Socxo Pte. Limited (“Our”, “We”, “Us”, “Socxo”) provides services to Subscribers including access to the website www.socxo.com and the Socxo web and mobile application (the “Socxo App”), the website www.socxly.com and the Socxly web and mobile application, including its LinkedIn Hub feature suite (the “Socxly App”), and the upcoming Socxo Signals platform, an AI-native Buyer Intelligence and Sales Enablement tool (“Socxo Signals”), each subject to the respective Terms of Service (the “ToS”) and this common Privacy Policy (the “Policy”).

This Policy applies to visitors, unregistered users and registered users (“Subscribers”) of www.socxo.com, www.socxly.com, the Socxo App, the Socxly App and Socxo Signals (together, the “Services”), with respect to all information collected through the Services, and forms part of the applicable ToS. The terms “You” and “Your” denote the Subscriber and include all authorised and permitted users under a Subscriber. Socxo may collect personal information about You online through the Services and connected social media handles, including LinkedIn. By providing Your personal information to Socxo and by using the Services, You consent to Socxo collecting Your personal information and using, processing and disclosing it in accordance with this Policy.

Please do not provide Your personal information to Socxo, or use the Services, if You disagree with any of the practices described in this Policy or do not consent to Our collection, use or disclosure of Your personal information as described herein.

This Policy provides insight into the nature of information collected, how and why such information is collected, how such information is stored, and how the Services utilise such information. This Policy is drafted with reference to, and is intended to support compliance with, applicable data protection laws including the Personal Data Protection Act 2012 of Singapore (“PDPA”), the EU General Data Protection Regulation and the UK GDPR (together, “GDPR”), and the Digital Personal Data Protection Act, 2023 of India (“DPDP Act”), besides other applicable data protection laws of the jurisdictions in which Subscribers are located.

1.1 This Policy is common to and governs the Socxo App (the flagship Employee Advocacy platform), the Socxly App (including its Smart Link/Short Link feature set and its LinkedIn Hub feature suite described in the Socxly ToS), and Socxo Signals (Socxo’s upcoming AI-native Buyer Intelligence and Sales Enablement platform). Where a provision applies to only one of these Services, this is stated expressly; otherwise, references to “the Services” apply to all of them.

1.2 This Policy should be read together with the Terms of Service applicable to the specific Service You use, including the Terms of Service, which addresses LinkedIn Hub features such as Post Intelligence, AI Features and account inactivity/misuse handling that are also referenced in this Policy.

i) “AI Features” has the meaning given in the Socxly ToS, features that use generative AI/LLM models to generate or assist in generating text, images, links or other output.

ii) “Business User” and “Individual User” have the meanings given in the Socxly ToS.

iii) “Post Intelligence” means the LinkedIn Hub feature that identifies and displays the names and LinkedIn profile URLs of persons who have engaged (liked, reacted to or commented) on a Subscriber’s LinkedIn posts.

iv) “Socxo Signals” means Socxo’s upcoming AI-native Buyer Intelligence and Sales Enablement platform, which may use Post Intelligence and Smart Link engagement data to help identify potential customers, partners and employees for Subscribers.

v) “Subscriber”, “You”, “Your” has the meaning given above, and where applicable includes the Entity registering for the Services and its Authorised Users.

vi) “Third-Party Engager” means a natural person who is not a Subscriber but whose name and/or LinkedIn profile URL is collected via Post Intelligence because they engaged with a Subscriber’s LinkedIn post, as described in Clause 7.

3.1 Socxo offers services through the Socxo App (a Social Advocacy platform), the Socxly App (a content marketing, short link and LinkedIn Hub platform) and Socxo Signals (a Buyer Intelligence platform), and collects only information necessary for the purposes of providing the respective Services to You. Categories of information collected are described in Clauses 3.2 to 3.9.

3.2 Voluntary Information. Information You voluntarily provide to Us, including, as a Subscriber, Your Company name, name of the authorised person, email ID, job title, and similar registration details, provided upon registration on the Website or the Services.

3.3 Authentication and Single Sign-On Information. Where You register or log in using a Single Sign-On (“SSO”) or identity provider described in Clause 6, We receive limited profile information from that provider (such as Your name, email address and profile picture) as further described in Clause 6, in place of, or in addition to, direct Email/OTP registration.

