Privacy Policy

Tvasan Technologies Pte Ltd (the “Company”) takes the security of your personal data very seriously and are committed to protecting, upholding and respecting the privacy of the users (“You” or “Your”) of Communa App(the “Platform”).

Your privacy is of paramount importance to the Company, as the Company recognizes the sensitive and personal nature of the information shared by You during Your usage of the Platform. The Company understands that trust is fundamental to the Company’s relationship with You, and the Company is committed to maintaining the confidentiality, integrity, privacy and security of Your personal information.

The Company adheres to strict privacy standards and employs robust measures to safeguard Your data against unauthorized access, misuse, or disclosure. The Company recognizes that You entrust the Company with Your personal information, and the Company takes this responsibility seriously by implementing industry-standard security protocols and regularly updating the Company’s systems to mitigate potential risks. The core principles of these protocols and measures are stipulated below, and shall be applicable in equal measure to all users of the Platform, including You.

Introduction

• You shall be bound by this Privacy Policy and all its subsequently modified versions.
• “Personal Information” is any and all information through or using which You can directly or indirectly be identified, including but not limited to Your name, e-mail address, residential address, information made available on social media, telephone number, password, and any other information which You provide while accessing services and products offered by the Company and which allows You to be directly or indirectly be identified and also includes limited personal data connected with use of the Platform e.g. IP address, browser type, operating system, geo-location, referring domains and exit links.
• By using or accessing the Platform, You irrevocably and unconditionally agree to the terms and conditions of this Privacy Policy. You also expressly consent to the Platform’s use and disclosure of Your Personal Information in any manner as described in this Privacy Policy. Your subscription to and usage of the Platform constitutes your express and perpetual consent to the Company’s usage of Your Personal Information for the purposes stated herein. At any time, You have the right to not provide the Company with certain information, or withdraw Your consent with respect to the collection, processing or disclosure of the Personal Information provided by You. Please note however, that in such cases, the Company reserves the right to limit its services offered to You, or refuse the provision of such services in their entirety, including deeming you ineligible for any further usage of this Platform.

Collection of Personal Information

• The Company receives Your Personal Information in the following cases:
  • Registering an Account: The Company stores the information that You provide to it when You create an account on the Platform, including Your email address, name, and additional information which You voluntarily provide to the Company during the process of registering Your account on the Platform.
  • Transactions: The Company collects certain information while providing services to You in order to verify Your identity and the type of information and extent of information collected by it will depend on the nature of services being availed by You. The Company reserves the right to use any and all such information (including any Personal Information) to verify your identity and to complete any authentication processes that may be required to be undertaken by the Company.
  • Reviews: The Company collects information pertaining to Your name, email address and any other media, as provided by You during the process of providing user reviews on the Platform.
  • Use of Platform: The Company collects and stores details pertaining to each instance of Your usage of the Platform (such as pages visited and the installation and uninstallation of the application) and Your interactions through any e-mails or online chat logs exchanged between the Company and You. For more information, please see The Company’s policy on cookies below.
• Cookies
  • The Company uses cookies and other technology like pixel tags for purposes described below. Cookies are small files which are sent from the Platform and then stored on to Your device/s. Pixel tags, also called web beacons are clear image (i.e. non-visible) files that may be placed on the Platform which request information from Your device (collectively, “Cookies”).
  • The Company sometimes collects anonymous information from visits to the Platform and uses this data to analyse trends and statistics and to help provide better customer service. This anonymous information is sometimes known as “clickstream data”.
  • Cookies may be set in Your devices when You access the Platform or may be set when You visit third-party websites or platforms.
  • You are free to suitably modify the Platform settings if You do not wish to accept cookies, but please note that changing such settings in the Platform may affect Your experience with the Platform, and also Our ability to effectively provide services to You.
• The Company uses Cookies for different purposes, which can be categorised as follows:
  • Required Cookies: These Cookies enable You to navigate the Platform and use its features, such as accessing secure areas of the Platform while using Our services. Each time You log into the Platform, a Cookie containing an encrypted, unique identifier tied to Your account is placed on Your browser. These Cookies allow the Company to uniquely identify You when You are using the Platform and to process the online transactions and requests.
  • Functional Cookies: These Cookies are required for the Platform to function. They include, for example, Cookies that enable You to log in. They may also enable the Company to recognise You when You return to the Platform and store information about Your preferences, so they allow the Company to customise the Platform according to Your individual preferences (such as the language chosen by You, changes made to text size and fonts, etc.). The Company uses local shared objects, also known as “Flash,” cookies, to store Your preferences or display content based upon what You view on the Platform to personalize Your visit to the Platform.
  • Performance Cookies: These Cookies collect information about how You use the Platform, including which pages You visit most often and if You receive error messages from certain pages. These Cookies do not collect information that individually identifies You. All information these Cookies collect is aggregated and anonymous. It is only used to improve how the Platform functions and performs. From time to time, the Company engages third-parties to track and analyze usage and volume statistical information from individuals who visit the Platform. The Company may also utilize “Flash” cookies for these purposes.
  • Analytical Cookies: These Cookies analyse how You navigate around the Platform (pages visited, links used etc.) or use e-mails or chat logs that the Company sends to You or that You send to Us. They enable the Company to better understand Your interests and to improve the Platform and the user experience for Your benefit.
  • Third-party advertising: The Company may uses third-party service providers to display advertisements (banners or links) on behalf of the Company across the internet. These advertising service providers may collect information about visits to the Platform and interactions with the Services, as well as Your visits to other websites. Such information does not include any Personal Information including Your names, addresses, e-mail addresses or any information pertaining to discussions or interactions undertaken on the Platform by the Users but may contain other Platform related information.

