PaiNotes Privacy Policy

This privacy policy (“Privacy Policy”) applies to the personal information that PERSONAL ASSISTANT INTELLIGENCE PTE. LTD. , Ltd. (“PaiNotes,” “Company,” “we,” or “our”) processes in connection with PaiNotes apps, websites, software and related services (the “Services”), that link to or reference this Privacy Policy.

Data Controller: PERSONAL ASSISTANT INTELLIGENCE PTE. LTD. , Ltd. 60 PAYA LEBAR ROAD#11-53 PAYA LEBAR SQUARE SINGAPORE

What Information We Collect

We collect your information in three ways: Information You Provide, Automatically Collected Information, and Information From Other Sources. More detail is provided below.

Information You Provide

Registration information. We may collect information that you provide when you set up an account, such as your nickname, grade, and a password. If you access or use the Services as an unregistered user, we may nonetheless collect your grade.
User Content. We collect the content you create or publish through the Services, such as photographs, comments, feedback, reviews, and the associated metadata (such as when, where, and by whom the content was created). When you use our community feature, we will collect the post submitted by you, including the question and the description in that post.
Chats and Messages. If you chat or otherwise interact with other users, we will also receive that information in order to provide you with the chatting and other interactive features.
Your Contacts. If you choose to sync your contacts, we will collect information from your device’s phone book such as names, phone numbers, and email addresses, and match that information to users of the Services. If you choose to find other users through your social network contacts, we will collect your public profile information as well as names and profiles of your social network contacts.
Purchase Information. When you make a purchase or payment on or through the Services, such as when you purchase a course, we collect information about the purchase or payment transaction, such as payment card information, billing, contact information, and items you purchased.
Surveys, Research, and Promotions. We collect information you provide if you choose to participate in a survey, research, promotion, contest, marketing campaign, or event conducted or sponsored by us.
Information When You Contact Us. When you contact us, we collect the information you send us, such as feedback or inquiries about your use of the Services or information about possible violations of our Terms or other policies.

Automatically Collected Information

Technical Information. We collect certain device and network connection information when you access the Services. This includes your device model, operating system and version, unique device identifiers, IP Address and mobile network information. We also collect service-related, diagnostic, and performance information, including crash reports and performance logs.
Location Information. We automatically collect information about your approximate location (e.g., country, state, or city) based on your Technical Information (such as IP address and SIM card region).
Application System information. We may collect the application information associated with the Services, such as the application version, application language and permission settings.
Usage information. We may collect information about how you engage with the Services, including information about the content you view, the duration and frequency of your use, your engagement with other users, and your search history.
Cookies. We use cookies and similar tracking technologies to operate and provide the Services. For example, we use cookies to remember your language preferences and for security purposes. We also use these technologies for marketing purposes. We will obtain your consent to our use of cookies where required by law.

Information From Other Sources

Payment Providers. We receive information about you from payment providers, such as payment confirmation details.
Third Party Platforms and Partners. Third party platforms, such as Apple, Facebook, and Google) provide us with information (such as your email address, user ID, and public profile) when you choose to sign up for or log in to the Services using sign-in features provided by those third parties.
Others. We may receive information about you from others, for example, where you are included or mentioned in User Content, Direct Messages, in a complaint, appeal, request or feedback submitted by a user or third party, or if your contact information is provided to us by a user.

How We Use Your Information

We use your information to operate, provide, develop, and improve the Services, including for the following purposes:

Provide and administer the Services, such as enabling you to create, share, and consume content, to interact with other users, and to provide user support.
To facilitate the purchase and delivery of products, goods and services, such as courses, including sharing your information with payment and transaction fulfillment providers, and other service providers in order to process your orders.
Enforce our Terms, Guidelines, and other policies that apply to you. We review User Content and other information to protect the safety and well-being of our community.
To measure and understand the effectiveness of the advertisements we serve to you and others and to deliver advertising to you on the Services, including advertising based on your activity on other apps and websites (“targeted advertising”) and advertising based on your activity on the Services.
Maintain and enhance the safety, security, and stability of the Services by identifying and addressing technical or security issues or problems (such as technical bugs, spam accounts, and detecting abuse, fraud, and illegal activity).
Review, improve, and develop the Services, including by monitoring interactions and usage across your devices, analyzing how people are using it, and by training and improving our technology, such as our machine learning models and algorithms.
Promote the Services through marketing communications, contests, or promotions.
Comply with our legal obligations, or as necessary to perform tasks in the public interest, or to protect the vital interests of our users and other people.

