Data Protection Policy

1. Purpose

AI Super Private Limited ("AI Super", "we", "us", or "our") is committed to protecting personal data in accordance with the Personal Data Protection Act 2012 ("PDPA") and other applicable laws. This Policy explains how we collect, use, disclose, process, and protect personal data in connection with our services, including AI-powered chatbot systems, messaging automation, and integrations.

2. Role as Data Controller and Data Intermediary

Depending on the context:

• Data Controller: We determine the purposes and means of processing personal data (e.g. website visitors, direct customers)
• Data Intermediary (Processor): We process personal data on behalf of customers

Where we act as a data intermediary:

• We process personal data only in accordance with documented customer instructions
• We do not use such data for our own purposes
• Customers remain responsible for ensuring compliance with applicable data protection laws, including obtaining valid consent

3. Personal Data We Collect

We may collect the following categories of personal data:

A. Customer and Business Information

• Name, company name, job title
• Email address, phone number, WhatsApp number

B. Technical and Usage Data

• IP address, device and browser information
• System logs, timestamps, API usage

C. Financial Data

• Billing details, invoices, transaction records

D. Communications and Support Data

• Messages, chatbot conversations, uploaded files
• Information provided during onboarding, support, or consultations

E. Customer-Controlled Data

• Personal data processed through our platform under customer instructions (e.g. chatbot users, leads, bookings)

4. How We Collect Personal Data

We collect personal data when you:

• Use our website, applications, or chatbot services
• Sign up for accounts, demos, or integrations
• Communicate with us via email, phone, or messaging platforms
• Authorize third-party integrations
• Interact with our services as an end-user of our customers

5. Purposes of Processing

We may process personal data for purposes including:

• Providing, operating, and improving our services
• Delivering AI chatbot responses and automation workflows
• Setting up accounts and integrations
• Customer support and communications
• Billing, invoicing, and contract administration
• Security monitoring, fraud prevention, and misuse detection
• Legal, regulatory, and audit compliance

6. AI and Automated Processing

We use artificial intelligence technologies, including services provided by OpenAI, to process, analyze, and respond to communications.

Such processing may include:

• Understanding message content and intent
• Generating automated responses
• Analyzing interaction patterns to improve system performance

Automated processing may influence how communications are handled without human intervention.

We do not use personal data to train general AI models unless explicitly permitted.

7. Third-Party Platforms and Integrations

Our services integrate with third-party platforms, including:

• Meta Platforms (WhatsApp Cloud API)
• Google (Google Calendar, Google Sheets)
• Cloud and infrastructure providers (including hosting in Singapore via Contabo)

Personal data processed through such platforms is subject to their respective privacy policies.

We do not control and are not responsible for:

• Platform availability or outages
• Message delivery failures
• Independent data processing practices of such platforms

8. Disclosure of Personal Data

We may disclose personal data to:

• Employees, contractors, and affiliates
• Cloud, hosting, analytics, and technology providers
• Messaging and communication platforms
• Payment processors and financial institutions
• Professional advisers (legal counsel, auditors, insurers) where necessary for compliance or legal claims
• Regulators, courts, and law enforcement where required

We do not sell personal data.

9. Customer Responsibilities

Customers using our services agree to:

• Obtain valid consent from individuals before processing personal data
• Comply with applicable data protection and privacy laws
• Ensure lawful use of messaging and automation features
• Avoid sending unsolicited or unauthorized communications

We are not responsible for misuse of our platform by customers.

10. Acceptable Use (Messaging and Anti-Spam)

Customers must not use our services to:

• Send unsolicited bulk messages or spam
• Violate applicable laws or platform policies
• Engage in fraudulent, abusive, or deceptive activities

We reserve the right to suspend or terminate services for violations.

11. Consent and Withdrawal of Consent

Where required, we obtain consent before collecting or using personal data. You may withdraw consent by contacting us. Withdrawal may affect our ability to provide services.

12. Access and Correction

You may request:

• Access to personal data we hold about you
• Correction of inaccurate or incomplete data

We may verify identity and charge a reasonable administrative fee where permitted.

13. Data Retention

Personal data is retained only as long as necessary for the purposes it was collected:

• Account data: duration of service + reasonable period after termination
• System logs: for security and operational purposes
• Financial records: in accordance with legal requirements

Data is deleted, anonymized, or securely disposed when no longer required.

14. Data Protection and Security

We implement reasonable administrative, technical, and physical safeguards, including:

• Access controls and authentication
• Encryption where appropriate
• Secure hosting infrastructure
• Monitoring and logging systems

However, no system is completely secure.

15. Data Breach Notification

In the event of a data breach, we will assess the incident and, where required, notify affected individuals and relevant authorities in accordance with the PDPA.

16. Overseas Transfers

Personal data may be transferred outside Singapore, including to service providers such as OpenAI and other infrastructure providers. We take reasonable steps to ensure comparable protection standards.

17. Cookies and Tracking Technologies

We use cookies and similar technologies for:

• Website functionality
• Analytics and performance
• User experience improvements

Users may manage cookies through browser settings.

18. Do Not Call (DNC) Compliance

Where we send or facilitate marketing communications, we comply with Singapore's Do Not Call provisions under the PDPA.

19. Children and Sensitive Data

Our services are not intended for children under 13.

Customers are responsible for implementing safeguards when processing sensitive personal data.

20. Limitation of Responsibility

We are not responsible for:

• Actions or policies of third-party platforms
• Service disruptions beyond our control
• Customer misuse of the platform
• Data processed under customer instructions

21. Contact Information

For data protection matters:

AI Super Private Limited

Email: hello@asi.sg

Phone: +65 8085 8100

Address: 60 Paya Lebar Road, #11-22, Paya Lebar Square, Singapore 409051

22. Updates to This Policy

We may update this Policy from time to time. The latest version will be published with the updated effective date.