Effective as of 1 February 2024

Thank you for using our mobile application Buz and/or visiting our website at https://www.buzmenow.com (collectively, the “Services”).

For the purposes of data protection and privacy laws, Tiya Pte Ltd and Buz Technology Pte Ltd (each a member of the group of companies trading as Vocalbeats) ("we or "us") are joint controllers in the processing of your personal information. We are committed to protecting and respecting your personal information.

This Privacy Notice describes:

• The ways we collect personal information about you and why we do so;
• How we or Vocalbeats or our authorised partners use your personal information;
• The choices you have about your personal information; and
• How we protect your personal information.

We may periodically update this Privacy Notice by posting the updated version on https://www.buzmenow.com/privacy-policy Where required, we endeavour to notify you of material changes to this Privacy Notice by posting a notice on Buz. Your continued use of our Services following the posting of changes to the Privacy Notice or any notification to you shall mean you accept those changes.

1. Contact Us

The designated joint controller representative is Buz Technology Pte Ltd which is entitled to act on behalf of Tiya Pte Ltd and is responsible for processing and responding to data requests made by you or any government authority.

If you have questions about how we collect, use, process or protect your personal information, or if you have any requests in respect of your personal information, we encourage you to contact us through the support features within the Buz app so we can respond more quickly. Alternatively, you may contact:

Name of the joint controller representative: Buz Technology Pte Ltd
Address : 6 Shenton Way, #37-03, OUE Downtown, Singapore 068809
Attn : Data Protection Officer
Email : [email protected]

We will respond to your requests in accordance with applicable laws and may take additional steps to verify your identity before fulfilling your request. These steps may include verifying details about personal identification information or account details. You may also designate an authorized agent to act on your behalf.

We endeavour to respond to all requests in a timely manner. For complex requests, we may charge a fee for processing your request. If you have any unresolved concerns about your privacy rights or personal data protection that we could not address adequately, you may contact your local privacy and personal data protection authority for further assistance.

2. Collection of Personal Information

Please see below for various categories of personal information we collect from you.

(I) Information you provide when you create or update your account

(II) Information We Get When You Use Our Services

When you use our Services, we may passively collect information about you and how you use our Services. We only use pseudonymized or anonymised data that have gone through a privacy-enhancement process to protect and improve the functionalities of the Services.

(III) Information We Collect from Third Parties

3. How Do We Use Your Information

We use information about you for the following purposes in accordance with applicable laws:

The table below sets out:

• our purpose for processing your personal data
• our legal justifications (each called a 'legal basis') under data protection laws for each purpose
• categories of personal data which we use for each purpose.

4. Who Else Can Use Your Information

Apart from us, we may share your information with other entities in the following situations:

A) Our Related Entities: We might share your personal information within Vocalbeats to assist us in technical processing operations (such as data hosting, analytics or maintenance), finance, legal, HR or accounting assistance, enhancing security against spam, abuse, fraud, infringement or other wrongdoings, and improve the Services; for corporate audit, analysis, strategic planning, research and development, corporate transactions (for example merger and acquisition, sale of company assets, financing etc); or compliance with applicable law. Each entity within the group may only use your personal information in accordance with this Privacy Notice.

B) Our Authorised Partners: We work with third party vendors to provide the Buz app. These authorised partners process your information only at and according to our instructions. They perform tasks such as hosting, user support, analytics and fraud detection and prevention. For more information, please read the privacy policies of our authorised third party vendors.

C) Government Agencies: In order to combat fraud and illegal activity, we may process and disclose information to other organizations or provide information to government agencies in response to any lawful request. If required by any government authority or courts for any legal purposes such as the enforcement of any laws or to prevent the breaching of any laws, we shall release your personal information to the extent as is legally required.

D) Other Users. When you share personal information (for example, by sending messages, creating profile information or uploading any other content onto Buz), such personal information may be viewed by some or all Buz users on Buz. Please refer to our Terms of Use on the best practices to use Buz in a safe and responsible manner. Remember that your personal information may be circulated outside the Buz app because of the actions of errant Buz users.

5. Cross Border Data Transfers

In order to provide you with the full range of Services efficiently, we are working with authorised third party partners as well as related member entities within Vocalbeats around the world. Accordingly, your personal information may be accessed by our authorised personnel around the world and/or your personal information may be lawfully transferred at our instructions for limited access, use or processing by our authorised personnel around the world. Because the data protection and privacy laws in other countries may be different from those of your home country, we will take steps to ensure that adequate safeguards are in place to protect your personal information as explained in this Privacy Notice. Adequate safeguards that we may use include relying on approved standard contractual clauses and implementing other lawful safeguards.