3.4 Involuntary Information. Information collected automatically by Socxo when You log in through Our website and/or mobile app, including Your IP address, operating system, browser and computer system details, screen resolution, browsing activity, and information about how You interact with Our websites. We may also collect information regarding Your connected social network accounts, such as name, profile picture, and track Your social network activities, including the number of likes, comments or shares on posts shared through the Socxo App or Socxly App (including LinkedIn Hub). Our website/app may request permissions including use of Your camera, photos, media, contacts (email IDs) and location; Socxo shall never post any content without Your consent.

3.5 Social Media Engagement and Post Intelligence Information. Where You use LinkedIn Hub’s Post Intelligence feature, We collect engagement metrics and, where made available through approved LinkedIn APIs, the names and LinkedIn profile URLs of persons who engaged with Your posts. This may include information about Third-Party Engagers who are not themselves Subscribers, as described in Clause 7. Where Socxo Signals is activated, such data, together with Smart Link click and engagement data, may further be processed and enriched to help identify potential customers, partners and employees for the Subscriber, as described in Clause 7.

3.6 AI Feature Usage Information. Where You use an AI Feature (such as AI Post Text Generation, post ideation or the AI ideation chat), We and/or Our AI vendors process the prompts, inputs and files You submit, and the resulting AI-generated output, as necessary to provide the relevant AI Feature, as described in Clause 8.

3.7 Payment Information. Socxo may store limited payment-related information, including the last four digits of Your credit/debit card, solely to facilitate invoice generation and automate renewal processes, as described in Clause 11.

3.8 Device, Technical and Telemetry Information. Where the Services are accessed via mobile application or browser extension, We may collect device screen resolution, IMEI number, device identifiers, location and related telemetry data, as described in the applicable ToS.

3.9 Cookies and Similar Technologies. We may use cookies and similar technologies to track and analyse Your browsing habits on Our websites, as described in Clause 18.

4.1 All information collected is used only to provide You with the best possible Services, including registration and account management, service delivery, AI Feature provisioning, Post Intelligence and Socxo Signals functionality, customer support, billing, security and legal compliance.

4.2 Your system details (“system” includes mobile phone, computer, laptop, tablet, personal digital assistant, etc.), including operating system, screen resolution and browser details, are collected to optimise Our website and Services to suit Your requirements.

4.3 We may track and analyse Your browsing habits through cookies or similar means to help optimise web content and, where applicable, advertising. You may exercise Your right to withhold this information by disabling cookies in Your browser settings, as described in Clause 18.

4.4 Personal information collected during the registration process is used only for registration and account maintenance purposes. Socxo may store Your payment details, including bank account/credit card information, solely to automate the renewal process, subject to Clause 11.

4.5 As part of Our Services, We may track and analyse Your connected social media accounts solely to provide a detailed and analytical report on the social media marketing carried out through the Services, including LinkedIn Hub Analytics and Post Intelligence. We do not collect personally identifiable information from Your social media accounts beyond what is described in Clause 3.5 and Clause 7.

4.6 Where You use AI Features, Your prompts and inputs are used to generate the requested AI Output, and, subject to Clause 8, may be used in de-identified or aggregated form to improve and monitor the safety and quality of AI Features.

4.7 Where Socxo Signals is used, Post Intelligence and Smart Link engagement data is used to build buyer-intent and persona insights for the purpose of helping Subscribers identify potential customers, partners and employees, subject to the safeguards in Clause 7.

5.1 Where GDPR applies, Socxo relies on one or more of the following legal bases: (a) performance of a contract with You (e.g., account provisioning, service delivery); (b) Your consent (e.g., certain cookies, marketing communications, use of AI Features involving optional data, and Post Intelligence/Socxo Signals features where consent is the appropriate basis); (c) Socxo’s legitimate interests (e.g., service security, fraud prevention, product improvement, and limited processing of publicly available LinkedIn engagement data for Post Intelligence, balanced against the rights of Third-Party Engagers as described in Clause 7); and (d) compliance with a legal obligation.

5.2 Where PDPA applies, Socxo relies on Your consent (including deemed consent where You voluntarily provide information for a stated purpose) or another basis permitted under the PDPA, such as the legitimate interest or business improvement exceptions, in each case only to the extent proportionate and with appropriate notice.

5.3 Where the DPDP Act applies, Socxo relies on Your free, specific, informed and unambiguous consent for processing of personal data, or on a “certain legitimate use” recognised under the DPDP Act (such as for a purpose for which You have voluntarily provided personal data and have not indicated non-consent, or for compliance with a legal obligation).

