Privacy Policy

1. Introduction

Toda Labs Pte. Ltd. ("Toda Labs", "we", "us", or "our") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our services, in compliance with the Personal Data Protection Act 2012 (PDPA) of Singapore.

By using our services, you consent to the data practices described in this policy.

2. Information We Collect

2.1 Personal Data

We may collect the following types of personal data:

• Contact information (name, email address, phone number)
• Account credentials (username, password)
• Profile information (preferences, interests)
• Communication data (messages, chat history)
• Technical data (IP address, browser type, device information)
• Usage data (interaction patterns, feature usage)

2.2 Automatically Collected Information

When you access our services, we automatically collect:

• Log data (access times, pages viewed, IP address)
• Device information (device type, operating system)
• Cookies and similar tracking technologies

3. How We Use Your Information

We use your personal data for the following purposes:

• To provide, maintain, and improve our services
• To process your requests and transactions
• To communicate with you about our services
• To personalize your experience
• To develop and train our AI models
• To detect, prevent, and address technical issues and fraud
• To comply with legal obligations
• To send marketing communications (with your consent)

4. Legal Basis for Processing (PDPA Compliance)

Under Singapore's PDPA, we process your personal data based on:

• Consent: You have given clear consent for us to process your personal data for specific purposes
• Contract: Processing is necessary for the performance of a contract with you
• Legal Obligation: Processing is necessary to comply with Singapore law
• Legitimate Interests: Processing is necessary for our legitimate interests, provided these do not override your rights

5. Data Sharing and Disclosure

We may share your personal data with:

• Service Providers: Third-party vendors who perform services on our behalf
• Business Partners: Partners who help us provide our services
• Legal Requirements: When required by law or to protect our rights
• Business Transfers: In connection with a merger, acquisition, or sale of assets

We do not sell your personal data to third parties.

6. International Data Transfers

Your personal data may be transferred to and processed in countries outside of Singapore. We ensure that such transfers comply with the PDPA by:

• Ensuring the recipient country has data protection standards comparable to Singapore
• Implementing appropriate contractual safeguards
• Obtaining your consent where required

7. Data Security

We implement appropriate technical and organizational measures to protect your personal data, including:

• Encryption of data in transit and at rest
• Regular security assessments and audits
• Access controls and authentication mechanisms
• Employee training on data protection

8. Data Retention

We retain your personal data only for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law. When we no longer need your personal data, we will securely delete or anonymize it.

9. Your Rights Under PDPA

Under Singapore's PDPA, you have the following rights:

• Right to Access: Request access to your personal data we hold
• Right to Correction: Request correction of inaccurate or incomplete personal data
• Right to Withdraw Consent: Withdraw your consent for processing at any time
• Right to Data Portability: Request a copy of your personal data in a structured format

To exercise these rights, please contact us at privacy@toadalabs.io

10. Children's Privacy

Our services are not intended for individuals under the age of 18. We do not knowingly collect personal data from children. If you believe we have collected information from a child, please contact us immediately.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of any material changes by posting the new Privacy Policy on this page and updating the "Last Updated" date. Your continued use of our services after such changes constitutes acceptance of the updated policy.

12. Contact Us

If you have any questions about this Privacy Policy or our data practices, please contact us:

13. Data Protection Officer

For matters relating to personal data protection, you may contact our Data Protection Officer at:

Email: dpo@toadalabs.io

14. Complaints

If you have concerns about how we handle your personal data, you may lodge a complaint with the Personal Data Protection Commission (PDPC) of Singapore: