Privacy Policy

1. Introduction

Pagsun ("Pagsun," "we," "us," or "our"), a company registered in Singapore, is committed to protecting your privacy and personal data. This Privacy Policy explains how we collect, use, process, and protect your personal information when you use our website and the Pagsun AI platform, where you describe a job, book a session, and define your AI teammate with our team.

This policy complies with applicable data protection laws, including Singapore's Personal Data Protection Act 2012 (PDPA), India's Digital Personal Data Protection Act, 2023 (DPDP Act), the UK GDPR and Data Protection Act 2018, the European Union's General Data Protection Regulation (GDPR), Hong Kong's Personal Data (Privacy) Ordinance (PDPO), the California Consumer Privacy Act (CCPA), New York's SHIELD Act, and other relevant privacy regulations.

2. Data Controller Information

3. Data Protection Officer

In line with Singapore's PDPA and as a matter of good practice everywhere we operate, we designate the following contact point as our Data Protection Officer for all privacy-related matters: ai@pagsun.com.

4. Information We Collect

4.1 Personal Information You Provide

• Account Information: Full name, email address, and phone number, collected when you sign in and set up your organization
• Business Profile: Job role, industry, business name, website, and your familiarity with AI, so your AI teammate is scoped to your actual situation
• Task Description: The job you describe when you describe it, and anything you share with our team during your Define sessions

Please do not include special category data (such as health records, government ID numbers, or financial account numbers) in your task description or anything else you share with us. We only ask for what's needed to scope and implement the specific job you describe.

4.2 Information Automatically Collected

• Device Information: IP address, browser type, device identifiers, operating system
• Usage Data: Pages visited, time spent, and how you interact with the platform, collected via our product analytics provider
• Advertising Data: If you arrive via one of our ads, our advertising partners may share limited browser and membership data with us to measure ad performance and build advertising audiences. See Section 12 for details
• Cookies: An essential session cookie that keeps you signed in, plus analytics and advertising cookies. See Section 12 for details
• Bot Protection: When you sign in, a bot-protection service checks that you're human before we send a login code — this shares limited browser signals with that provider

4.3 Business Data Your AI Teammate Works With

If you go ahead with Onboard and Work together, your AI teammate works with documents and systems from your business. Pagsun hosts and runs your AI teammate. How your business data is handled during those phases is set out in your written agreement rather than in this policy.

5. How We Use Your Information

5.1 Primary Purposes

• Service Delivery: Prepare our notes on your job and the documents we prepare with you, and run your live Define sessions by video call
• Account & Access: Authenticate you, keep you signed in, and apply the daily limit on new jobs fairly
• Communication: Respond to inquiries, provide support by email, and send updates about your job or sessions

5.2 Secondary Purposes (With Your Consent)

• Service Improvement: Analyse usage patterns through our analytics provider to improve the platform
• Marketing: Send promotional materials or updates relevant to your AI teammate, where you haven't opted out

Every marketing message includes a clear way to opt out, and we stop on request — consistent with Hong Kong PDPO's direct marketing requirements as well as general good practice.

6. Legal Basis for Processing

• Consent: For marketing communications and non-essential analytics
• Contract Performance: To deliver our services and fulfil our obligations to you
• Legitimate Interest: For service improvement, security, and fraud prevention
• Legal Compliance: To comply with applicable laws and regulations

7. Data Sharing and Disclosure

7.1 Third-Party Service Providers

• Hosting and authentication: Store our database and handle sign-in
• Video calls: Host your live Define sessions
• Product analytics: Help us understand how the platform is used
• Advertising: Measure the performance of our ad campaigns
• Security: Provide bot protection on our login page

We only share what each provider needs to do its job, under agreements that require them to protect it. As we develop the platform, the providers we use may change; we'll update this policy when the kinds of providers we share data with change. You can ask us at ai@pagsun.com for the current list.

7.2 Legal Disclosure

We may disclose your information if required by law, court order, or to protect our rights, property, or safety, or that of our users or the public.

7.3 Business Transfers

In the event of a merger, acquisition, or sale of assets, your information may be transferred. We will provide notice before your personal data is transferred and becomes subject to a different privacy policy.

8. Data Security

We implement technical and organisational measures to protect your personal data against unauthorised access, alteration, disclosure, or destruction:

• SSL/TLS encryption for all data transmissions
• Row-level database security, so your data is only ever readable by you and our systems, never by other users
• Column-level restrictions on sensitive fields, writable only by our verified backend, never directly by a user's browser
• Access controls limiting who on our team can see your data

In the event of a data breach affecting your personal information, we will notify affected users and, where required, the relevant regulator (including under New York's SHIELD Act and other applicable breach notification laws) without undue delay.

9. Data Retention

• Active Users: Data retained while you use our services and for a reasonable period after your last activity, so you can pick up where you left off
• Payment Records: Retained for 7 years for tax and accounting purposes
• Analytics: Retained per our analytics provider's standard retention period
• Advertising Data: Retained per our advertising partners' standard retention periods
• Marketing Data: Deleted upon unsubscribe or opt-out

10. Your Rights

We offer the following rights to all users globally, as a matter of policy — including in jurisdictions like Hong Kong and New York, where local law does not require the full set:

How to Exercise Your Rights

To exercise any of these rights, contact us at ai@pagsun.com. We will respond within 30 days for DPDP and PDPA requests, and 1 month for GDPR (EU and UK) requests.

11. International Data Transfers

Several of our service providers operate internationally, so your personal data may be transferred to and processed in countries other than your country of residence. Where required, we rely on:

• Standard Contractual Clauses (SCCs) for EU data transfers, and the UK International Data Transfer Addendum for UK data transfers
• Adequacy decisions where available
• Data Processing Agreements with our service providers
• Comparable safeguards for transfers from Singapore, consistent with the PDPA's transfer limitation obligation

For Hong Kong users: we follow the PCPD's recommended cross-border transfer safeguards as a matter of best practice.

12. Cookies and Tracking Technologies

We keep cookie usage minimal:

• Essential Cookies: A session cookie that keeps you signed in. The platform doesn't function without this one.
• Analytics Cookies: Set by our analytics provider to understand how the platform is used. If you're signed in, these are linked to your account (name and email) so we can improve the product for real usage patterns.
• Advertising Cookies: Set by our advertising partners to measure the performance of our ad campaigns and, if you're a member of their platform, to build advertising audiences. Each partner's own privacy policy explains how it handles this data.

We don't currently run a cookie consent banner. You can block cookies in your browser settings, opt out of ad tracking through your account settings on the advertising platform, or contact us at ai@pagsun.com to opt out of analytics or advertising tracking.

13. Children's Privacy

Our services are designed for business leaders aged 18 and above. We do not knowingly collect personal information from children under 18. If we become aware that we have collected personal data from a child under 18, we will delete it immediately.

14. Complaints and Supervisory Authorities

If you have concerns about how we handle your personal data, you can file a complaint with the relevant supervisory authority:

• Singapore: Personal Data Protection Commission (PDPC)
• India: Data Protection Board of India
• EU: Your local Data Protection Authority
• UK: Information Commissioner's Office (ICO)
• Hong Kong: Office of the Privacy Commissioner for Personal Data (PCPD)
• California: California Attorney General's Office
• New York: New York Attorney General's Office

15. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of any material changes by posting the new policy on our website and, where appropriate, by email. Changes will be effective 30 days after posting unless a longer notice period is required by law.

16. Contact Us