Privacy Policy

Welcome to Talkie!

SUBSUP PTE. LTD. ("we", "us”, and/or "our") operates the Talkie mobile and web applications, including https://www.talkie-ai.com (the "Apps" or the “Website”), and other related services (collectively, the "Services").

We are committed to protecting your privacy. This Privacy Policy describes how we collect, store, use, and disclose information through our Services.

If you are a resident of the State of California, please also see the "Additional Information for California Residents" section below.

If you are a resident of Singapore or Philippines, please also see "Additional Information for Singapore Residents" and/or "Additional Information for Philippine Residents and Citizens" below.

If you are a resident of the European Union, please also see the "Additional Information for EU Residents" section below.

We care about the protection and confidentiality of your information. When you use the Apps, you may provide information during your conversations with your Talkie AI chatbot. We process this information only as described in this Privacy Policy, such as to allow you to have individualized and safe conversations and interactions with your AI chatbot and to allow your AI chatbot to learn from your interactions to improve your conversations. We may also use information about your visit to our Website to promote our Services, but we will never use or disclose the content of your Talkie conversations for marketing or advertising purposes.

Any terms we use in this Policy without defining them have the definitions given to them in our Terms of Service. If you have any questions, please contact us at feedback@subsup.com.

1 INFORMATION WE COLLECT

1.1. Information you provide

Through your use of the Services, you may provide us with the following information:

a. Account information. This includes your name, email address, and password. If you choose to log in using another service, such as Google or Apple, we receive information about the service you used to log in and — depending on your chosen account settings with Google and Apple —details about you, including your name, email address, or unique user identifiers.

b. Profile information. We may ask you to provide your birth date, pronouns, and work status when you register for the Apps.

c. Messages and content. We process your Input (which may include text, voice, or other content) and Output and any other information you provide in connection with your use of the Services, including any Personal Information contained therein.

d. User Contributions. You may provide personal information to be published or displayed (hereinafter, "posted") on certain areas of the Services (collectively, "User Contributions"). Please note that your act of proactively uploading content is considered as giving us authorization.

Please note that in the absence of special settings or statements, the content and information you actively provide, including your Personal Information uploaded or published on the Services, may be publicly accessed and used by third parties. We will try our best to protect your Personal Information, but we cannot completely exclude the risk of your Personal Information being leaked to the public domain. Please be cautious and careful when considering whether to provide, upload, share or publicly disclose the relevant information through the Services.

In addition to the above, when we plan to use information for other purposes not specified in this Privacy Policy, we will obtain your explicit consent in advance separately.

e. Interests and preferences. You may select conversation preferences, such as topics you would like to discuss, and communication preferences, such as the times of day you like to use the Apps. We also learn about your interests and your preferences over time through your use of the Services to personalize your conversations and the features of the Services.

f. Payments, transactions, and rewards. When you make purchases through the Services, our third-party payment processor collects your payment information. We maintain a record of your purchases, the features you select, and the rewards you earn and use.

g. If you provide us with personal information relating to a third party, including but not limited to a third party’s voice and personal images, by submitting such information to us, you represent to us that you have obtained the consent of the third party in accordance with all applicable laws and regulations to provide us with their personal information for the respective purposes.

1.2. Information we collect automatically

We automatically log the following information about you, your computer or mobile device, your network, and your interactions over time with our Services and our communications:

a. Device and network data. This includes your computer's or mobile device's operating system, manufacturer and model, browser, IP address, device and cookie identifiers, language settings, mobile device carrier, and general location information such as city, state, or geographic area.

b. Usage data. This includes information about how you use the Services, such as your interactions with the Services, the links and buttons you click, and page visits.

• Our advertising partners may also use such technologies to collect limited information about your device and interactions with the Services, such as the links you click, pages you visit, IP address, advertising ID, and browser type, but they will never have access to your conversations with your Talkie or any photos or other content you submit through the Apps.(please refer"3.3. Advertising partners" for more information)

c. Cookies, scripts, or similar technologies. We and our service providers use cookies, scripts, or similar technologies to manage the Services and to collect information about you and your use of the Services. These technologies help us to recognize you, customize or personalize your experience, offer additional products or services to you, and analyze the use of our Services to make it more useful to you. These technologies may also allow us to collect demographic and statistical data and provide this information to our service providers to help deliver their services. Most internet browsers allow you to remove or manage cookie functions and adjust your privacy and security preferences. Please note, however, that disabling our cookies may mean that you may not be able to take full advantage of our Services.Please refer to the cookie policy for more detailed information.