How We Share Your Information

Service Providers

We engage service providers that help us provide, support, and develop the Services and understand how it is used. They provide services such as cloud hosting, content delivery, customer and technical support, content moderation, marketing, analytics, and online payment. We share Information You Provide, Automatically Collected Information, and Information From Other Sources with these service providers as necessary to enable them to provide their services.

Business Partners

Third Party Platforms and Partners. We share limited information which may include Information You Provide, Technical Information, and Usage Information with third party platforms and partners whose platform or services are integrated with the Services. We do this to give you a seamless experience, allow your content to be shared on other platforms, and/or enable third party platforms and partners to better authenticate users.

Advertising and Analytics Partners. We may share information collected through your use of the Services with our advertising and analytics partners. These partners may help us and our partners deliver advertising on the Services, promote the Services on other apps and websites, and measure the effectiveness of advertising.

Payment Providers and Other Service Providers. When you purchase a course on the Services, we may share Purchase Information related to the transaction with payment providers and other service providers. We may also share certain Technical Information about your device or connection with these parties to help ensure the security of the transaction.

Our Corporate Group

The Services are supported by certain entities within our corporate group (“Corporate Group”). These entities process Information You Provide, Automatically Collected Information, and Information From Other Sources for us, as necessary to provide certain functions, such as storage, content delivery, security, research and development, analytics, online payments, customer and technical support, and content moderation.

Others

We may share your information in other limited scenarios as follows:

Other Users. Your Profile Information and User Content may be visible to other users and the public. Your profile and content may also be visible to third parties, such as search engines, content aggregators, and news sites. You and other individuals may be able to share your User Content both on and off the Services.
Corporate Transactions. Your information may be disclosed to third parties in connection with a corporate transaction, such as a merger, sale of assets or shares, reorganization, financing, change of control, or acquisition of all or a portion of our business.
Legal Obligations and Rights. We may access, preserve, and share the information described in "What Information We Collect" with law enforcement agencies, public authorities, copyright holders, or other third parties if we have good faith belief that it is necessary to comply with any applicable laws, regulations, codes of practice, governmental guidelines, or other legal and regulatory obligations, protect rights, property, and safety, or investigate potential violations and address illegal activity.
With Your Consent. Depending on where you live, we may share personal information with the proper authorization or to provide the Services you have requested or authorized.

Third-party content

The Services may contain links to policies, functionality, or content maintained by third parties who we do not control. We are not responsible for, and make no representations regarding, such policies, functionality, or content or any other practices or operations of such third parties. If there are links to third party websites, please note that these websites are governed by their own privacy policies and terms of use.

Data Security

Security of your information is important to us. We maintain appropriate technical, administrative, and physical security measures that are designed to protect your information from unauthorized access, theft, disclosure, modification, or loss. We regularly review our security measures to consider available new technology and methods.

Data Retention

We retain information for as long as necessary to provide the Services and for the other purposes set out in this Privacy Policy. We may also retain information when necessary to comply with contractual and legal obligations, when we have a legitimate business interest to do so, and for the exercise or defense of legal claims. The retention periods will be different depending on the type of information and the purposes for which we use the information. For example, when we process your information to provide you with the Services, we keep this information for as long as you have an account.

International Data Transfers

The personal information we collect from you may be stored on a server located outside of the country where you live. We store the information we collect in secure servers located in China. Where we transfer any personal information out of the country where you live, we will do so in accordance with the requirements of applicable data protection laws.

Your Rights and Choices

Depending on where you live, you may have certain rights with respect to your personal information, such as a right to know, access, update, rectify and change your data, oppose to its processing, withdraw your consent, or limit our collection and use of your personal information as well as to request that we delete it. Please contact us at Pai_report@paperpai.com to exercise any of your rights.

Information Relating to Minors

PaiNotes is not directed at children under the age of 13. The minimum age to use the Services may differ depending on the country or region you are in. If you believe that we have collected personal information from a minor under the minimum age, please contact us at Pai_report@paperpai.com.

Privacy Policy Updates

We may amend or update this Privacy Policy from time to time. When we update the Privacy Policy, we will notify you of any material changes to this policy by updating the “Last Updated” date at the top of the new Privacy Policy, posting the new Privacy Policy, or providing any other notice required by applicable law.

Contact Us

Questions, comments and requests regarding this Privacy Policy should be addressed to: Pai_report@paperpai.com.