5.4 Where Socxo processes personal information on behalf of a Subscriber acting as a data controller/data fiduciary in its own right (for example, a Business User using Socxo Signals to process data about its own prospects or an Entity managing its own Authorised Users), Socxo acts as a data processor for that specific processing activity, and the Subscriber remains responsible for establishing its own lawful basis, as further set out in Clause 19.

6.1 Socxly Authentication. The Socxly App (including LinkedIn Hub) may be accessed through individual Single Sign-On via Google, Facebook, Apple or Microsoft, or through direct Email/OTP- based access. When You choose an individual SSO option, the relevant identity provider authenticates You and shares limited profile information with Socxo (typically Your name, email address and profile picture) in accordance with that provider’s own privacy policy and the permissions You grant at the time of authorisation.

6.2 Socxo and Socxo Signals Authentication. The Socxo App and Socxo Signals may be accessed through Corporate Single Sign-On, including Azure Active Directory (Azure AD) or Okta via SAML, as configured by Your organisation’s administrator, or through direct Email/OTP-based access. Where Corporate SSO is used, Your organisation’s identity provider authenticates You, and Socxo receives the identity attributes released by that identity provider under the configuration set by Your organisation (typically name, email address, and, where configured, job title or group/role membership).

6.3 Role as Relying Party. In each case, Socxo acts only as a “relying party” to the relevant identity provider. Socxo does not receive or store Your password or authentication credentials held by Google, Facebook, Apple, Microsoft, Azure AD, Okta or any other identity provider, and authentication security (including multi-factor authentication, session and credential management at the identity-provider level) remains governed by that provider’s own systems, terms and privacy policy.

6.4 Corporate SSO Administration. Where Your organisation has configured Corporate SSO (Azure AD or Okta SAML) for the Socxo App or Socxo Signals, Your organisation’s administrator controls user provisioning, de-provisioning and access policies for the Service, and Socxo will act on instructions received through that Corporate SSO configuration (including automatic de-provisioning on removal from Your organisation’s directory, where enabled).

6.5 No Responsibility for Identity Provider Practices. Socxo is not responsible for the data handling, security or privacy practices of Google, Facebook, Apple, Microsoft, Azure AD, Okta or any other identity provider You choose to authenticate through. You should review the privacy policy of the relevant identity provider before using it to access the Services.

6.6 Email/OTP Access. Where You register or log in using direct Email/OTP access (available across the Socxo App, Socxly App and Socxo Signals), We collect and verify Your email address and issue a one-time password/code for authentication purposes, retained only as necessary for account security.

7.1 Nature of the Data. Post Intelligence identifies persons who have liked, reacted to or commented on a Subscriber’s LinkedIn posts, and, where available through approved LinkedIn APIs, displays their name and LinkedIn profile URL to the Subscriber. This is personal data of the Third-Party Engager, most of which is data that such person has already made visible through their own engagement with a public or connections-visible LinkedIn post.

7.2 Purpose Limitation. Post Intelligence data, and any Socxo Signals enrichment derived from it, is made available to Subscribers solely to help them understand engagement with their own content and, where Socxo Signals is activated, to help identify potential customers, partners and employees for legitimate B2B marketing, sales and recruitment purposes. Subscribers must not use this data for any purpose inconsistent with this Policy, the Socxly ToS, or applicable law.

7.3 Source and Basis. Data made available through Post Intelligence is sourced only through LinkedIn’s approved APIs and platform mechanisms, consistent with LinkedIn’s own platform policies; Socxo does not scrape or extract data from LinkedIn outside of approved API access. Socxo’s own processing of this data as a service provider to the Subscriber relies on the legitimate interests described in Clause 5.1, balanced against the rights of the Third-Party Engager, having regard to the fact that the underlying engagement (like, reaction or comment) was a voluntary and visible action taken by that person on the relevant post.

7.4 Subscriber Responsibility. Where a Subscriber (particularly a Business User) uses Post Intelligence or Socxo Signals data for outreach, marketing, sales or recruitment activity directed at a Third-Party Engager, the Subscriber acts as an independent data controller/data fiduciary for that onward processing, and is solely responsible for ensuring it has a lawful basis to do so (including, where required, obtaining consent or providing notice to the Third-Party Engager) and for complying with applicable data protection and anti-spam/marketing laws. This obligation is also set out in the Socxly ToS.

7.5 Rights of Third-Party Engagers. A Third-Party Engager who wishes to exercise a data protection right (such as access, correction or objection) in respect of data made available through Post Intelligence may contact Socxo using the details in Clause 21, and Socxo will take reasonable steps to address the request, including, where appropriate, directing the request to the relevant Subscriber(s) who received the data, or removing the relevant data from Socxo’s own systems where feasible.