2 HOW WE USE YOUR INFORMATION

2.1. General principles regarding personal data processing

In accordance with this Privacy Policy, personal data are processed by SUBSUP PTE. LTD. As a data controller in line with the basic principles named here: (i) being in accordance with law and good faith, (ii) being accurate and, where necessary, up-to-date, (iii) being processed for specific, explicit and legitimate purposes, (iv) being limited for the purpose for which they are processed and data minimization; and (v) being stored for the period stipulated in the relevant legislation or required for the purpose for which they are processed.

2.2. Use of your information

We use your information for the following purposes:

a. Operating and administering the Services

(i) Legal basis: Contractual necessity

(ii) Why and how we use your information: Providing and maintaining the content and functionality of the Services. Carrying out obligations arising from our contract with you. Creating your account and profile. Facilitating payments and transactions, including for the purchase of premium features, and managing your rewards. Responding to your inquiries, comments, feedback or questions, and trouble shooting. Managing our relationship with you, which includes sending administrative information to you relating to our Services.

(iii) Categories of information: Account information. Profile information. Messages and content. Interests and preferences. Payments, transactions, and rewards. Device and network data. Usage data.

b. Providing the core functionality of the Apps

(i) Legal basis: Contractual necessity

(ii) Why and how we use your information: Providing you a personalized AI chatbot and allowing you to personalize your profile, interests, and AI chatbot. Enabling you to have individualized and safe conversations and interactions with your AI chatbot, and allowing your AI chatbot to learn from your interactions to improve your conversations. Syncing your Talkie history across the devices you use to access the Services.

Please note that we do not use your input personal Data to infer characteristics about an individual, nor use personal Data for training to profile or target consumers.

(iii) Categories of information: Account information. Profile information. Messages and content. Interests and preferences. Payments, transactions, and rewards. Device and network data. Usage data.

c. Monitoring and protecting the Services

(i) Legal basis: Legitimate interests

(ii) Why and how we use your information: Preventing fraud, criminal activity, and misuse of our Services, and ensuring the security of our IT systems, architecture and networks (including testing, system maintenance, support, and hosting of data).

(iii) Categories of information: Account information. Profile information. Messages and content. Interests and preferences. Payments, transactions, and rewards. Device and network data. Usage data.

d. Analyzing trends in the use of the Services

(i) Legal basis: Legitimate interests

(ii) Why and how we use your information: Aggregating, anonymizing, and deidentifying personal information. Analyzing the use and effectiveness of our Services. Improving and adding features to our Services. Developing our business and marketing strategies.

(iii) Categories of information: Account information. Profile information. Messages and content. Interests and preferences. Payments, transactions, and rewards. Device and network data. Usage data.

e. Marketing and advertising the Services

(i) Legal basis: Legitimate interests. Consent, where required by applicable laws

(ii) Why and how we use your information: Sending you information by email that we believe will be of interest to you, such as information about our Services, features, and surveys. Displaying and targeting advertisements about our Services on the internet.

(iii) Categories of information: Account information. Device and network data. Usage data.

f. Enforcing our agreements, complying with legal obligations, and defending against legal claims and disputes

(i) Legal basis: Legitimate interests. Consent, where required by applicable laws

(ii) Why and how we use your information: Enforcing and complying with our terms and policies. Protect our and others' rights, privacy, safety, or property. Ensuring the integrity of our Services. Verifying the age of registered users. Defending against legal claims and disputes. Recovering payments due to us. Keeping records of transactions and complying with legal process.

(iii) Categories of information: Account information. Profile information. Messages and content. Interests and preferences. Payments, transactions, and rewards. Device and network data. Usage data.