SUPPLEMENTAL TERMS – JURISDICTION SPECIFIC

In the event of a conflict between the provisions of the Supplemental Terms – Jurisdiction Specific that are relevant to your jurisdiction from which you access or use the services, and the rest of the Privacy Policy, the relevant jurisdictions’ Supplemental Terms – Jurisdiction Specific will supersede and control.

European Economic Area (“EEA”), Switzerland, and UK

If you are using the Services in the EEA, Switzerland or the UK (the “European Region”), the following additional terms apply:

Legal Bases for Processing

We use your personal data only as permitted by law. Our legal bases for processing your personal information described in this Policy are described in the table below.

Personal information categories and processing purpose	Legal basis
We use the <Information You Provide>, <Automatically Collected Information>, and <Information From Other Sources>, for example: Registration Information; User Content and Usage Information; Technical Information. to provide and administer the Services, such as enabling you to create, share, and consume content, and to interact with other users.	Processing is necessary to perform the contract governing our provision of the Services or to take steps that you request prior to signing up for an account to use the Services.
We use the <Information You Provide>, <Automatically Collected Information>, and <Information From Other Sources>, for example: Registration Information; Purchase Information; Payment Providers. to facilitate the purchase of products, goods and services. This includes sharing your information with payment providers, and other service providers in order to process your orders.	Processing is necessary to perform the contract governing our provision of the Services or to take steps that you request prior to signing up for an account to use the Services.
We use the <Information You Provide>, <Automatically Collected Information>, and <Information From Other Sources>, for example: Registration Information; User Content and Usage Information; Surveys, Research and Promotions; Information When You Contact Us; and Technical Information to understand how you use the Services, and to review, improve and develop the Services, including by monitoring interactions and usage across your devices, and to train and improve our technology, such as our machine learning models and algorithms.	The processing is necessary for our legitimate interests, namely, to improve and develop the Services.
We share your information with third parties whose platforms or services are integrated with the Services. For example, if you: sign-up or log-in to the Services using your account details from a third party platform (such as Facebook or Google), we will facilitate the process by sharing certain Technical Information. share User Content you publish on the Services with other social media platforms, we will share your User Content and related information.	This processing is necessary for our legitimate interests, namely to provide you with a seamless experience, allow your content to be shared on other platforms, enable third parties to authenticate users, and optimise user experience.
The categories of information that we use will depend on the specific circumstances of each request or obligation. Depending on the circumstances, We use the <Information You Provide>, <Automatically Collected Information>, and <Information From Other Sources>, for example: Registration Information; User Content and Usage Information; Others; and Technical Information to comply with any legal obligation, including where necessary to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority.	This processing is necessary in order to comply with our legal obligations under European Union or Member State law. This includes situations where we have obligations to take measures to ensure the safety of our users or comply with a valid legal request such as an order from law enforcement agencies or courts. Similarly processing may be necessary to respond to regulatory requests requiring the processing of information under Chapters IV and VI of the GDPR. In other circumstances, the processing is necessary for our legitimate interests, namely, to disclose and share information with regulators or other government entities.
We use the <Information You Provide>, <Automatically Collected Information>, and <Information From Other Sources>, for example: Registration Information; Information When You Contact Us; and Technical Information to communicate with you, including to notify you about changes to the Services, provide customer support to you and send you other service-related messages.	The processing is necessary for the performance of a contract with you.
We use the <Information You Provide>, <Automatically Collected Information>, and <Information From Other Sources>, for example: Registration Information; User Content and Usage Information; Technical Information to send you marketing communications in accordance with your preferences. We may also send you promotions or contests.	The processing is necessary for our legitimate interests, namely to promote new developments and features of our Services. We will obtain your consent to send you messages where required by law.
We use the <Information You Provide>, <Automatically Collected Information>, and <Information From Other Sources>, for example: Registration Information; User Content and Usage Information; Others; and Technical Information to enforce our Terms of Service, guidelines and policies.	The processing is necessary for the performance of a contract with you.
We use the <Information You Provide>, <Automatically Collected Information>, and <Information From Other Sources>, for example: Registration Information; User Content and Usage Information; Others; and Technical Information to maintain and enhance the safety, security, and stability of the Services by identifying and addressing technical or security issues such as technical bugs and spam accounts, and detecting abuse, fraud, and illegal activity on the Services including by scanning and reviewing User Content and other information.	The processing is necessary for our legitimate interests, namely, to ensure that the Services are safe and secure, to ensure compliance with our Terms of Service, guidelines and other policies, and to identify misuse of the Services; and to ensure the ongoing stability and security of the Services and to ensure they are continuously available and functioning.
In some cases, we may aggregate or anonymize the <Information You Provide>, <Automatically Collected Information>, and <Information From Other Sources> and use it in a way that is designed to be unable to identify you, for research or other purposes, to the extent allowed by applicable law.	The processing is necessary for our legitimate interests, namely to conduct research and protect personal information through aggregation or anonymization, consistent with data minimization and privacy by design principles.
We may use the <Information You Provide>, <Automatically Collected Information>, and <Information From Other Sources> where it is necessary to protect your or someone else's life, physical integrity, or safety. This could include providing law enforcement agencies or emergency services with information in urgent situations to protect health or life. The specific types of information we use will depend on the specific situation.	The processing is necessary to protect the vital interests of you or other individuals.

