Effective Date: 2026.10.01
1.1 Welcome to use our products and services! We place great importance on your privacy and the protection of your user information. This Privacy Policy applies to the information you access, use, or retain regarding our products on our platform.
1.2 [INNOPAAS] (referred to as "We") is well aware of the importance of personal information protection and places high value on user privacy. This Privacy Policy explains how We collect, use, store, share, and protect your personal information when you use the International OM platform services.
1.3 Please read this Policy carefully before using our products and services. By accessing or continuing to use our products and services, you agree to have read and understood this Policy.
2.1 Information You Provide. We collect personal information that you provide to us directly, including:
(a) account information, such as your name, business contact details, email address, phone number, and login credentials when you register for or access the Platform;
(b) identity and verification information, such as government-issued identification, business registration documents, and know-your-customer (KYC) information required for compliance screening;
(c) billing information, such as billing address, bank account or payment details, and transaction records;
(d) correspondence and support information, such as records of your communications with us, support tickets, and survey responses; and
(e) any other personal information you choose to provide to us.
2.2 Information We Collect Automatically. When you access or use the Platform, we may automatically collect certain information, including:
(a) device and log information, such as IP address, browser type and version, operating system, device identifiers, pages visited, access times, and referring URLs;
(b) usage information, such as features used, API calls made, message volumes, and delivery records; and
(c) cookie and similar technology information, as described in Section 8.
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2.3 Information from Other Sources. We may receive personal information about you from third parties, including payment processors, fraud-prevention providers, business partners, and publicly available sources, to the extent permitted by applicable law.
2.4 Sensitive Personal Information. We may collect sensitive personal information. We do not use or disclose sensitive personal information for purposes other than those permitted by applicable law without your consent, and we do not sell or share sensitive personal information.
3.1 Purposes of Processing. We use personal information for the following purposes:
(a) to provide, operate, maintain, secure, and improve the Platform and the Services;
(b) to create and manage accounts, verify identity, and conduct compliance screening;
(c) to process payments, invoices, and billing inquiries;
(d) to communicate with you about the Services, including service updates, security alerts, and technical support;
(e) to enforce the Agreement, the Acceptable Use Policy, and this Policy, and to prevent, detect, and investigate fraud, abuse, and other unlawful activity;
(f) to comply with legal obligations, court orders, regulatory requests, and applicable sanctions requirements; and
(g) with your consent where required by applicable law, to send marketing communications about our products and services. You may withdraw your consent to marketing communications at any time by using the unsubscribe link in any marketing email or by contacting us using the details in Section 13. Withdrawal of consent will not affect the lawfulness of processing based on consent before its withdrawal.
3.2 Aggregated and De-identified Information. We may aggregate or de-identify personal information so that it can no longer be used to identify a natural person, and use or share such information for analytics, benchmarking, and service improvement, to the extent permitted by applicable law.
4.1 Categories of Recipients. We may share personal information with the following categories of recipients:
(a) affiliates and group companies, for the purposes set out in Section 4;
(b) service providers and sub-processors, including cloud infrastructure providers, payment processors, analytics providers, and customer-support providers, who process personal information on our behalf under contractual safeguards;
(c) professional advisers, including legal, accounting, and auditing advisers, where necessary to protect our rights or comply with legal obligations;
(d) regulatory, judicial, or governmental authorities, where disclosure is required by applicable law, court order, or regulation, or where we reasonably believe disclosure is necessary to protect the rights, property, or safety of the Platform, its Customers, End Users, or the public; and
(e) purchasers or transferees in connection with a merger, acquisition, reorganization, or sale of all or substantially all of our assets, subject to confidentiality obligations.
5.1 Our primary servers are currently located in Singapore. However, given that we provide global communication and customer interaction services, personal data may be transferred to, stored at, accessed from, or otherwise processed outside your jurisdiction.
5.2 In particular, such data may be transferred to overseas recipients due to message routing, carrier delivery, or cloud infrastructure support. Where WhatsApp services are involved, the relevant data is also subject to Meta's privacy policies.
5.3 To the extent required by applicable law, we will take reasonable steps to ensure that the protection standards provided by overseas recipients are no lower than the requirements of the applicable law. Such steps may include contractual arrangements, internal policies, access controls, technical and organizational safeguards, or other appropriate mechanisms. We enter into data processing agreements with all third-party processors, requiring them to process information solely pursuant to our instructions and to adopt protection measures that are no lower than those set forth in this Policy.