7.6 Retention. Post Intelligence and Socxo Signals-derived data is retained in accordance with Clause 13, and is deleted upon deletion of the associated Subscriber account under Clause 13, or earlier upon a valid request under Clause 7.5, subject to Socxo’s legal retention obligations.

8.1 AI Vendors. Socxly’s AI Features (including within LinkedIn Hub) are powered by proprietary and/or third-party generative AI/LLM providers, which Socxo may change at its discretion, as described in the Socxly ToS. Where a third-party AI vendor is used, Your prompts, inputs and related data necessary to generate the requested AI Output are transmitted to that vendor for processing.

8.2 Data Use Limitations. Socxo takes reasonable steps to engage AI vendors that agree not to use Subscriber data to train their general-purpose models without appropriate safeguards or authorisation, and to process such data only as necessary to provide the AI Feature. However, as AI vendors and their terms may change, You should avoid submitting highly sensitive personal data through AI Features unless necessary.

8.3 No Automated Decision-Making with Legal Effect. Socxo does not use AI Features to make decisions producing legal or similarly significant effects on Subscribers or Third-Party Engagers without human involvement. AI Output (including Post Intelligence-derived insights and Socxo Signals persona/scoring information) is provided as an aid to the Subscriber’s own decision-making, and the Subscriber remains responsible for verifying and acting on such output, as set out in the Socxly ToS.

8.4 Retention of AI Inputs/Outputs. Prompts, inputs and AI Output are retained only as long as necessary to provide the relevant AI Feature and for a reasonable period thereafter for quality, safety and support purposes, subject to Clause 13.

9.1 We are committed to protecting Your personal information and will make reasonable security arrangements to prevent unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks. Although Socxo attempts to protect Your personal information, Socxo does not warrant the security of any information You transmit to Us, and You do so at Your own risk. Socxo, through the Services, provides You the right of deletion of personal data and account as described in Clause 16.

9.2 Google Services, User Data Policy. Socxo strictly complies with the Google API Services User Data Policy, including the Limited Use requirements, for any information received from Google APIs, including where Google SSO is used under Clause 6.

9.3 Cloud Providers. We utilise third-party cloud services, including Microsoft Azure and Amazon Web Services or similar providers, to store information, and third-party AI vendors described in Clause 8, each of which is bound by appropriate data protection terms. You may review their respective privacy and security documentation for further detail.

9.4 General. Socxo does not share Your personal contact information with unaffiliated third parties for non-service-related purposes without Your prior consent. Where We share Your information, Socxo will ensure it is stored and processed securely and in accordance with this Policy, in each country or territory in which it is stored/processed, through appropriate instruments (such as contractual agreements, including standard contractual clauses where required) as described in Clause 12.

9.5 Socxo may use personal information collected for registration and account management purposes. Note that whenever You voluntarily disclose personal information online (including on LinkedIn or other social platforms), such information could be collected and used by others; Socxo is not responsible for the actions of third-party websites, apps or platforms and their respective privacy policies.

9.6 Socxo may, where You so consent, provide certain information and user statistics to prospective advertisers, partners or ISPs for marketing assistance, customer service or survey purposes.

9.7 Socxo may disclose personal information where required by law, to protect the rights or property of Socxo, or where Socxo believes disclosure is appropriate in the interests of national security. Government authorities or a competent court may require disclosure, including of Your personal information, and Socxo will comply where legally compelled, particularly in matters of national security, criminal activity or litigation.

9.8 Socxo may use the information/data to manage its relationship with You; prevent and detect security threats, fraud or other illegal activity, including platform or AI Feature Misuse as described in the Socxly ToS; communicate with You and provide updates; offer support services; and undertake data analysis and research to improve the Services.

9.9 Socxo may send You emails and notifications through the Services, including the inactivity notice described in Clause 13. Your data is protected and presented to You through the applicable application for reference. We confirm that Your data will not be offered to any third party not connected with the Services, other than as described in this Policy. For further queries, reach out to Your company administrator for the Service.

10.1 If You are a Registered Individual/Personal User and/or Subscriber of the Socxo App and/or Socxly App (including LinkedIn Hub), You may be given the following options within the app using approved social media platform APIs: authorise and connect Your personal social media accounts (Facebook, LinkedIn, Twitter/X); share posts or content on Your connected accounts; remove Your social media account connections; and delete platform data/accounts as described in Clause 16. You will also be able to view engagement metrics (reactions, comments), including via Post Intelligence, whichever is available from approved APIs of the respective social media platform. By doing so, You confirm You are authorised and in full compliance with the respective social media platform’s policies, and You indemnify Socxo under the applicable ToS.

