of the information, the purposes for which it was collected, and applicable legal or regulatory requirements.

5.1 Retention of Account Information

We generally retain personal information associated with your account for as long as your account remains active.

If you choose to deactivate or delete your account, we will take reasonable steps to delete or anonymize personal information associated with your account within a reasonable period of time, subject to the exceptions described in this section.

Certain information may be retained where necessary to:

• comply with legal obligations
• resolve disputes
• enforce our Terms of Service or other agreements
• prevent fraud, abuse, or other harmful activity
• maintain records required for legitimate business or regulatory purposes.

5.2 Retention of User Content and Communications

Information you provide through the Service, including profile information, photographs, and communications, may be retained for a period of time consistent with the operation of the Service.

If you delete content or close your account, copies of such information may remain for a limited period of time in backup systems or archives maintained for system integrity, disaster recovery, or legal compliance purposes.

In certain circumstances, we may retain records associated with user interactions, reports, or policy enforcement actions where reasonably necessary to investigate misconduct, protect users, or enforce our policies.

5.3 Retention for Safety and Platform Integrity

To maintain the safety and integrity of the Service, we may retain certain information for longer periods where necessary to:

• investigate reports of misconduct or abuse
• enforce platform rules and policies
• prevent fraudulent or abusive accounts
• detect repeat violations of our Terms of Service.

This may include retaining records related to moderation actions, safety investigations, or enforcement decisions.

5.4 Retention for Legal and Regulatory Compliance

We may retain personal information where required to comply with applicable laws, regulations, legal processes, or governmental requests.

Such retention may include maintaining records necessary for:

• tax and accounting obligations
• legal reporting requirements
• responding to lawful requests from courts or regulatory authorities
• establishing, exercising, or defending legal claims.

5.5 De-Identified and Aggregated Information

In some circumstances, we may de-identify or aggregate personal information so that it can no longer reasonably be used to identify an individual.

De-identified or aggregated information may be retained and used for lawful business purposes, including analytics, research, service improvement, and product development.

5.6 Residual Copies

Please note that residual copies of personal information may remain in backup systems for a limited period of time in accordance with our backup and disaster recovery procedures.

Such retained information will continue to be protected in accordance with this Privacy Policy and applicable security safeguards.

6. Your Privacy Rights

Depending on your jurisdiction and applicable privacy laws, you may have certain rights regarding the personal information we collect and process about you.

These rights may vary depending on where you reside and the legal requirements that apply to your personal information.

6.1 Right to Access

You may have the right to request confirmation of whether we process personal information about you and to request access to that information.

Where required by applicable law, we will provide you with a copy of the personal information we maintain about you, subject to certain legal limitations and exceptions.

6.2 Right to Correct

You may have the right to request that we correct inaccurate or incomplete personal information that we maintain about you.

We will make reasonable efforts to verify and correct such information in accordance with applicable law.

In many cases, you may also update certain information directly through your account settings within the Service.

6.3 Right to Delete

You may have the right to request that we delete personal information we have collected about you.

Please note that we may retain certain information where necessary to:

• comply with legal obligations
• detect or prevent fraud, abuse, or security incidents
• enforce our agreements or policies
• resolve disputes
• protect the rights, property, or safety of the Company, our users, or the public.

If you request deletion of your personal information, certain features of the Service may no longer be available to you.

6.4 Right to Data Portability

Where provided by applicable law, you may have the right to request a copy of certain personal information in a structured, commonly used, and machine-readable format.

This right may apply to personal information you have provided directly to us and that we process using automated means.

6.5 Right to Opt-Out of the Sale or Sharing of Personal Information

Certain privacy laws, including those in California, provide residents with the right to opt out of the sale or sharing of personal information.

The Company does not sell personal information as defined under applicable privacy laws and does not share personal information for cross-context behavioral advertising purposes.

If applicable laws change or our practices change in the future, we will update this Privacy Policy accordingly.

6.6 Exercising Your Rights

To exercise any applicable privacy rights, you may submit a request by contacting us at:

sg@thirdhub.com

When you submit a request, we may take reasonable steps to verify your identity before processing the request. This verification process may require you to provide information sufficient to confirm that you are the individual associated with the request.

We will respond to verified requests within the timeframes required by applicable law.

6.7 Authorized Agents

In certain jurisdictions, including California, you may designate an authorized agent to submit privacy rights requests on your behalf.

If an authorized agent submits a request on your behalf, we may require:

• proof that the agent has been authorized to act on your behalf; and
• verification of your identity.

6.8 Non-Discrimination

We will not discriminate against you for exercising any privacy rights available to you under applicable law.

However, certain features of the Service may require the collection and processing of personal information. If you request deletion of certain information or restrict processing, some features of the Service may no longer function as intended.

7. Data Security

We implement reasonable administrative, technical, and organizational safeguards designed to protect personal information from unauthorized access, disclosure, alteration, or destruction.

These safeguards are intended to provide a level of security appropriate to the nature of the personal information we process and the risks associated with the processing of such information.

7.1 Security Measures

Our security practices may include measures such as:

• restricting access to personal information to authorized personnel with a legitimate business need
• implementing authentication and access control mechanisms
• encrypting data during transmission where appropriate
• maintaining monitoring systems designed to detect security incidents or unauthorized access
• conducting regular reviews and assessments of our security practices and systems.

