1. About This Policy

1.1  Antelligence Technologies Pte. Ltd. (“Antsomi,” “we,” “us” or “our”) is a Singapore-incorporated company that provides a business-to-business SaaS customer data and marketing platform (the “Services”) enabling our business customers (“Customers”) to engage and understand the end users of their own websites, applications and marketing channels (“End Users”).

1.2  This Privacy Policy explains how Antsomi collects, uses, discloses, stores and protects personal data in connection with our website, the Services, and our business operations across Singapore, Vietnam, Malaysia, the Philippines, Thailand, Indonesia and Australia, and describes the rights available to individuals under applicable regional data protection laws (collectively, “APAC Data Protection Laws”), including Singapore’s Personal Data Protection Act 2012 (“PDPA”), Vietnam’s Law on Personal Data Protection and Decree 13/2023/NĐ-CP, Malaysia’s Personal Data Protection Act 2010, the Philippines’ Data Privacy Act of 2012, Thailand’s Personal Data Protection Act B.E. 2562, Indonesia’s Law No. 27 of 2022 on Personal Data Protection, and Australia’s Privacy Act 1988 (Cth) and Australian Privacy Principles (“APPs”).

1.3  This Policy applies to website visitors, prospective and existing Customers, job applicants, employees and contractors, and End Users whose data we process on a Customer’s behalf. It does not apply to third parties that Antsomi does not own, control, employ or manage.

1.4  Where Antsomi collects personal data directly from an individual (e.g. website visitors, job applicants, employees), Antsomi acts as the party determining the purpose and means of processing (“Controller”). Where Antsomi processes End User data on behalf of a Customer, Antsomi acts solely on the Customer’s instructions (“Processor”), and the Customer remains responsible for its own privacy notices and for obtaining any consents required from its End Users.

2. Information We Collect

2.1  As Controller

We collect personal data that individuals provide directly to us, including through the following channels, limited to the fields reasonably necessary for each purpose:

• Website forms: first and last name, business email, phone number and country, when requesting a demo, contacting us, or registering for a webinar;
• Account creation: name, company name, work email and password, when signing up for an account or a free-tier trial;
• Careers: name, contact details, resume, work history and compensation expectations, when applying for a role;
• Partnerships: name, business email, company and partnership type, when applying to our partner ecosystem.

We may also collect personal data about employees, contractors and interns in the course of employment or engagement, including identification, payroll and performance-related information, as set out in our internal Employee Privacy Notice.

2.2  As Processor

Our Customers configure the Services to collect End User data such as name, email address, phone number and behavioral or device data (e.g. app/website interactions, device identifiers, IP address, location, and engagement with campaigns), depending on how each Customer implements our SDKs, APIs or tracking scripts. Antsomi processes this data solely under the Customer’s instructions and has no direct relationship with End Users. End Users should direct data requests to the relevant Customer in the first instance; if a Customer does not respond within a reasonable period, End Users may contact Antsomi at [email protected].

2.3  Automatically Collected Information

We automatically collect technical data such as IP address, browser and device type, operating system, referring pages and clickstream data via server logs and cookies, to secure, operate and improve the Services and our website.

3. How We Use Personal Data

We process personal data only for purposes that are lawful under APAC Data Protection Laws, including one or more of the following bases: performance of a contract with you; your consent (e.g. cookies, marketing communications); our legitimate business interests (e.g. improving and securing the Services, fraud prevention, internal analytics); and compliance with legal or regulatory obligations. Typical purposes include:

• providing, maintaining, securing and improving the Services and website;
• managing Customer accounts, billing and support;
• sending product updates, marketing communications and event invitations, where you have consented or as otherwise permitted by law;
• processing job applications and managing employment relationships;
• complying with applicable legal, tax, accounting and regulatory obligations.

Where consent is the applicable legal basis, you may withdraw it at any time with effect for future processing, by adjusting your cookie settings or contacting [email protected]. Withdrawal does not affect the lawfulness of processing carried out before withdrawal.

4. Cookies and Similar Technologies

We use cookies and similar tracking technologies to operate our website, remember preferences, analyze site usage and, where consented to, deliver relevant marketing. You can manage or withdraw cookie consent at any time through our cookie settings tool or your browser settings; disabling certain cookies may limit site functionality. Further detail is available in our separate Cookie Policy.