10.2 If You are a Registered Admin User or Admin Subscriber (as an authorised representative of a company/business, or an individual business owner), You will have the equivalent business-level options described in Clause 10.1 in respect of Your business social media accounts, including LinkedIn Company/Brand Pages managed through LinkedIn Hub, subject to the same compliance and indemnity obligations.

Socxo will not collect or hold information related to Your digital/online payment details, except the last four digits of Your credit or debit card, used only for automatic invoice generation. Payments are made through a secure third-party payment gateway, which collects card details and transaction history under its own terms and conditions (including www.stripe.com, where applicable). The privacy policy of the relevant payment gateway also applies. Where LinkedIn Hub Token/Credit purchases are made, the same payment-gateway arrangement applies.

12.1 Given Socxo’s cloud infrastructure, AI vendors and SSO identity providers may be located in jurisdictions other than Your own, Your personal information may be transferred to, stored in, and processed in countries other than the country in which it was collected, including Singapore and other jurisdictions where Our processors operate.

12.2 Where required under GDPR, such transfers are made subject to appropriate safeguards, such as the European Commission’s Standard Contractual Clauses, an applicable adequacy decision, or another lawful transfer mechanism. Where required under the DPDP Act or PDPA, Socxo will comply with any applicable cross-border transfer restrictions or notified requirements in force from time to time.

12.3 By using the Services, You acknowledge and consent to such cross-border transfer, storage and processing of Your personal information, subject to the safeguards described in this Clause 12.

13.1 Socxo will not keep personal information longer than is reasonably necessary for the purpose for which it was collected, or for any legal or business purpose, or as agreed between Socxo and Your employer. Examples of a legal or business purpose justifying retention include: (i) handling an ongoing legal claim or action; (ii) compliance with applicable laws or regulations; (iii) carrying out business operations, such as generating annual reports or performance forecasts; and (iv) meeting contractual requirements. Socxo will ensure personal information is securely destroyed or erased from Our systems when no longer required.

13.2 Inactivity-Based Deletion. Consistent with the Socxly ToS, where a Registered User of Socxly does not log in to or otherwise access their account for a continuous period of 60 days, Socxo/Socxly will remove account access and permanently delete all associated personal data, following a prior notice of inactivity sent approximately 15 days before the end of the 60-day period.

13.3 Misuse-Based Deletion. Consistent with the Socxly ToS, where an account is found to have misused the platform or its AI Features for illegitimate or illegal purposes, Socxo/Socxly may immediately and permanently delete all associated personal data without prior notice.

13.4 Post Intelligence/Socxo Signals data relating to Third-Party Engagers is retained and deleted in accordance with Clause 7.6.

14.1 Socxo implements administrative, technical and physical safeguards designed to protect personal information against unauthorised access, use, alteration or disclosure, including encryption in transit, access controls, and reliance on established cloud infrastructure providers described in Clause 9.3.

14.2 No method of transmission or storage is completely secure. While Socxo strives to protect Your personal information, We cannot guarantee its absolute security, and any transmission of information to Us is at Your own risk, as set out in Clause 9.1.

15.1 Subject to applicable law and any relevant exemptions, You have the right to:

vii) Access, request confirmation of, and access to, the personal information Socxo holds about You;

viii) Correction, request correction of inaccurate or incomplete personal information;

ix) Erasure, request deletion of Your personal information, including via the account-level deletion right described in Clause 16;

x) Withdraw Consent, withdraw consent previously given for a specific processing activity, without affecting the lawfulness of processing before withdrawal;

xi) Restriction, (where GDPR applies) request that We limit the way We use Your personal information in certain circumstances;

xii) Portability, (where GDPR applies) request a copy of certain personal information in a structured, commonly used, machine-readable format;

xiii) Objection, object to processing based on legitimate interests, including certain uses of Post Intelligence data, and to direct marketing;

xiv) Grievance/Complaint, lodge a complaint with the relevant supervisory authority, including the Personal Data Protection Commission of Singapore (PDPC), the competent EU/UK Data Protection Authority, or the Data Protection Board of India, as applicable, in addition to contacting Socxo directly under Clause 21.