We also take steps to require service providers that process personal information on our behalf to implement appropriate security safeguards.

7.2 Account Security

Users are responsible for maintaining the confidentiality of their account credentials and for taking reasonable precautions to protect access to their accounts.

We encourage users to:

• use strong and unique passwords
• avoid sharing account credentials with others
• log out of accounts when using shared devices
• notify us promptly if they believe their account has been compromised.

The Company is not responsible for unauthorized access to accounts resulting from a user’s failure to safeguard their login credentials.

7.3 Security Limitations

While we implement reasonable security measures designed to protect personal information, no method of transmission over the internet or method of electronic storage can be guaranteed to be completely secure.

Accordingly, we cannot guarantee the absolute security of personal information transmitted to or stored through the Service.

Users acknowledge that they provide personal information and use the Service at their own risk, and that the Company cannot ensure or warrant the security of information transmitted to or through the Service.

7.4 Security Incidents

If we become aware of a security incident that affects personal information, we will take reasonable steps to investigate the incident and mitigate potential harm.

Where required by applicable law, we will notify affected individuals and relevant regulatory authorities in accordance with applicable legal requirements.

8. International Data Transfers

The Company operates the Service through infrastructure, personnel, and service providers located in multiple jurisdictions.

As a result, personal information that we collect may be transferred to, stored in, and processed in countries other than the country in which you reside. These countries may include jurisdictions where the Company or its service providers maintain operations, such as Singapore, the United States, and other countries.

Data protection laws in these jurisdictions may differ from those in your country of residence and may not provide the same level of legal protection.

8.1 Cross-Border Processing

When you access or use the Service, your personal information may be transferred to and processed in jurisdictions outside of your country of residence.

Such transfers may occur in connection with activities such as:

• hosting and infrastructure services
• payment processing
• customer support operations
• analytics and product improvement
• safety and security monitoring.

By using the Service and providing personal information, you acknowledge that your information may be transferred to and processed in these jurisdictions.

8.2 Safeguards for International Transfers

Where required by applicable law, we implement safeguards designed to protect personal information transferred across borders.

Such safeguards may include:

• contractual protections with service providers and partners
• internal policies governing access to personal information
• technical and organizational security measures designed to protect personal information.

These safeguards are intended to ensure that personal information receives an appropriate level of protection when transferred internationally.

8.3 Processing by Service Providers

Service providers that process personal information on our behalf may operate in multiple jurisdictions.

These providers are contractually required to process personal information only for the purposes authorized by the Company and in accordance with applicable privacy and data protection laws.

8.4 User Acknowledgment

By accessing or using the Service, you acknowledge and agree that your personal information may be transferred to, stored in, and processed in countries outside your country of residence.

Such jurisdictions may have data protection laws that differ from those of your home jurisdiction.

9. Children’s Privacy

The Service is intended for use only by individuals who are at least eighteen (18) years of age.

We do not knowingly collect, solicit, or maintain personal information from individuals under the age of eighteen (18).

9.1 Age Restrictions

By accessing or using the Service, you represent and warrant that you are at least eighteen (18) years old and legally permitted to use the Service in accordance with our Terms of Service.

Individuals under the age of eighteen (18) are not permitted to create accounts or use the Service.

9.2 No Knowing Collection of Children’s Information

We do not knowingly collect personal information from children under the age of eighteen (18).

If we become aware that personal information has been collected from a person under the age of eighteen (18) without appropriate authorization, we will take reasonable steps to delete such information as soon as practicable.

9.3 Parental or Guardian Inquiries

If you are a parent or legal guardian and believe that a minor may have provided personal information to us through the Service, please contact us at:

sg@thirdhub.com

Upon receiving such notice, we will investigate the matter and take appropriate action, which may include deleting the information and terminating the associated account.

9.4 Compliance with Child Privacy Laws

Nothing in this Privacy Policy is intended to limit any rights provided under applicable child privacy protection laws, including the Children’s Online Privacy Protection Act (COPPA) in the United States where applicable.

However, because the Service is intended only for adults, we do not knowingly permit the use of the Service by children under the age of thirteen (13) or minors under the age of eighteen (18).

10. Changes to This Privacy Policy

We may update or modify this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, or other operational considerations.

When we make changes to this Privacy Policy, we will update the “Last Updated” date at the top of this document.

If we make material changes to how we collect, use, or disclose personal information, we may provide additional notice where appropriate, including by:

• posting a prominent notice within the Service
• sending an email notification to users
• providing other reasonable forms of notice as required by applicable law.

Your continued access to or use of the Service after the updated Privacy Policy becomes effective constitutes your acknowledgment of the updated policy.

We encourage users to review this Privacy Policy periodically to remain informed about how we collect, use, and protect personal information.

11. Contact Us

If you have any questions about this Privacy Policy or our privacy practices, or if you wish to exercise any rights available to you under applicable privacy laws, you may contact us using the information below.

THIRD HUB GLOBAL PTE. LTD.
9 Raffles Place, #06-00
Republic Plaza
Singapore 048619
Singapore
Email: sg@thirdhub.com

We will review and respond to privacy-related inquiries in accordance with applicable laws and regulations.

If you submit a request to exercise your privacy rights, we may take reasonable steps to verify your identity before fulfilling your request.