Privacy Policy

Effective Date: 1 Jan 2025

Last Updated: 30 May 2025

1. Introduction and Scope

This Privacy Policy ("Policy") describes how OSINITY PTE. LTD. (UEN: 202510646H), a private company limited by shares registered in Singapore, with its registered office at 74 Flora Road, #4-30, The Gale, Singapore ("Osinity," "we," "us," or "our"), collects, uses, discloses, and protects Personal Data (as defined by Singapore's Personal Data Protection Act 2012 ("PDPA")) and other information. This Policy applies to information collected through our website, https://www.osinity.com (the "Site"), and in connection with all our services, including but not limited to our AI-powered automation services, free analysis tools (such as the "Google Ads Search Term Analyzer"), and any integrations with third-party platforms like the Facebook Platform (collectively, the "Services").

By accessing our Site or using any of our Services, you signify your acknowledgment and acceptance of the terms of this Policy and consent to the collection, use, and disclosure of your Personal Data as described herein. If you do not agree with this Policy, you must not access the Site or use our Services.

2. Information We Collect

We collect information to provide, operate, and improve our Services. The types of information we collect depend on your interaction with us:

2.1. Information You Provide Directly:

• Contact and Business Information: When you contact us (e.g., via contact forms, email), request a demo, or use specific tools, we may collect your name, email address, phone number, business name, business website, business description, and any other information you choose to provide in your communications or form submissions.
• Service-Specific Data You Submit: For certain Services, such as our free analysis tools (e.g., Google Ads Search Term Analyzer), you may provide data files (e.g., CSV reports via a shareable cloud storage link) and contextual information (e.g., keyword themes). The handling of such data is further detailed in Section 3 and any tool-specific terms you accept.

2.2. Information Collected Automatically (Site and Service Usage):

• Log Data and Device Information: When you visit our Site or use our Services, our servers (or those of our third-party service providers) automatically record information ("Log Data"). This Log Data may include your IP address, browser type and settings, device information (e.g., operating system, device identifiers), referring/exit pages, URLs, number of clicks, pages viewed, time spent on pages, date and time stamps, and other usage statistics.
• Cookies and Similar Tracking Technologies: We use cookies, web beacons, pixels, and other similar technologies to operate and administer our Site, gather usage data, enhance security, and improve your experience.
• Browser Characteristics for Abuse Prevention (e.g., for Free Tools): To maintain the integrity of our free Services and prevent abuse (such as excessive use or automated bot activity), we may collect and process certain general browser and device characteristics to generate a unique browser identifier (sometimes referred to as a "browser fingerprint"). This identifier helps us with rate-limiting and understanding usage patterns for service improvement. This identifier is derived from standard information your browser makes available and does not, on its own, directly identify you personally beyond your browser instance. We log this identifier along with an email address (if provided by you for the service) and timestamp for these limited purposes.

2.3. Information Accessed via Third-Party Platform Integrations (e.g., Facebook Marketing API):

For Services involving integration with third-party platforms like Facebook, and only upon your explicit authorization and granted permissions through that platform's native consent mechanisms, we may access or receive data from your connected accounts. This access is strictly limited by the permissions you grant and is necessary for the functionality of the requested automation Service. For example, with Facebook Marketing API, this might include (but is not limited to):

• Ad Account IDs, Campaign/Ad Set/Ad IDs, Page IDs, and associated configuration and performance metrics (impressions, clicks, cost, conversions, etc.) as made available by the API and permitted by you.

We do not request or store your login credentials (e.g., passwords) for these third-party platforms. Our access and use are governed by the API terms of the respective platform and the permissions you set.