Purpose and Usage of Personal Information

• All Personal Information collected by the Company is specific and utilised based on the specific services which You wish to participate in or access, and is utilised for the purpose of providing such services as requested by You. Additionally, the Personal Information collected is utilised for the following purposes:
  • Transactions: Personal Information is used to administer accounts, process Service requests, generate tickets/transaction records, etc.
  • Internal Record Keeping: Personal Information is used to allow You to use the services on the Platform, to inform the You of the usage of the Platform, to communicate changes to the Terms of Services/Privacy Policy, and for any other purposes with Your consent.
  • Analytics: The Company uses and collects Personal Information to help learn more about Your preferences (to enable the personalisation of the Platform or to provide You with any offers or promotions, based upon Your interests and preferences), to help address problems with and improve the Platform, to analyse trends and statistics, and to present content with the most clarity and usability.
• Legal Proceedings: In the event the Company is required to respond to any legal, regulatory, judicial or administrative proceedings, including any legal notices or court orders, governmental directives, or the Company is otherwise required to adhere to specific applicable laws, Your Personal Information may be disclosed pursuant to such legal regulatory, judicial or administrative proceedings or in accordance with the requirements under applicable law.

Disclosure and Sharing of Information

• The Company treats Your Personal Information as strictly confidential.
• The Company may involve other companies in providing services to You with whom the Company may share Your Personal Information such as third-party service providers for data analytics, payments or other similar purposes. Where the Company engages such service providers that use Personal Information, the Company will ensure that such Personal Information is processed for such specific purposes only.
• Additionally, the Company reserves the right to share, disclose and transfer Your Personal Information collected hereunder with its affiliates or the owner of the domain under any specific contractual terms that exist vis a vis such owner.
• The Company considers consumer information as a critical business asset. In the event the Company sells or transfers all or a portion of its business assets or capital stock (whether through a private arrangement or in accordance with judicial or administrative directives), consumer information may be one of the business assets that are consequently shared, disclosed or transferred as part of any such transaction.
• The Company may also share Personal Information where necessary to comply with any legal obligation, or in order to enforce any other agreements under which the Company is contractually bound.
• Prior to the use or disclosure of Personal Information for any reasons other than as stated above, the Company will ensure that You are intimated of the same in a timely manner.
• The Company will take reasonable steps to ensure that all usage of and dealings in Your Personal Information, shall be:
  • processed lawfully, fairly and in a transparent manner;
  • undertaken only Your consent;
  • available for review by You, as and when reasonably requested by You;
  • kept secure against unauthorized or unlawful processing and against accidental loss, destruction or damage, as per legally prescribed standards; and
  • collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes.