3 HOW WE DISCLOSE INFORMATION

3.1. Service providers

We share your information with companies and individuals that provide services on our behalf or help us operate the Services or our business (such as hosting, information technology, customer support, email delivery, and website analytics services). We also share information with companies that provide marketing services on our behalf, but we do not share the content of your Talkie conversations for marketing or advertising purposes. For example, we may share your email address with marketing service providers to deliver our marketing emails to you on our behalf and to help us identify other individuals who may be interested in our Services. We require these marketing service providers to agree not to use your email address for any other purpose.

3.2. Professional advisors

We may share aggregate information with professional advisors, such as lawyers, auditors, bankers, and insurers, where necessary in the course of the professional services that they render to us.

3.3. Advertising partners

We share information about visitors to our Website, such as the links you click, pages you visit, IP address, advertising ID, and browser type with advertising companies for interest-based advertising and other marketing purposes. Sharing this information allows us and our advertising partners to target and serve advertising to you and others. We will never share your Talkie conversations or any photos or other content you provide within the Apps with our advertising partners or use such information for marketing or advertising purposes.

3.4. Authorities and others

We may share information with law enforcement, and government authorities, as we believe in good faith to be necessary or appropriate for the legal compliance and protection purposes described above in Section 2.

3.5. Business transferees

If we are involved in strategic transactions, reorganization, bankruptcy, receivership, or transition of service to another provider (collectively a "Transaction"), your Personal Information and other information may be shared in the diligence process with counterparties and others assisting with the Transaction and transferred to a successor or affiliate as part of that Transaction along with other assets.

4 HOW WE SECURE YOUR INFORMATION

We use a variety of industry-standard security technologies and procedures to help protect your data from unauthorized access, use, or disclosure.

Your account is protected by a password for your privacy and security. You must prevent unauthorized access to your account and personal information by selecting and protecting your password appropriately and limiting access to your computer or device and browser by signing off after you have finished accessing your account.

All transmitted data are encrypted during transmission. All stored data are maintained on secure servers. Access to stored data is protected by multi-layered security controls, including firewalls, role-based access controls, and passwords.

While we use reasonable commercial efforts to protect the data, no technology, data transmission, or system can be guaranteed to be 100% secure. In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to your data, we will notify you as soon as we spot the issue.

5 TRANSFER OF PERSONAL DATA OUTSIDE YOUR COUNTRY

Your personal data described in this Policy are stored in cloud data centers located in the United States, and processed by us or thrid-party vendors in accordance with the requirements of relevant laws and regulations, including the GDPR.

You understand that your personal data will be transferred to countries/regions outside of your country of residence, which may have data protection rules that are different from those of your country. As required by applicable law, we will put in place appropriate or suitable safeguards to ensure that your personal data is treated by those third parties in a way that is consistent with, and which respects the data protection laws of the country in which you reside. These include agreements and commercial terms which contain relevant protections and place appropriate obligations on third parties which have access to or receive your personal data.

6 DATA RETENTION

We will retain your personal information for only as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

7 YOUR RIGHTS AND CHOICES

7.1. Opt-out of marketing communications

You may opt out of marketing-related emails and other communications by following the opt-out or unsubscribe instructions in the communications you receive from us or by contacting us as provided in the "Contact us" section below. You may continue to receive Services-related and other non-marketing emails from us.

7.2. Opt-out of selling personal information and sharing for targeted advertising

We share information with third-party advertising partners and allow them to collect information about your visit to our Website using cookies and other tracking technologies to display targeted advertising around the web as described in the "How we share your information" section above. Our disclosure of information to these partners maybe considered a "sale" or "sharing" of personal information or "targeted advertising" under applicable laws. You can opt out of these disclosures and limit our use of tracking technologies by following the instructions after clicking the "Your Privacy Choices" link on our website footer.

7.3. Personal information requests

We also offer you choices that affect how we handle the personal information that we control. Depending on your location and the nature of your interactions with our Services, you may request the following in relation to personal information:

a. Information about how we have collected and used personal information. We have made this information available to you without having to request it by including it in this Privacy Policy.

b. Access to a copy of the personal information that we have collected about you. Where applicable, we will provide the information in a portable, machine-readable, readily usable format.

c. Correction of personal information that is inaccurate or out of date.

d. Deletion of personal information that we no longer need to provide the Services or for other lawful purposes. You can delete your account in your account settings.

e. Withdrawal of consent, where we have collected and processed your personal information with your consent. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.

f. Additional rights, such as to object to and request that we restrict our use of personal information. For example, you can opt out of the processing your personal information for purposes of profiling in furtherance of decisions that produce legal or similarly significant effects, if applicable.