5.4 Compliance with the Hong Kong PDPO and the Singapore PDPA: As a data user whose principal place of operations is in Hong Kong, we comply with the six data protection principles set forth in the Personal Data (Privacy) Ordinance of Hong Kong, and we clearly inform data subjects of the relevant purposes before cross-border transfer of personal data, as well as of the overseas recipients. Pursuant to the transfer restrictions under the Personal Data Protection Act of Singapore, we ensure that overseas recipients are bound by legally enforceable obligations, provide protection standards no lower than those set forth in the PDPA, and fulfill such obligations through contractual terms, specific certifications, or binding corporate rules.
5.5 As the controller of personal data, you shall ensure that you have obtained lawful authorization for the cross-border transfer of end-user data, have informed the end-user of the name of the overseas recipient (including the Singapore server), the purpose of the processing, and the types of data, and have obtained the necessary consent from the end-user.
We retain personal data only for as long as necessary to achieve the objectives set forth in this Policy. Where longer retention periods are required or permitted by law, regulation, dispute resolution, auditing, taxation, accounting, security, anti-fraud, backup, or record retention requirements, we may retain the relevant data to the extent necessary.
When personal data is no longer necessary for the relevant purposes, we will delete, anonymize, or otherwise process such data in other appropriate ways, in accordance with applicable law and technical feasibility.
In certain circumstances, a request to deactivate or delete an account may not result in the immediate removal of the corresponding information from the backup system. In such cases, we will securely store this information, restrict further processing, and, where permitted by applicable law and technical feasibility, delete or anonymize it.
7.1We may use cookies, local storage, or similar technologies on the website and console for the following purposes:
• maintaining login sessions and basic website functionality;
• remembering your preferences;
• improving security and identifying abnormal activity; and
• understanding usage, performance, and traffic in order to improve the website or console experience.
7.2You may manage cookies through your browser or device settings. Please note that disabling certain cookies or similar technologies may affect the availability or functionality of some features.
8.1We attach great importance to data protection and implement appropriate technical and organizational measures to safeguard personal information from unauthorized access, loss, alteration or disclosure, including transmission encryption, access control, authentication, minimum privilege management, backup, and employee confidentiality obligations. No transmission or storage method is absolutely secure, and we cannot guarantee absolute security. In the event of a personal data incident that may affect you or trigger applicable legal obligations, we will assess the incident and take response, notification and remedial measures as required.
8.2 To the extent permitted by applicable law, in the event of a data breach, or if personal data is subjected to unauthorized use, access, deletion, or alteration, we shall not be liable for any direct or indirect loss, damage, or expense incurred by the data subject, except in cases of our intentional misconduct or gross negligence.
9.1 Our services aren't directed at or intended for children under 18 years of age. We never knowingly collect or process personal data from children under 18. If we discover we've received such data without parental/legal consent, we will take reasonable steps to delete that information. If you believe we have information from or about a child, contact us.
10.1 Depending on your jurisdiction and the applicable law, you may have the following rights with respect to your personal information: (a) access; (b) correction; (c) deletion; (d) restriction of processing; (e) objection to processing, including objection to processing for direct-marketing purposes; (f) data portability; (g) withdrawal of consent at any time, where processing is based on consent; and (h) the right not to be discriminated against for exercising your privacy rights.
10.2 To exercise your rights, please submit a request to us using the contact details in Section 13. We will respond within the timeframe required by applicable law (generally within thirty (30) days). We may request additional information to verify your identity before acting on your request.
10.3 Rights Regarding End-User Data. Where we process End-User Data as a processor on behalf of a Customer, we will cooperate with the applicable Customer to enable the Customer to respond to requests from End Users exercising their rights under applicable law. End Users should direct their privacy requests to the Customer that submitted their personal data.
10.4 If you are located in the European Economic Area, the United Kingdom, or Switzerland, you also have the right to lodge a complaint with your local supervisory authority. If you are located in other jurisdictions with a supervisory authority, you may have a similar right.
11.1 The Platform may contain links to third-party websites, services, or applications. This Policy does not apply to those third parties, and we are not responsible for their privacy practices. We encourage you to review the privacy policies of any third party you interact with.
12.1 We may update this Policy from time to time. For material changes,we will notify you in advance via email or in-app notifications, where feasible.Your continued use of the Services after the changes take effect constitutes acceptance of the updated Policy. The “Last Updated” date at the top of this Policy will indicate when it was last revised.If you do not agree to the updates, you may stop using the service and log out of your account.
13.1 If you have any questions, concerns, or requests regarding this Policy or our privacy practices, please contact us at: TRANSLAND INFORMATION GROUP LIMITED,FLAT/RM A 12/F ZJ 300 LOCKHART ROAD WAN CHAI; email: cloud@innopaas.com; attention: Data Protection Officer / Privacy Team.
13.2 This Policy shall be read in conjunction with the Terms of Use of our website; the applicable laws, limitations of liability, and dispute resolution provisions shall be governed by the relevant provisions or other applicable contractual documents.
