# NIYEO PRIVACY POLICY

Updated: January 20, 2025

Apance Pte Ltd ("Niyeo," "our," "we," or "us") provides the services described below to you as "Services" or "Niyeo Services"

At Niyeo, we prioritize your privacy. Our Privacy Policy outlines our data practices and the information we process to provide our Services.

This Privacy Policy explains what information we collect, how it affects you, and the measures we take to protect your privacy. We design our Services with privacy in mind, ensuring that we don't store delivered messages and giving you control over your communications.

This Privacy Policy applies to all Niyeo Services unless otherwise specified. Some of our products or features may have additional privacy policies that supplement this main policy.

Please also read Niyeo's Terms of Service ("Terms"), which describe the terms under which you use and we provide our Services.

## Information we collect

The information we collect is essential for providing our Services. To create a Niyeo account, you must provide an email address. This is necessary for account creation and authentication, and without it, we cannot offer our Services to you.

For security purposes, we also collect your IP address during account creation and when you use our Services. This helps us protect your account and maintain the integrity of our platform.

Our Services may include optional features that require additional information. We will notify you if such information is needed for a specific feature. You can choose whether to provide this information, but certain features may not be available if you decline.

If you contact our customer support, you may provide additional information to help us understand and resolve your query. This may include details about your use of our Services or any issues you're experiencing. We use this information solely for the purpose of assisting you and improving our Services.

We take measures to verify your account when you sign up or log in, such as sending a verification code to your email address. We collect limited information about your usage of Niyeo Services. This includes session data, such as when you access our Services and for how long, as well as your IP address. We also gather basic interaction data, such as which features you use. This information helps us improve our Services and ensure their proper functioning.

Niyeo uses standard, government-approved encryption methods to protect your data and communications within our Services. This ensures that only you and the intended recipients can access your messages and information. When you use Niyeo Services, we collect basic device and connection information. This includes device type and model, operating system, app version, and network type (WiFi or cellular). This information is necessary for the proper functioning of our Services across different devices and networks.

Niyeo respects your privacy choices and collects information about your app settings and preferences. You have control over various privacy settings, such as who can see your profile information or when you were last active.

To ensure the security of your account, Niyeo creates and stores authentication codes. These are used to verify your identity and grant appropriate access to your account and our Services.

## Third Party Services

Users of Niyeo are solely responsible for deciding to share personal information with third parties through our platform. Any legal relationship regarding such shared information exists exclusively between the user and the third party. The third party bears sole liability for providing privacy protections for shared information, and Niyeo is not responsible for their practices. Users must exercise discretion in determining what information to share with any third party. Niyeo cannot control or be held liable for how third parties use or protect information shared through our platform. We urge users to review third-party privacy policies before sharing sensitive data.


## Legal Basis for Processing Your information

Niyeo processes your information in compliance with applicable data protection laws, including but not limited to the European Union's General Data Protection Regulation (GDPR), the United States' federal and state privacy laws, the United Kingdom's Data Protection Act, Singapore's Personal Data Protection Act, Japan's Act on the Protection of Personal Information, and other relevant regional and international data protection regulations. We use various legal bases for processing, each tied to specific purposes and operations described in this Privacy Policy.

We outline our processing purposes, operations, and the categories of information processed for each legal basis. Your rights may vary depending on the legal basis used and the applicable laws in your jurisdiction. However, we strive to provide all users with fundamental rights, including the right to access, rectify, and erase your information, subject to legal requirements and limitations.

Any information processed for communication purposes, such as email addresses and message timestamps, is handled in accordance with applicable laws and regulations, including EU Directive 2002/58/EC where relevant, and similar provisions in other jurisdictions.

## Your Consent

We process information for the purposes described below when you have given us your consent to enable particular product features. The categories of information used, why it's processed, and how it's processed are set out below:

We may also collect and process user-generated content that you choose to share within our Services.

When we process your information based on your consent, you have the right to withdraw your consent at any time without affecting the lawfulness of processing based on such consent before the consent is withdrawn. To exercise your rights, you can visit your account settings to disable features that use this information; remove your information or remove your account from our systems;

## Compliance With Legal Obligations

We process information to comply with legal obligations in all jurisdictions where Niyeo operates or from which users access our Services. This includes, but is not limited to, the European Union, Ireland, the United States, Singapore, and Japan. We may access, preserve, or disclose information in response to valid legal requests from authorized entities such as regulators or law enforcement agencies.

The specific information processed depends on the applicable laws and the nature of the legal obligation. It may encompass any data we hold about you, including account details, user content, usage data, and device information. We adhere to laws relating to civil and criminal matters, consumer protection, corporate governance, taxation, data protection, and information security across these jurisdictions.

Our compliance may involve assisting in investigations, reporting to authorities, implementing security measures, or disclosing information for court proceedings. As new laws are enacted or new obligations become binding in any relevant jurisdiction, we may update our practices accordingly. We strive to fulfill all legal requirements while maintaining our commitment to user privacy and data protection principles.

## Protection of Vital Interests of Persons

Niyeo processes information to protect your vital interests or those of another person. The specific information used depends on the circumstances but may include any data we hold about you. We employ both automated processing techniques and manual review to ensure the safety and security of our users.

In cases where someone's vital interests require protection, such as emergencies, we may share information with law enforcement and other relevant authorities. These vital interests encompass the protection of life, physical and mental health, wellbeing, and personal integrity of you or others.

Our commitment to protecting vital interests involves combating harmful conduct and promoting safety, integrity, and security within Niyeo Services. We investigate reports of harmful behavior and take appropriate action, which may include suspending or terminating user accounts or sharing information with relevant authorities when there is a risk of imminent harm or a threat to someone's safety.

Niyeo also employs advanced technologies to detect and prevent the spread of child sexual abuse material (CSAM). We compare profile pictures, community content, and reported images against databases of known CSAM using hash-matching techniques. Additionally, we utilize a combination of automated processing and human review to identify previously unknown CSAM. If we detect apparent CSAM, we report it to the appropriate authorities and take necessary actions to protect potential victims and prevent further distribution of such material.

By using Niyeo Services, you acknowledge and agree that we may process your information for these vital interest protection purposes, always in compliance with applicable laws and regulations.

## Legitimate Interests

Niyeo relies on legitimate interests as a lawful basis for processing personal information when such interests are not overridden by your rights and freedoms. These legitimate interests include:

Account Management: Niyeo processes information to assist users in creating and managing their accounts, including verifying accounts, recording user preferences, and facilitating account deletion upon request. This processing is necessary to provide a secure and personalized service.

Service Operation: To operate and maintain the Niyeo Services, we analyze log information, collect diagnostic data, and monitor service performance. This allows us to ensure service quality, reliability, and efficiency.

Search Functionality: Niyeo processes user queries and related data to enable effective search capabilities within the platform. This processing is essential for users to discover relevant information and connect with appropriate resources.

Chat Features: To facilitate communication between users, Niyeo processes message content and metadata. This includes storing encrypted messages temporarily for delivery purposes and managing user status indicators.

Q&A System: Niyeo processes user-submitted questions and answers, as well as related engagement data, to operate and improve the Q&A feature. This processing enables users to share knowledge and receive accurate responses.

Safety and Security: To protect the integrity of Niyeo Services, we process information to detect and prevent fraudulent activities, policy violations, and other potential threats. This may include automated and manual review processes to identify suspicious behavior.

Service Improvement: Niyeo analyzes usage patterns, user feedback, and performance metrics to develop new features and enhance existing ones. This processing is crucial for continually improving the user experience and adapting to user needs.

Customer Support: To provide effective assistance, Niyeo processes support requests, user communications, and related data. This enables us to resolve issues efficiently and maintain user satisfaction.

Legal Compliance: Niyeo may process and share information to comply with legal obligations, respond to valid legal requests, or protect our rights in the context of litigation or disputes.

By using Niyeo Services, you acknowledge and consent to the processing of your information for these legitimate interests, always in compliance with applicable laws and regulations.


## How To Exercise Your Rights

Under applicable data protection laws, you have rights regarding your information. These include accessing, rectifying, porting, and erasing your data, as well as restricting and objecting to certain processing. You can object to our processing of your information for direct marketing or when we pursue legitimate interests. We'll consider various factors when assessing objections and will uphold them unless there are compelling legitimate grounds or legal reasons for the processing.

To exercise your rights, use the appropriate forms or features within Niyeo Services. You can access or port your information, rectify, update, and delete your data directly in the app. If we process your information based on consent, you can withdraw it anytime. You have the right to lodge complaints with relevant data protection authorities.

## Retention of Your Information

We retain information as long as necessary for the purposes outlined in this Privacy Policy, including providing our Services, complying with legal obligations, and protecting our rights. Retention periods vary based on the type of information and its purpose. We may keep certain data for legal reasons even after account deletion.

## Deleting Your Information

When you delete your Niyeo account, we remove most of your information from our servers. However, some data may be retained for technical, legal, or operational reasons. The deletion process typically takes up to 90 days. Certain anonymized or disassociated data may be kept for analytical or security purposes.

## Managing Your Information

You can manage your information through Niyeo's in-app settings. This includes changing your profile details, managing contacts and groups, and using privacy features. To delete your account, use the in-app deletion feature. Remember that account deletion doesn't affect information others have about you or content in groups you created.

## Working With Authorities, Advisors And Industry Partners

We may share your information with regulators, law enforcement, government agencies, industry partners, and advisors when necessary to comply with laws, detect and prevent illegal activities, or protect rights and safety. The extent of information shared depends on the specific circumstances and legal requirements.

## Transferring Information Globally

Niyeo transfers information globally to provide its services. This includes transfers within our company group and to external service providers. We use various legal mechanisms to protect your information during these transfers, including adequacy decisions, data protection frameworks, and standard contractual clauses approved by relevant authorities.