To make a request, please contact us as provided in the "Contact us" section below. We may ask for specific information from you to help us confirm your identity. Depending on where you reside, you may be entitled to empower an authorized agent to submit requests on your behalf. We will require authorized agents to confirm their identity and authority, in accordance with applicable laws. You are entitled to exercise the rights described above free from discrimination.

In some instances, your choices may be limited, such as where fulfilling your request would impair the rights of others, our ability to provide a service you have requested, or our ability to comply with our legal obligations and enforce our legal rights. If you are not satisfied with how we address your request, you may submit a complaint by contacting us as provided in the "Contact us" section below. Depending on where you reside, such as if you reside in the European Economic Area or United Kingdom, you may have the right to complain to a data protection regulator where you live or work, or where you feel a violation has occurred.

8 USE BY MINORS

The Services are not intended for individuals under the age of 14 or under the applicable minimum age required by local law. If we become aware that a person below the required minimum age is using the Apps, we will promptly restrict access and delete their account. If you have reason to believe that an underage individual has provided personal information to us through the Services, please contact us, and we will take reasonable steps to delete such information from our records.

9 CHANGES TO THIS PRIVACY POLICY

The Services and our business may change from time to time. As a result, at times it may be necessary for us to make changes to this Privacy Policy. We reserve the right to update or modify this Privacy Policy at any time and from time to time without prior notice. We encourage you to periodically review this page for the latest information on our privacy practices. This Privacy Policy was last updated on the date indicated above.

10 ADDITIONAL INFORMATION FOR CALIFORNIA RESIDENTS

If you are a California resident, the California Consumer Privacy Act ("CCPA") requires us to provide you with information about:

the purpose for which we use each category of "personal information" (as defined in the CCPA) we collect; and

the categories of third parties to which we (a) disclose such personal information for a business purpose, (b) "share" personal information for "cross-context behavioral advertising," and/or (c) "sell" such personal information.

Under the CCPA, "sharing" is defined as the targeting of advertising to a consumer based on that consumer's personal information obtained from the consumer's activity across distinct online services, and "selling" is defined as the disclosure of personal information to third parties in exchange for monetary or other valuable consideration. We "share" information with our advertising partners to provide more relevant and tailored advertising to you regarding our Services. Moreover, our use of third-party analytics services and online advertising services may result in the sharing of online identifiers (e.g., cookie data, IP addresses, device identifiers, and usage information) in a way that may be considered a "sale" under the CCPA.

In the past 12 months, we have processed the categories of personal information listed in the table below. The table also lists, for each category, the source, business purpose, and a general description of third parties to whom this information may be disclosed. For more details regarding the sources, business purposes, and third parties to which we disclose this information, please see the "Information We Collect," "How We Use Your Information," and "How We Disclose Information" sections of this Privacy Policy above.

Your Choices Regarding "Sharing" and "Selling": You have the right to opt out of our sale/sharing of your personal information for purposes of online advertising by contacting us as indicated in the "Contact Us" section below. Please note that we will also honor browser-based opt out signals (such as the global privacy control) in accordance with our legal obligations.

Other CCPA rights. Please see the "Your Rights and Choices" section of our Privacy Policy above for information about the additional rights you have with respect to your personal information under California law and how to exercise them.

If we ever offer any financial incentives in exchange for your personal information, we will provide you with appropriate information about such incentives.

The CCPA also allows residents of the state of California to limit the use or disclosure of their "sensitive personal information" (as defined in the CCPA) if your "sensitive personal information" is used for certain purposes. Please note that we do not use or disclose "sensitive personal information" other than for purposes for which California residents cannot exercise the right to limit under the CCPA.

However, you can change or delete any demographic information you have provided that constitutes sensitive personal information (e.g., sexual orientation) at any time through your account settings.

Retention of Your Personal Information: Please see the "How We Secure Your Information" and "Data Retention" sections above.