6. Your Rights and Choices

A) Contacts, Camera, Photos, Microphone

We will ask for your permission to access your contacts, camera, photos and microphone so that you can send messages (audio, text, pictures) to your contacts. You may opt-out at any time by changing the settings on your mobile device.

B) Access the personal information we hold about you

Upon your written request and successful verification of your identity, we will provide you with a copy of your personal information in an electronic format.

C) Personal information rights

You may, at any time, withdraw your consent for us to collect, use, disclose or transfer your personal information to third parties. You also have the right to rectify or delete your personal information. Upon receipt of your written request, we require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences regarding the same. In general, we shall seek to process your request within thirty (30) calendar days of receiving it. Depending on the nature and scope of your request, you may not be able to access some or all features on Buz, and we may have to terminate the End-User License Agreement we have with you. We will notify you before completing the processing of your request. Should you decide to cancel your request, please inform us immediately.

Please note that:

1. You may withdraw your consent to using or disclosing your personal information at any time by adjusting the relevant settings on the App or by contacting us, but withdrawing does not affect the lawfulness of the processing before the withdrawal nor our rights to collect such information where (i) such use or disclosure is required by law, (ii) the personal data in question was collected from publicly available sources or (iii) such use or disclosure is necessary in an emergency where the life or health of a person is at risk.
2. Even if you ask us to delete all or some of your personal information, we may still retain some of your data to the extent necessary to serve our legitimate business interests, such as to comply with our legal obligations, resolve disputes, and enforce our agreements.
3. We may send you push notifications regarding your account or certain features of Buz through the app. If you wish to opt out from receiving these types of communications, you may change your settings.

You have the right to obtain a transferable version of your personal information or ask for it to be transferred to another provider (where technically feasible).

To exercise your personal information rights, please contact us according to Section 1 "Contact Us" above. You will not be subject to discriminatory treatment for exercising your rights.

D) Reviewing or amending your account information, or deleting your account

You may review or amend your account information, or delete your Buz account at any time by logging to your account settings on Buz app.

If you decide to delete your Buz account, we will deactivate your account and your information from our active databases. You may lose your personal information or other related information associated with the account. You will be informed and required to acknowledge the consequences of deleting your account. However, we may retain some information to the extent necessary to serve our legitimate business interests such as to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms of Use and/or comply with applicable legal requirements.

7. How Do We Protect Your Personal Information

DO NOT SELL. We do not sell your personal information. We also do not transfer, disclose or share your personal information with third parties, except where the information is necessarily transferred, disclosed and shared with our authorised third-party partners who must use and process your information solely to provide you with the Services on our behalf.

A) Security

In order to help ensure a secure environment for the Services and safe experience for our users, we are continuously developing and implementing administrative, technical and physical security measures to protect your personal information from unauthorized use or access and against loss, misuse or alteration.

While we try our best, we cannot warrant the security of any information transmitted to us through or in connection with the Services, that we store on our or our authorised partners' systems.

Any improper collection or misuse of personal information is a violation of this Privacy Notice and our Terms of Use and should be reported to [email protected]

B) Pseudonymisation, anonymisation and aggregation techniques

These privacy-enhancing techniques involve modifying or removing certain identifying information from your personal data and information to make it more difficult to link the data or information to you. We only use information that has gone through this privacy-enhancement process if we are using them to improve functionalities of the Services.

C) Personal information retention

Generally, we will store your personal information only for the time period necessary:

1. to fulfil the purposes for which such personal information was collected;
2. for as long as your account is active or as needed to provide you the Services (You may delete your account any time and if your account is inactive for two years, we may delete it for you); or
3. as required or permitted by applicable laws (such as tax, accounting, or other legal requirements).

Once we determine that the retention of your personal information is no longer necessary for the intended purposes, or that retention is no longer necessary for any legal or business purpose, we will cease to retain your personal information, or anonymise the personal information so that it can no longer be used to identify any particular individual.

Logs are pseudonymized and retained for a year, after which we may delete or anonymize it.

8. Protecting Children

We take our responsibilities to the Buz community very seriously. We also believe in protecting children's privacy online. Buz app is not meant for use by persons under the age of 13 years old. If you are under the age of 13, please do not use our Buz app in any manner. If you are a minor, you may only access and use Buz app with the consent and under supervision of your parent or legal guardian.