3. How We Use Your Information (Our Purposes)

We use the information we collect for the following purposes, based on legitimate interests, performance of a contract, consent (where applicable), or legal obligations:

• To Provide and Operate Our Services: Delivering the functionalities of our Site and the specific Services you engage with, including processing data you submit for analysis (e.g., in the Google Ads Search Term Analyzer) or automating tasks via platform APIs as authorized by you.
• To Improve and Develop Our Services: Analyzing usage patterns, troubleshooting, and understanding user needs to enhance existing Services and develop new ones. This may include using anonymized or aggregated data derived from service usage (excluding your raw, identifiable campaign data from submitted CSVs or sensitive API data unless explicitly for your direct benefit and with your understanding).
• To Communicate With You: Responding to your inquiries, sending service-related communications, updates, and administrative messages.
• For Security and Abuse Prevention: Protecting the security and integrity of our Site and Services, preventing fraud, spam, and unauthorized access or use, including through rate-limiting mechanisms based on email and/or browser identifiers for free tools.
• For Analytics: Understanding how our Site and Services are used to measure effectiveness and guide improvements. This is typically done with aggregated or pseudonymized data.
• To Comply with Legal Obligations: Fulfilling our legal and regulatory duties, responding to lawful requests from authorities, and enforcing our terms and policies.
• For Marketing (with Consent): If you opt-in, we may send you promotional communications about our products and services. You can opt-out at any time.

Specific to Free Analysis Tools (e.g., Google Ads Search Term Analyzer): Data you submit (e.g., CSV files, business descriptions) is used by our automated system *exclusively* to generate the analysis report for you for that specific session. We do NOT store your uploaded CSV data or the specific content of your search term report on our servers long-term after the analysis is provided to you. This data is NOT used to train our general AI models or for any other purpose beyond providing you with the immediate, one-time report, unless explicitly stated otherwise and agreed to by you for a different service. As stated in section 2.2, we do log email and browser identifiers associated with the use of such free tools for abuse prevention and internal usage analytics.

4. Sharing and Disclosure of Information

OSINITY PTE. LTD. is committed to protecting your privacy and **does not sell your Personal Data.** We may share your information only in the following limited circumstances:

• Third-Party Service Providers: We engage trusted third-party companies and individuals to perform functions on our behalf (e.g., cloud hosting providers like AWS/Google Cloud, email service providers, analytics providers, customer support tools, security services, and potentially specialized AI processing partners for specific service components). These providers are contractually obligated to process your data only for the purposes we specify, to maintain confidentiality, and to implement appropriate security measures. They do not have any independent right to use your Personal Data except as necessary to provide their services to us.
• Third-Party Platform Integrations (as authorized by you): When you authorize our Services to connect with platforms like Facebook, data is exchanged via their APIs as per your granted permissions. This interaction is governed by your agreement with that platform and their respective privacy policies.
• Legal Compliance and Protection: We may disclose your information if required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation or governmental request, (ii.ii) protect and defend the rights or property of Osinity, (iii) prevent or investigate possible wrongdoing in connection with the Services, (iv) act in urgent circumstances to protect the personal safety of users of the Services or the public, or (v) protect against legal liability.
• Business Transfers: In connection with any merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company, your information may be transferred as part of that transaction. We will notify you via email and/or a prominent notice on our Site of any change in ownership or uses of your Personal Data, as well as any choices you may have.
• With Your Explicit Consent: We may share your information with other third parties when we have your explicit consent to do so for a specified purpose.

5. Data Security

We implement appropriate technical and organizational security measures designed to protect the security of any Personal Data we process. These measures include, but are not limited to, access controls, encryption (where appropriate), and regular security assessments. However, please also remember that no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security. You are responsible for keeping any passwords or access tokens confidential.

6. Data Retention

We will retain your Personal Data only for as long as is necessary for the purposes set out in this Policy, or as required to comply with our legal obligations (e.g., if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies. Retention periods will vary depending on the type of information and why we collected it.

• Information provided through contact forms or direct communication will be retained for as long as necessary to address your inquiry and for reasonable business record-keeping.
• Data accessed via authorized third-party platform APIs (e.g., Facebook) will be handled in accordance with that platform's terms and our service agreement with you, typically retained only as long as needed to provide the active service and securely deleted or de-identified upon service termination or permission revocation.
• Log data and site analytics data (often aggregated or pseudonymized) may be kept for longer periods for analytical and service improvement purposes.
• Information collected for abuse prevention for free tools (email, browser identifier, timestamp) will be retained for a reasonable period necessary to fulfill that purpose (e.g., to enforce daily limits).