Third-Party Links

• Accessing any third party link which are made available on the Platform by Users, may direct You to third-party websites that are not affiliated with the Company. Such websites or applications are governed by their respective privacy policies and terms of use, which are beyond the Company’s control. Once You leave the Platform, usage of any information provided by You is governed by the privacy policy of the operator of the website or applications which You are visiting or using. The Platform expressly disclaims any responsibility for the privacy practices or the content of such third-party websites and applications.

Security Procedures

• The Company strives to ensure the security, integrity and privacy of Your Personal Information and to protect Personal Information against unauthorised access, use, disclosure, alteration or destruction. The Company’s databases are stored on servers secured behind a firewall with access to such servers being password-protected and strictly limited based on a need-to-know basis. The Company will at all times make reasonable endeavors to upgrade its security protocols such that they are in consonance with prevailing and extant legal and regulatory requirements in Singapore
• Despite the Company’s best efforts to maintain a robust privacy and security system, You agree, acknowledge and understand that no security system is impenetrable and can absolutely guarantee unconditional privacy and security of Your Personal Information. Therefore, the Company’s extensive measures to maintain the integrity of its security protocols and systems does not guarantee the security of its database which includes the Personal Information that has been provided by You. In light of the above, the Company expressly disclaims all responsibility for any unintended or accidental breach of our security protocols, or any action of any third-parties that are consequently receiving Your Personal Information.

Retention of Data

• The Company shall retains and continue to utilise Personal Information for as long as necessary until: (i) the relevant purposes for the use of such Personal Information pursuant to EULA or any other contractual arrangements are completed; or (ii) as mandated under applicable laws and regulations including the Personal Data Protection Act, 2012 or (iii) for legitimate business purposes. Upon the completion of the purposes as stated herein, the Personal Information collected shall be disposed of in a proper and secure manner in accordance with applicable laws and regulations.
• Upon Your request, the Company shall provide You the details pertaining to the usage and disclosure of Your Personal Information within one (1) year from the date of Your request.

Access to and Updating Personal Information

• You may contact the Data Protection Officer at surendar@communa.app in order to view, update and change the Personal Information provided by You within the Platform. You may also ask to erase, restrict or port Your Personal Information and intimate objections, if any, to use Your Personal Information by the Company. In such instances, You understand that your usage of the Platform is likely to be restricted in varying measures, and may even need to be discontinued, at our discretion. Additionally, You may access all information the Platform holds about You, and request a correction where data is incorrect or a deletion of the data, unless the Company has to retain the data for legal reasons and legitimate business purposes.
• You are solely responsible for the accuracy of the Personal Information provided, and for any changes, updates or modifications to such information. The Company does not and will not authenticate the veracity or accuracy of any Personal Information whatsoever, and hence, do not and will not carry any liability to any third party about the authenticity, veracity and accuracy of the information that you choose to provide to the Company or otherwise decide to provide on the Platform during the course of Your usage of the Platform.

Changes to the Privacy Policy

• This Privacy Policy was posted on 18 June, 2024. The Company will endeavor to undertake periodic evaluations of the legal and regulatory landscape which is applicable to the Platform, this Privacy Policy and the Terms of Service thereof. Consequently, the Company unconditionally reserves the right to periodically and at any time, review and change the Privacy Policy (or any part thereof) to incorporate such future changes as may be considered appropriate, including as an outcome of any changes to applicable laws or regulations. The updated Privacy Policy will be posted on this page and where appropriate, notified to You by e-mail. The Company strongly advises You to periodically review this Privacy Policy to update Yourself about any such changes and alterations, irrespective of which You shall be automatically bound by such updated Privacy Policy as soon as such updates are made effective by the Company. Your continued usage of the Platform after such changes constitutes Your unconditional consent to such changes.

Contact Us

Any questions, clarifications, concerns or grievances with respect to this Privacy Policy or the Company’s practices concerning Personal Information may be addressed to the Data Protection Officer at:

surendar@communa.app