We do not knowingly collect personal information and data from anyone under the age of 13 and we do not direct any the Buz app at this age group. Any person who provides their personal information to us through our Services explicitly represents that they are 13 years of age or older. If we become aware that someone under 13 years of age provided us with their personal information, we will close the account of that person and promptly delete their information, save when we are under a legal obligation to keep certain information.

If you are a parent or legal guardian of a minor, and wish to review any personal data that may have been collected by us from your child or ward for security reasons, or request that their Buz account or personal information be modified or deleted for security or accuracy reasons, you may contact us at [email protected] We will respond to your requests after verifying the identities of the relevant users and their parents or legal guardians, and obtaining consent (if required under the laws) from the relevant users.

You are responsible for any and all account activity conducted by a minor on your Buz account.

9. Notice to US Residents

If you are a US resident and a consumer defined under the applicable consumer laws of the state you reside in, you have a right to request:

• the categories of personal information that is processed;
• the categories of sources from which personal information is obtained;
• the purpose for collecting or processing your personal information;
• the categories of third parties with whom we may share your personal information;
• the specific pieces of personal information we have collected about you provided that the data given in the request is reliable enough and allows us to identify the user;
• a list of the categories of personal information disclosed for a business purpose in the prior twelve (12) months, or that no disclosure occurred;
• a list of the categories of personal information sold about you in the prior twelve (12) months, or that no sale occurred. We do not sell your personal information. If we do sell, we will explain:
• the categories of your personal information we have sold.
• the categories of third parties to which we sold the information, by categories of personal information sold for each third party.

We do not and have not sold your personal information. However, in the last 12 months, we have disclosed the following categories of information in order to provide our Services:

Please note that personal information does not include de-identified or aggregated consumer information. You can refer to "How Do We Use Your Information" in Section 3 above.

You have the right to request a transportable copy, no more than twice in a 12-month period, of your personal information that we have collected in a 12-month period prior to the request date.

Except to the extent we have a basis for retention under the law, you may request that we delete your personal information that we have collected directly from you and are maintaining. We are not required to delete your personal information that we did not collect directly from you.

Any request you submit to us is subject to an identification and residency verification process. We will not respond to your request or provide you with personal information if we cannot verify your identity. Please include in the title of your request "Verifiable consumer request”. When submitting a verifiable consumer request, you should:

• provide adequate information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative. If you are making a request through an authorized agent acting on your behalf, such authorized agent must provide written authorization confirming or a power of attorney, signed by you; and
• describe your request with sufficient detail that allows us to understand, evaluate, and respond to it.
• The personal information provided in a verifiable consumer request will be used for the sole purpose of verifying the requestor’s identity or authority to make the request. We will retain such information for the adequate period reasonably needed for the purpose described above and delete them after the purpose is fulfilled.

We will not discriminate against you because you exercise your consumer rights. Save that, depending on the nature and scope of your request, you may not be able to access some or all features on Buz, and we may have to terminate the End-User License Agreement we have with you. We will notify you before completing the processing of your request. Should you decide to cancel your request, please inform us immediately. We will make commercially reasonable efforts to respond to your requests within 45 days or 90 days if required. We may charge a reasonable fee, or refuse to act upon a request if your request is excessive, repetitive, unfounded, or overly burdensome. If we cannot comply with a request, we will explain the reasons in our response.

California's "Shine the Light" law, Civil Code section 1798.83, does not apply to us because we do not disclose personal information to third parties for the third parties' direct marketing purposes.

10. Notice to EU or UK Residents

Pursuant to the General Data Protection Regulation (GDPR) and the UK Data Protection Act, we now explain the valid legal bases we rely on in order to process your personal information.

1. Consent. We may process your information if you have given us permission to use your personal information for a specific purpose. You can withdraw your consent at any time.
2. Performance of a contract. It is necessary for us to process your information in order to allow you to register a Buz account and grant you a license to access, use or navigate our Services (or continue to do so at your choice).
3. Compliance with Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.
4. Legitimate Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.

11. Notice to Canadian Residents

We may process your information if you have given us specific permission to use your personal information for a specific purpose, or in situations where your permission can be inferred. You can withdraw your consent at any time.

In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:

1. If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way.
2. For investigations and fraud detection and prevention.
3. For business transactions provided certain conditions are met.
4. If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim.
5. For identifying injured, ill, or deceased persons and communicating with next of kin.
6. If we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse.
7. If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province.
8. If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records.
9. If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced.
10. If the collection is solely for journalistic, artistic, or literary purposes.
11. If the information is publicly available and is specified by the regulations.