International Data Transfers

If you normally reside in the European Region, the personal data that we collect about you may be further transferred to, and stored at, a destination outside of the European Region (for instance, to our service providers and partners). For example, we store the information that we collect in secure servers located in China.

When we transfer your information outside of the European Region, we ensure it benefits from an adequate level of data protection by relying on:
Adequacy decisions. These are decisions from the European Commission under Article 45 GDPR (or equivalent decisions under other laws) where they recognise that a country offers an adequate level of data protection. We transfer your information to some countries with adequacy decisions; or
Standard contractual clauses. The European Commission has approved contractual clauses under Article 46 of the GDPR that allows companies in the EEA to transfer data outside the EEA. These (and their approved equivalent for the UK and Switzerland) are called standard contractual clauses. We rely on standard contractual clauses to transfer your information to certain entities in our corporate group and third parties in countries without an adequacy decision.

If you wish to enquire further about these safeguards, please contact us at Pai_report@paperpai.com.

Your Rights

You have the following rights:

The right to request free of charge (i) confirmation of whether we process your personal data and (ii) access to a copy of the personal data retained;
The right to request proper rectification or erasure of your personal data;
Where processing of your personal data is either based on your consent or necessary for the performance of a contract with you and processing is carried out by automated means, the right to receive the personal data concerning you in a structured, commonly used and machine-readable format or to have your personal data transmitted directly to another company, where technically feasible (data portability);
Where the processing of your personal data is based on your consent, the right to withdraw your consent at any time (withdrawal will not impact the lawfulness of data processing activities that have taken place before such withdrawal);
The right not to be subject to any automatic individual decisions, including profiling, which produces legal effects on you or similarly significantly affects you unless we have your consent, this is authorised by Union or Member State law or this is necessary for the performance of a contract;
The right to object to processing if we are processing your personal data on the basis of our legitimate interest unless we can demonstrate compelling legitimate grounds which may override your right. If you object to such processing, we ask you to state the grounds of your objection in order for us to examine the processing of your personal data and to balance our legitimate interest in processing and your objection to this processing;
The right to request the restriction of the processing of your information where (a) you are challenging the accuracy of the information, (b) the information has been unlawfully processed, but you are opposing the deletion of that information, (c) where you need the information to be retained for the pursuit or defence of a legal claim, or (d) you have objected to processing and you are awaiting the outcome of that objection request;
The right to object to processing your personal data for direct marketing purposes; and
The right to lodge complaints before your local data protection authority.

Before we can respond to a request to exercise one or more of the rights listed above, you may be required to verify your identity or your account details. Please send an email to us if you would like to exercise any of your rights at Pai_report@paperpai.com.

Indonesia

If you are using our Services in Indonesia, the following additional terms apply. In the event of any conflict between the following additional terms and the provisions of the main body of this Policy, the following terms shall prevail.

Age, Parental and Guardian Consent. By accessing and/or using our Services, you represent that you are at least 21 years of age or married or not under guardianship. If you are below 21 years old and you are not married, or under guardianship:

you must obtain approval from your parent(s) or legal guardian(s); and
your parent(s) or legal guardian(s) are responsible for: (i) all your actions in connection with your access to and use of the Services; (ii) your compliance with this policy; and (iii) ensuring that any of your participation in the Services will not, in any event, result in any violation of applicable laws and regulations relating to child protection.

If you do not have consent from your parent(s) or legal guardian(s) and your parent(s) or guardian(s) is not willing to open the account under their name, you must cease accessing and/or using the Services.

