TrueWatch Mobile SDK Privacy Notice

When you use the TrueWatch website, platforms, and services (including https://www.truewatch.com) in connection with the TrueWatch service (the "Services"), you agree to the terms outlined in our privacy notice. By using our Services, you expressly consent to the collection, processing, use, and storage of your personal information, device, network, and application information as described in this privacy notice.

Scope of Application

This notice applies to all TrueWatch SDK products and services.

What Personal Information Is Collected, How It Is Collected, and Its Purposes

Device Information

TrueWatch collects the following device-related information:

• Device Attributes: Hardware model, operating system version, device configuration, and unique device identifiers (e.g., Android ID).
• Identifiers: International Mobile Equipment Identity (IMEI), International Mobile Subscriber Identity (IMSI), network hardware address (MAC), and advertising identifiers (e.g., IDFA).
• Device Connection Information: Carrier information and language settings.

Purpose:

• Provide consistent services across your devices,
• Enhance the functionality and user experience of TrueWatch platform, and
• Support troubleshooting and technical assistance.

Network Information

TrueWatch collects the following network-related information:

• IP address,
• Wi-Fi connection details, and
• Base station information.

Purpose:

• Identify users uniquely,
• Accurately depict user profiles for service customization, and
• Optimize connectivity for seamless service delivery.

Application Information

TrueWatch collects the following application-related crash data and application logs.

Purpose:

• Improve the user experience,
• Optimize application performance, and
• Identify issues such as application stuttering, or errors.

Application Permissions Usage Description

Cookies and Similar Technologies

1. After logging in, this application will cache the user's login identity token to enable a smooth login experience during subsequent sessions, with a validity period of 7 days, starting from when the user logs out of the application.

2. Embedded web pages within this application utilize cookies to support essential functionalities, enhance user experience, and improve application performance. Cookies are used in accordance with the rules outlined in this notice.

3. By using this platform, you consent to the use of cookies as described in this notice. You may manage or disable cookies at any time through your browser settings or the application’s cookie management feature. However, disabling cookies may affect the functionality of certain features within the application.

Data Protection Measures:

TrueWatch implements industry-standard encryption, access controls, and other security measures to protect collected information against unauthorized access, misuse, or disclosure.

Information Usage

1. TrueWatch shall not provide, sell, rent, share, or trade your personal information to any unrelated third party unless we have obtained your prior consent, or except in cases where the third party and TrueWatch (including TrueWatch affiliates) are individually or jointly providing services to you, and upon the conclusion of the Services, the third party is prohibited from accessing the personal information previously made available to them;

2. TrueWatch prohibits any third party from collecting, editing, selling, or freely distributing your personal information through any means. If any TrueWatch user engages in such activities, once discovered, TrueWatch reserves the right to terminate the service agreement with that user immediately;

3. For customers using the TrueWatch ICSP service, TrueWatch will maintain the confidentiality of any relevant information, plans, or architectures obtained during cooperation. This information will not be shared with any third party without your explicit consent.

Information Disclosure

TrueWatch may disclose your personal information, in whole or in part, under the following circumstances:

1. Disclosure to third parties will occur only with your prior consent;

2. If you are a qualified intellectual property complainant and have filed a complaint, TrueWatch may disclose your information to the respondent upon request to facilitate the resolution of potential rights disputes;

3. TrueWatch will disclose your personal information to third parties, administrative bodies, or judicial institutions in accordance with applicable laws or upon lawful requests by such institutions;

4. If you violate relevant Singapore laws, regulations, or the TrueWatch Service Agreement or related rules, TrueWatch may disclose your personal information to third parties as necessary;

5. When required to provide the products or services you request, TrueWatch may share your personal information with third parties essential for service delivery;

6. In transactions facilitated on the TrueWatch platform, if one party has fulfilled or partially fulfilled their obligations and requests information disclosure, TrueWatch may provide necessary information, such as contact details of the transaction counterpart, to facilitate transaction completion or dispute resolution;

7. TrueWatch may disclose your personal information in other circumstances deemed appropriate according to laws, regulations, or applicable website and/or platform policies.

User Notification

Where feasible, TrueWatch will notify users of any disclosures of personal information unless prohibited by law or regulation.

Information Storage and Exchange

The information and data collected about you by TrueWatch will be stored on the servers of TrueWatch and/or its affiliated companies. This information and data may be transmitted to, accessed, stored and displayed in countries or regions outside of your country of residence or the location where the information was initially collected. TrueWatch ensures that cross-border transfers of personal data are conducted in compliance with applicable data protection laws.

Information Security

1. Please keep your account and password information secure. TrueWatch employs security measures such as server backups and user password encryption to ensure your information is not lost, misused or altered. While TrueWatch makes every effort to safeguard your data, please note that no security measures are entirely impenetrable in information networks;

2. When using the TrueWatch Services for online transactions, you may need to share personal information, such as contact details or postal addresses with counterparties or potential counterparties. Please protect your privacy by only share personal information when absolutely necessary and monitor for unauthorized access or use of your personal data. If you discover that your personal information, particularly your TrueWatch account and password, has been compromised, contact TrueWatch customer service immediately so that appropriate measures can be taken;

3. Currently, users cannot delete their accounts independently. To delete your account, please contact TrueWatch customer service. We will process the account deletion within 10 business days from the date of receipt. User information will be retained until the account deletion is completed. After deletion, TrueWatch will cease using your personal information for commercial purposes.

Special Attention to Minors

TrueWatch services are intended for use only by individuals with full civil rights capacity and full civil conduct capacity. If you are a minor or otherwise lack full capacity, you are not authorized to use TrueWatch services, and TrueWatch requests that you do not provide any personal information.

If TrueWatch inadvertently collects personal information from minors, we will delete such data promptly upon discovery. If you believe we may have collected information from a minor, please contact TrueWatch customer service immediately.

Updates to the Privacy Notice

1. TrueWatch reserves the right to revise this privacy notice as necessary to reflect changes in laws, regulations, or business practices;

2. Without your explicit consent, TrueWatch will not limit any rights granted to you under this privacy notice. All revisions will be published on a dedicated page for transparency;

3. For significant changes that materially impact the processing of your personal data, you may opt out of the affected services by contacting TrueWatch customer service.

4. For significant changes to the privacy notice, TrueWatch will provide prominent notifications in advance. Notifications may include website announcements, emails, or direct communications detailing the specific changes;

5. Significant changes referred to in this notice include but are not limited to:

• Significant changes in our service model. Modifications in the purpose of processing user information, types of user information processed, or methods of processing;
• Significant changes in control, organizational structure, or ownership, such as those resulting from business judgments, mergers, acquisitions, or bankruptcy;
• Alterations to the main entities with whom user information is shared, transferred, or publicly disclosed;
• Significant changes affect your rights to participate in the processing of your information and how you can exercise those rights;
• Changes in the department responsible for handling user information security, contact methods and complaint channels;
• When the user information security impact assessment report indicates a high risk.

Retention Policy

All collected information is retained only as long as necessary to fulfil the purposes outlined above, unless otherwise required by law.

How to Contact Us

If you have any questions or comments about this Privacy Notice, or if you wish to inquire about TrueWatch's practices and operations concerning this notice, please feel free to contact us via our customer service hotline at (+65) 6924-1094.

Alternatively, you may reach us through the following methods:

• Email: [email protected]

• Address: 18 Kaki Bukit Road 3, #04-11, Entrepreneur Business Centre, Singapore 415978

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