5. Sharing and Disclosure of Information

We do not sell personal data. We may share personal data with:

• Service providers: service providers and sub-processors engaged to host, store, secure or support the Services (e.g. cloud infrastructure, email delivery, customer support tools), under written confidentiality and data protection obligations; a current sub-processor list is available at antsomi.com;
• Group affiliates: Antsomi group affiliates, for the purposes described in this Policy;
• Advisers: professional advisers such as auditors, lawyers and insurers, where necessary for their services or to comply with legal obligations;
• Customers and the public: in aggregated or anonymized form, with Customers or the public for analytics, benchmarking or thought-leadership purposes;
• Legal and regulatory authorities: regulators, courts or law enforcement, where required by applicable law or to protect our rights, property or safety, or that of others;
• Business transfers: a successor entity, in connection with a merger, acquisition, financing or sale of business assets, subject to equivalent privacy protections.

6. Cross-Border Data Transfers

As a regional SaaS provider, Antsomi may transfer personal data between Singapore, Vietnam, Malaysia, the Philippines, Thailand, Indonesia, Australia and other jurisdictions in which we or our sub-processors operate. Where APAC Data Protection Laws require it, such transfers are made subject to appropriate safeguards, which may include standard contractual clauses, binding intra-group data transfer agreements, contractual accountability obligations consistent with the ASEAN Model Contractual Clauses, or your consent. You may contact [email protected] for further information on the safeguards applicable to a specific transfer.

7. Data Security

We maintain administrative, technical and physical safeguards aligned with ISO/IEC 27001 and SOC 2 principles, including encryption in transit, access controls and regular security reviews, designed to protect personal data against unauthorized access, use, alteration or disclosure. No method of transmission or storage is completely secure; if we become aware of a data breach affecting your personal data, we will notify affected individuals and the relevant regulator as required by applicable law.

8. Data Retention

We retain personal data only for as long as necessary to fulfil the purposes described in this Policy, including to meet legal, accounting, tax or regulatory retention requirements, resolve disputes, and enforce our agreements. Retention periods vary by data category and are set out in our internal data retention schedule; on request, we will provide relevant retention information to Customers and individuals exercising their rights under Section 9.

9. Your Privacy Rights

Subject to the exceptions and procedures set out in the applicable law of your country of residence, you may generally have the right to:

• Access: obtain confirmation of, and access to, the personal data we hold about you;
• Correction: request correction of inaccurate or incomplete personal data;
• Deletion: request deletion of personal data that is no longer necessary for the purpose it was collected;
• Objection / restriction: object to, or request restriction of, certain processing, including direct marketing;
• Portability: request a copy of your personal data in a portable format, where technically feasible;
• Withdraw consent: withdraw previously given consent, without affecting the lawfulness of prior processing.

These rights are provided under, and may vary according to, the PDPA (Singapore), Decree 13/2023/NĐ-CP (Vietnam), the PDPA (Malaysia), the Data Privacy Act (Philippines), the PDPA (Thailand), Law No. 27/2022 (Indonesia), and the Privacy Act 1988 and Australian Privacy Principles (Australia). To exercise any right, contact us at [email protected] with your name, contact details, country of residence and the nature of your request. We will verify your identity and respond within the timeframe required by applicable law (generally within 30 days). Where Antsomi acts as a Processor for End User data, such requests should first be directed to the relevant Customer.

If you are not satisfied with our response, you may lodge a complaint with your local data protection authority, including the Personal Data Protection Commission (Singapore), the Ministry of Public Security (Vietnam), the Department of Personal Data Protection (Malaysia), the National Privacy Commission (Philippines), the Personal Data Protection Committee (Thailand), the Ministry of Communication and Informatics (Indonesia), or the Office of the Australian Information Commissioner (Australia).

10. Children’s Privacy

The Services are intended for business use and are not directed to children. We do not knowingly collect personal data from individuals under 18 years of age (or the applicable minimum age under local law), and we will delete any such data if we become aware it has been collected without appropriate consent. Parents or guardians who believe their child has provided personal data to us may contact [email protected].

11. Third-Party Links and Social Media Features

Our website may contain links to, or features from, third-party websites and social media platforms. This Policy does not apply to those third parties, and we are not responsible for their privacy practices. We encourage you to review their privacy policies before providing personal data.

12. Changes to This Policy

We may update this Policy from time to time to reflect changes in our practices or applicable law. Material changes will be notified through our website or by email, and the “Last updated” date above will be revised accordingly. Continued use of the Services after an update constitutes acceptance of the revised Policy.

13. Contact Us / Data Protection Officer

For questions, requests or complaints regarding this Policy or our handling of personal data, please contact our Data Protection Officer, Serm Teck Choon, at [email protected], or via the “Contact Us” form at https://antsomi.com/contact-us/ (note “Data Protection Officer”).