7. Your Data Protection Rights (PDPA & General)

Depending on your location and applicable data protection laws (including Singapore's PDPA), you may have certain rights regarding your Personal Data. These may include:

• The right to access – You have the right to request copies of your Personal Data we hold.
• The right to rectification (correction) – You have the right to request that we correct any information you believe is inaccurate or complete information you believe is incomplete.
• The right to erasure (deletion) – You have the right to request that we erase your Personal Data, under certain conditions.
• The right to restrict processing – You have the right to request that we restrict the processing of your Personal Data, under certain conditions.
• The right to object to processing – You have the right to object to our processing of your Personal Data, under certain conditions, particularly for direct marketing.
• The right to data portability – You have the right to request that we transfer the data that we have collected to another organization, or directly to you, under certain conditions.
• The right to withdraw consent – Where we rely on your consent to process your Personal Data, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.

To exercise any of these rights, please contact our Data Privacy Officer using the details in Section 13 ("Contact Us"). We will respond to your request within a reasonable timeframe and in accordance with applicable laws. We may require you to verify your identity before we can act on your request. Please note that these rights are not absolute and may be subject to certain exemptions or limitations.

For data accessed via third-party platforms like Facebook, you can typically manage or revoke app permissions directly within that platform's settings.

8. Cookies and Tracking Technologies

Our Site and Services use cookies and similar technologies (e.g., web beacons, pixels, local storage). These technologies are used for various purposes such as enabling essential site functionality, remembering your preferences, analyzing site traffic and user interactions (often via Google Tag Manager which may deploy other analytics or marketing cookies based on our configuration), enhancing security (e.g., Google reCAPTCHA), and facilitating embedded third-party content (e.g., Wistia videos).

For detailed information about the cookies we use, their purposes, and how you can manage your cookie preferences, please refer to our separate **Cookie Policy**. Most browsers allow you to control cookies through their settings. However, disabling certain cookies may affect the functionality of our Site and Services.

9. Children's Privacy

Our Site and Services are not directed to individuals under the age of 16 (or the relevant age of majority in their jurisdiction). We do not knowingly collect Personal Data from children. If we become aware that we have inadvertently collected Personal Data from a child without verification of parental consent, we will take steps to delete that information. If you are a parent or guardian and believe your child has provided us with Personal Data, please contact us.

10. International Data Transfers

Osinity is based in Singapore. Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ from those in your jurisdiction. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Policy and that appropriate safeguards are in place for such transfers, complying with applicable legal requirements (e.g., Singapore PDPA requirements for cross-border transfers, standard contractual clauses if transferring from EEA/UK).

11. Links to Other Websites

Our Site or Services may contain links to other websites or services not operated or controlled by Osinity ("Third-Party Sites"). The information that you share with Third-Party Sites will be governed by the specific privacy policies and terms of service of the Third-Party Sites and not by this Policy. By providing these links we do not imply that we endorse or have reviewed these sites. Please contact the Third-Party Sites directly for information on their privacy practices and policies.

12. Governing Law

This Privacy Policy and any dispute or claim arising out of or in connection with it or its subject matter or formation (including non-contractual disputes or claims) shall be governed by and construed in accordance with the laws of the Republic of Singapore, without giving effect to any choice or conflict of law provision or rule.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, service offerings, or legal requirements. We will post any changes on this page and update the "Last Updated" date at the top of this Policy. If we make material changes, we may provide more prominent notice (such as by adding a statement to our homepage or sending you a notification if we have your email address and it's appropriate). We encourage you to review this Policy periodically to stay informed about how we are protecting the information we collect.

14. Contact Us / Data Protection Officer

If you have any questions, comments, or concerns about this Privacy Policy, our data practices, or if you wish to exercise your data protection rights, please contact our Data Protection Officer:

Data Protection Officer
OSINITY PTE. LTD.
74 FLORA ROAD, #4-30, THE GALE
Singapore 506895
Email: jj@osinity.com

This Privacy Policy is intended to provide a general overview of Osinity's data practices. It is essential to have this document and your specific data processing activities reviewed by qualified legal counsel to ensure full compliance with all applicable laws and regulations, including but not limited to Singapore's PDPA, Facebook's Platform Terms, and any international data protection laws relevant to your users and operations.