15.2 You have the right to request access to, amend and/or withdraw consent given for the collection, use or disclosure of Your personal information held by Socxo. We will take all reasonable steps to comply with such requests within the timelines required by applicable law. You may reach out to Your employer/app administrator if registered under a corporate account, or otherwise to Socxo’s Administrator/Grievance Officer at the contact details in Clause 21.

15.3 We may need to verify Your identity before acting on a request under this Clause 15, and may decline a request where permitted or required by applicable law (for example, where the request would adversely affect the rights of another person, including a Third-Party Engager under Clause 7).

16.1 You have the right and option to delete Your account, on Your own, within the Socxo App and Socxly App, thereby removing the personal data associated with Your account and associated connected sites through the app.

16.2 You can reach out to the Socxo Administrator/Grievance Officer at advocacy@socxo.com to further request and confirm the status of Your deletion process and request, including deletion arising from account inactivity (Clause 13.2) or platform/AI Misuse (Clause 13.3).

17.1 The Services are intended for business, professional and individual use by persons of or above 18 years of age, consistent with the eligibility requirements in the applicable ToS. Socxo does not knowingly collect personal information from individuals under 18 years of age. If Socxo becomes aware that it has inadvertently collected personal information from a person under 18, it will take reasonable steps to delete such information.

18.1 We use cookies and similar technologies on Our websites to recognise You, remember Your preferences, and analyse site traffic and usage, as described in Clause 4.3.

18.2 You may disable cookies through Your browser settings; doing so may affect the functionality of Our websites and Services. Where required by applicable law, We will obtain Your consent before placing non-essential cookies.

19.1 Third-Party Identity and AI Providers. Socxo is not responsible for the data handling, security, availability or privacy practices of third-party SSO identity providers (Google, Facebook, Apple, Microsoft, Azure AD, Okta) or third-party AI vendors described in Clause 8, each of which processes data under its own terms and privacy policy.

19.2 Third-Party Social Platforms. Socxo is not responsible for the privacy or data practices of LinkedIn, Facebook, Twitter/X or any other social media platform integrated with the Services, and Your use of such platforms remains subject to their own terms and privacy policies.

19.3 Subscriber as Independent Controller. Where a Subscriber (particularly a Business User using Socxo Signals, or an Entity managing its own Authorised Users) determines the purposes and means of processing personal information independently of Socxo, including outreach to potential customers, partners or employees identified via Post Intelligence or Socxo Signals, that Subscriber acts as an independent data controller/data fiduciary for such processing and bears sole responsibility for its own compliance with applicable data protection law, as set out in Clause 7.4 and the applicable ToS.

19.4 No Liability for Subscriber Content or Onward Use. Consistent with the applicable ToS, Socxo shall not be liable for Your Content, Your use of AI Output, or Your onward use of Post Intelligence or Socxo Signals data, and You agree to indemnify Socxo in accordance with the indemnification provisions of the applicable ToS for any claim arising from such use.

19.5 Limitation of Liability. Socxo’s liability in connection with this Policy is subject to the limitation of liability provisions set out in the applicable ToS.

20.1 In the event of a data breach affecting Your personal information that is likely to result in a risk to Your rights and interests, Socxo will notify affected Subscribers without undue delay, and will notify the relevant supervisory authority (such as the PDPC, the competent EU/UK Data Protection Authority, or the Data Protection Board of India) where required under applicable law and within the applicable statutory timelines.

21.1 For any queries, requests or grievances relating to this Policy or the processing of Your personal information, including requests under Clause 15, You may contact Socxo’s Grievance Officer/Data Protection contact at advocacy@socxo.com, or, for Socxly-specific matters, at support@socxly.com.

21.2 Socxo will acknowledge and endeavour to resolve grievances within the timelines prescribed by applicable law (including under the DPDP Act, where applicable), and in any event as soon as reasonably practicable. Grievance Officer, Sudarsan Rao.

21.3 Contact address: Socxo Pte. Limited, 2, Venture Drive, #08-28 Vision Exchange, Singapore 608526.

22.1 Socxo reserves the right to modify or update this Policy at any time, including to reflect new features such as further Socxo Signals capabilities or additional AI Features. Material changes will be reflected by updating the “last updated” date on this page, and, where required by applicable law, We will provide additional notice or seek fresh consent. You are encouraged to review this Policy periodically.

23.1 This Policy shall be governed by and construed in accordance with the laws of Singapore, without prejudice to any mandatory data protection rights available to You under the law of Your own jurisdiction, including GDPR/UK GDPR or the DPDP Act, where applicable.