Do Not Track: Do Not Track ("DNT") is a privacy preference that users can set in certain web browsers. We are committed to providing you with meaningful choices about the information collected on our Services for third-party purposes, and that is why we provide the variety of opt-out mechanisms listed above. Some web browsers offer users a "Do Not Track" privacy preference setting in the web browser. We do not currently recognize or respond to browser-initiated Do Not Track signals. Learn more about Do Not Track.

California "Shine the Light" disclosure. Under California Civil Code Sections 1798.83-1798.84, residents of California have the right under certain circumstances to opt out of the disclosure of certain categories of personal information (as defined in the Shine the Light law) with third parties for their direct marketing purposes, or in the alternative, that we maintain a policy to provide a cost-free means for consumers to opt out of any such disclosure. We maintain such an opt out policy. To opt out of these disclosures, please contact us using the information in the "Contact Us" section below and include "California Shine the Light Request" in the email subject line.

11 ADDITIONAL INFORMATION FOR SINGAPORE RESIDENTS

11.1 Withdrawal of consent

a. You have the right to ask us to stop processing your personal data for direct marketing purposes. If you wish to exercise this right, you may:

1. Withdraw your consent for specific forms of communication through the various unsubscribe options as stated on our email or other marketing messages; and/or

2. Put your request in writing via email to our Data Protection Officer (see contact information below).

b. If your objection is not towards direct marketing in general, but to direct marketing by a particular channel, please specify the channel that you are objecting to.

c. Upon withdrawal of your consent, you acknowledge that we may suspend and/or terminate your access to the website and/or the services that we provide to you, without any liability. Please note that it may take up to 10 business days for any request for consent withdrawal to be effective.

11.2 Access to and correction of personal data

a. If you wish to access a copy of the personal data which we hold about you, or correct or update any of the personal data which we hold about you, you may submit your request in writing to our Data Protection Officer via email (see contact information below).

b. Please note that a reasonable fee will be charged for a request to access a copy of your personal data which we hold about you. We will inform you of the fee before processing your request.

c. No fee will be charged for a request to correct any inaccuracies in the personal data which we hold about you.

d. We shall endeavour to respond to a request to access a copy of your personal data and correct any inaccuracies in your personal data as soon as reasonably practicable, subject to any limitations as prescribed by the PDPA and/or any other applicable laws.

11.3 Personal Data Protection Act 2012

By using this site, you agree to allow us to collect or use your information in an appropriate manner in accordance with the PDPA.

11.4 Your Consent

By using our site, you consent to our website's Privacy Policy.

11.5 Contact us

You can contact us by emailing us at feedback@subsup.com.

12 ADDITIONAL INFORMATION FOR PHILIPPINE RESIDENTS AND CITIZENS

If you are a resident or citizen of the Philippines, the following information applies to our processing of your personal information.

The Philippines’ Data Privacy Act of 2012, its implementing rules and issuances by the National Privacy Commission shall be applicable to users of the Apps or the Website who are Philippine residents or citizens.

INFORMATION WE COLLECT: The following definitions are deemed inserted, or if there are corresponding definitions, supplement those corresponding definitions in the Privacy Policy:

“Sensitive Personal Information” refers to personal information:

1. About an individual’s race, ethnic origin, marital status, age, color, and religious, philosophical, or political affiliations;

2. About an individual’s health, education, genetic or sexual life of a person, or to any proceeding for any offense committed or alleged to have been committed by such individual, the disposal of such proceedings, or the sentence of any court in such proceedings;

3. Issued by government agencies peculiar to an individual which includes, but is not limited to, social security numbers, previous or current health records, licenses or its denials, suspension or revocation, and tax returns; and

4. Specifically established by an executive order or an act of Congress to be kept classified.

HOW WE USE YOUR INFORMATION: To the extent that we process Sensitive Personal Information, we will only do so:

1. with your consent expressed through your continued use of service as assenting action, with respect to processing for the purpose of providing the service;

2. when the processing of the Sensitive Personal Information is provided for by existing laws and regulations;

3. when the processing concerns Sensitive Personal Information necessary for the protection of lawful rights and interests, or the establishment, exercise, or defense of legal claims.