Your Choices. You may withdraw your consent to our disclosure of personal data to third parties. Upon your request, we will display, publish, transmit, disseminate, and/or open the access to your personal data to third parties. Please note that by withdrawing your consent to the disclosure and/or collection of your personal data, we may not be able to fulfill your requests and you may not be able to use some of PaiNotes’s features and functionality.

You may request that we: (i) disclose the history of personal data that we have collected; and/or (ii) erase and dispose of your personal data that we have collected on our server. Please note that by requesting us to erase and dispose of your personal data, you may not be able to use some of PaiNotes's features and functionality. To exercise any of your rights, contact us at Pai_report@paperpai.com.

Notification. In the event of any breach of personal data, we will notify you and provide you with information regarding such breach of personal data.

Data Retention. We retain your information for as long as it is necessary to provide you with the service. Where we do not need your information in order to provide the service to you, we retain it only for so long as we have a legitimate business purpose in keeping such data. However, there are occasions where we are likely to keep this data for five (5) years (or longer if required) in accordance with our legal obligations or where it is necessary for the establishment, exercise or defence of legal claims.

After you have terminated your use of our Services and the five (5) years retention period has lapsed, we store your information in an aggregated and anonymised format. Non-personally identifiable information may be retained indefinitely for analytics.

Brazil

If you are using the Services in Brazil, the following additional terms apply:

Exercise of data protection rights. Brazilian law provides certain rights to individuals with regard to their personal data. Thus, we seek to ensure transparency and access controls to allow users to benefit from the mentioned rights. We will respond and/or fulfill your requests for the exercise of your rights (confirmation, access, correction, anonymization, portability, objection, withdrawal of consent, etc.) according to the applicable law and the LGPD.

Verifying your identity. We may request specific information and/or documents from you before we can properly respond to a request received concerning your data for your safety and to authenticate your identity.

International Transfer of Data. We share your personal data globally with companies of our business group. Whenever we transfer your personal data to third parties located in other countries, we will ensure that these companies comply with applicable data protection laws.

DPO. If you wish to contact the Data Protection Officer, please contact us: Pai_report@paperpai.com

Canada

The minimum age to use the Service in Canada is 14. If you are using the Services in Canada, the following additional terms apply.

Your Rights. You have the right to access, update, rectify and correct inaccuracies in your personal information and to withdraw your consent. To exercise these rights, you may contact us using the contact information set out in the “Contact Us” section.

Transfer Outside Your Jurisdiction. We and our service providers may access, store and otherwise process personal information outside of Canada (including in China), and other foreign jurisdictions where we or our service providers are located.

Argentina

If you are using the Services in Argentina, the following additional terms apply. In the event of any conflict, these terms shall prevail.

Your rights and options. According to Law No. 25,326, you have rights of access, rectification and deletion regarding data protection. If you have questions about your rights or how to exercise them, please contact us using the information in the "Contact Us" section. You also have the right to lodge a complaint with the AAIP.

Mexico

If you use the Services in Mexico, the following additional terms apply.

How we use your personal data. The following are secondary purposes: providing you with personalized advertising, marketing communications, contests, and promotions. You may be able to limit these secondary purposes via available tools in settings.

Your Rights. You have rights of access, rectification, cancellation, objection, consent withdrawal, limitation of use and disclosure of your data. You may exercise your rights by sending your request to Pai_report@paperpai.com.

Philippines

If you are using our Services in Philippines, you shall have the right to information, object, access, rectification, erasure or blocking, lodge complaints before the NPC, damages and data portability pursuant to relevant laws and regulations.

United States

If you are using our Services in the United States, the following additional terms apply:

Your Rights and Choices. Depending on where you live, you may be entitled to the Right to Know, Access and Data Portability, Deletion, and to Correct Inaccurate Information. You may exercise these rights by submitting your request via email to: Pai_report@paperpai.com

Other California Rights & Disclosures. The Services do not sell your personal information or share it for cross-context behavioral advertising where restricted by applicable law. You can request disclosure of categories of personal information shared with third parties for their direct marketing purposes. Our products do not support Do Not Track requests at this time.

Vietnam

If you are using our Services in Vietnam, the following additional terms apply:

Age, Parental and Guardian Consent. By accessing and/or using the Services, you represent that you are at least 16 years of age or not under guardianship. If you are below 16 years old or under guardianship, you must obtain approval from your parent(s) or legal guardian(s).