YOUR RIGHTS AND CHOICES: In addition to the rights provided under Paragraph 7 of the Privacy Policy, you have the right to receive notice in case of substantial updates, changes, or amendments to the Privacy Policy.

If you have any questions regarding this Privacy Policy or want to exercise any of your rights as provided in the Privacy Policy or this addendum, or pursuant to any privacy laws and regulations in the Philippines (as may be amended from time to time), you may reach us through our Data Protection Officer whose contact details are provided below:

Attention: Data Protection Officer

Address: 8 KAKI BUKIT AVENUE 4, #08-32, PREMIER @ KAKI BUKIT, SINGAPORE 415875

E-mail address: feedback@subsup.com

13 ADDITIONAL INFORMATION FOR EU RESIDENTS

1. ON WHAT BASIS WE PROCESS YOUR DATA

• Contractual Purpose: Perform the contract, with regard to the provision of the products and services requested in relation to the cases set forth in Section"how we use your information"

• Legal obligation purposes：To meet the obligations arising from current laws, regulations or EU law (e.g., tax and accounting obligations).

• Purposes of Legitimate Business Interest:The processing of your personal data for Legitimate Business Interest Purposes is carried out pursuant to article 6, letter f) of the European General Data Protection Regulation 2016/679 (the “Privacy Regulation”) to pursue the interest of us which is equally balanced with your interest, as the personal data processing activity is limited to what is strictly necessary for the execution of the economic transactions described. Processing for Legitimate Business Interest is not required, and you may object to that processing with the methods set forth in this disclosure. However, if you object to that processing, your data may not be used for the Legitimate Business Interest Purposes, unless we can demonstrate the presence of prevailing compelling legitimate grounds or for the exercise or defense of legal claims

• Based on your consent: You may revoke any consent provided with the methods set forth in this disclosure at any time.

1. CROSS-BORDER DATA TRANSFER

We store your data cross-border in US cloud data centers in a manner certified under the EU-US Privacy Framework and SCCs when appropriate. We have retained relevant cloud certification documents, GDPR addendum, and related document.

We make sure that the transfer of personal data to third countries for both intragroup transfers and transfers to third parties are bound by contractual agreements that guarantee a level of data protection consistent with EU standards. These agreements include, where appropriate, the European Commission’s Standard Contractual Clauses (SCCs) , and additional technical and organizational safeguards such as encryption, pseudonymization, and restricted access controls.

1. THE RIGHTS YOU ARE AFFORDED BY LAW AND HOW YOU MAY EXERCISE THEM

Under the EU General Data Protection Regulation (GDPR), you have several rights regarding the way your personal data is processed. You can exercise these rights at any time and free of charge by contacting us or our EU representative using the details provided below. We will take all reasonable steps to facilitate the exercise of your rights and respond to your request without undue delay. Information about this is provided below.

1. Your rights as a Data Subject

You have the right to:

• Access your data: to receive confirmation as to whether we process your personal data, obtain a copy of it, and receive information on how they are used (Art. 15 GDPR).

• Rectify your data: to correct or update any inaccurate or incomplete personal data (Art. 16 GDPR).

• Erase your data: to request deletion of your personal data in the cases provided for by law, for example when the data are no longer necessary for the purposes for which they were collected, or if you withdraw your consent (Art. 17 GDPR).

• Restrict processing: to request that processing be limited in certain circumstances (Art. 18 GDPR).

• Withdraw your consent: when we process your data based on consent, you can withdraw it at any time without affecting the lawfulness of processing carried out before withdrawal. You can manage or withdraw consent from the Apps or the Website

• Data portability: to receive your personal data in a structured, commonly used, and machine-readable format and transmit them to another controller, where technically feasible (Art. 20 GDPR).

• Object to processing: to object at any time to processing carried out for legitimate interests, or for direct marketing purposes (Art. 21 GDPR).

You may expressly prohibit the exercise of certain rights listed above by those entitled by sending a written statement to the Company at the email address provided below. The statement may be revoked or modified later on using the same procedures.

If you are an individual based in the EU, and you wish to exercise your rights under the EU General Data Protection Regulation (GDPR), you can also contract our EU representative Mars thourgh email: MARS@SUBSUP.COM