Security & Compliance

Data Processing Agreement

1. Scope and Application

This appendix applies only to the extent that VoyraCloud, as a processor on your behalf, processes personal data ("Data") contained in or related to your member content in the course of providing any VoyraCloud services to you, if required by data protection regulations (as defined below).

This appendix constitutes part of the VoyraCloud terms and conditions, or other equivalent agreement between you and VoyraCloud regarding your use of VoyraCloud services ("Agreement").

Capitalized terms not defined here will have the meanings given in the Agreement. If there is a conflict between other terms of this Agreement (including its appendices) or any other agreement you have with VoyraCloud regarding data and this appendix, this appendix shall prevail.

2. Definitions

In this appendix:

"Controller," "Data Subject," "Process," "Processor," and "Supervisory Authority" all have the meanings given to them in the GDPR, or equivalent terms under applicable data protection regulations.

"Data Protection Law" means (as applicable): all laws and regulations applicable to you and/or VoyraCloud processing data and binding upon them, including but not limited to (i) GDPR, (ii) GDPR preserved to UK law by section 3 of the European Union (Withdrawal) Act 2018 ("UK GDPR"), (iii) Singapore Personal Data Protection Act 2012 ("PDPA"), and in each case any relevant national laws, regulations, rules or regulations related to privacy and data protection. For clarity, references to data protection laws include references to data protection laws as amended, modified, extended, re-enacted, consolidated or replaced from time to time.

"GDPR" means Regulation (EU) 2016/679.

"Personal Data" means personal data, personal information, personally identifiable information or other equivalent terms (all as defined in data protection regulations).

"Restricted Transfer" means (i) in the case of applicable GDPR, the transfer of personal data from the European Economic Area to countries, territories or organizations outside the European Economic Area where such transfer is not subject to an adequacy decision by the European Commission; and (ii) in the case of applicable UK GDPR, the transfer of personal data from the UK to any other country, territory or organization where such transfer is not based on adequacy provisions set out in section 17A of the UK Data Protection Act 2018.

"Standard Contractual Clauses" means (i) if data is protected by GDPR, the standard contractual clauses annexed to Commission Implementing Decision (EU) 2021/914 of 4 June 2021 on standard contractual clauses for the transfer of personal data to third countries pursuant to Regulation (EU) 2016/679 of the European Parliament and of the Council ("EU SCCs"); and (ii) if data is protected by UK GDPR, the "International Data Transfer Addendum to the European Commission's Standard Contractual Clauses" issued by the Information Commissioner under section 119A(1) of the Data Protection Act 2018 ("UK Addendum"). Copies of the Standard Contractual Clauses can be obtained at https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc, or by contacting us at voyracloud@gmail.com.

3. Processing Description

For this appendix, you (as a controller or processor) designate VoyraCloud as your processor, processing data during the term of this Agreement for the purpose of providing VoyraCloud services and complying with applicable law ("Permitted Purpose").

4. Data Processing

When processing data in accordance with this Agreement, VoyraCloud shall within the scope of its possession or control:

(a) Process data only at your written instruction, unless applicable law requires otherwise;

(b) Ensure that all personnel authorized to process data through VoyraCloud comply with appropriate confidentiality obligations;

(c) Implement and maintain appropriate technical and organizational security measures (including access controls), or make other reasonable security arrangements, aimed at: (i) Protecting VoyraCloud's data from unauthorized or accidental access, processing, deletion, loss or use caused by VoyraCloud's security vulnerabilities; VoyraCloud may change these measures from time to time, but will not lower the level of protection below the mandatory minimum required by data protection regulations (if applicable). If a confirmed security event occurs, within the scope of data protection regulations: (1) VoyraCloud shall promptly notify you and provide you with reasonable information and cooperation so that you can fulfill any data breach reporting obligations under applicable data protection law (and in accordance with its time table); (2) VoyraCloud shall further take any reasonable necessary measures and actions to mitigate the impact of the security event and shall keep you informed of all significant developments related to the security event. Security events shall be considered to include the "personal data breach" as defined under applicable data protection law or any equivalent term;

(d) General authorization is hereby granted to you to engage third-party subcontractors for the purpose of processing data, but subject to VoyraCloud's (i) (on condition that you comply with the provisions of section 5 below) assuming full responsibility for any subcontractor; and (ii) imposing data protection terms on any subcontractor designated to process data on behalf of VoyraCloud, requiring that such subcontractor comply with applicable data protection law or this appendix (in the stronger of the two); You may object to the appointment or replacement of such subcontractors before VoyraCloud appoints or replaces them, provided that such objection is based on reasonable grounds relating to data protection; In such case, VoyraCloud shall not appoint or replace the relevant subcontractors, or, if this is not possible, you may terminate the relevant VoyraCloud services and this appendix (within the scope of the VoyraCloud services) but you shall not be entitled to any refund for any fees or costs incurred in connection with such termination, and such termination shall not affect any other services provided to you or any related fees or costs;

(e) Assist you in responding to requests from data subjects to exercise their rights under applicable data protection law, by providing technical measures, enabling you to directly access, correct, delete, restrict or export data within the scope of VoyraCloud's services and VoyraCloud's role as a processor, consistent with your use of VoyraCloud services (and you agree, considering the nature of processing, that this section reflects VoyraCloud's ability to provide such assistance); If data subjects, supervisory authorities, or any other party directly request data from VoyraCloud, VoyraCloud shall immediately notify you or notify the person they should contact you;

(f) If VoyraCloud believes or is aware that its processing of data may pose a high risk to the data subject's data protection rights and freedoms, it shall immediately notify you and provide reasonable cooperation and/or consultation on any data protection impact assessment and/or prior consultation, at your expense, under applicable data protection law;

(g) In your discretion, upon termination of this Agreement, VoyraCloud shall delete or return all data owned or controlled by VoyraCloud, but VoyraCloud shall not be liable for any costs incurred in connection with such deletion or return; If applicable law requires or permits VoyraCloud to retain part or all of the data, or data archived on backup systems, then this requirement does not apply, in which case VoyraCloud shall isolate and protect such data to prevent further processing, except in the following cases: (i) within the scope of the law's requirements, until such data can be deleted; or (ii) such data no longer contains personal data;

(h) VoyraCloud shall make reasonable security arrangements, at (appropriate periodic intervals), to verify the adequacy of its security measures; and

(i) No policy or action that may be inconsistent with data protection law shall be implemented or taken.

If you are granted audit rights (e.g., standard contractual clauses or applicable data protection law), you agree to exercise your audit rights by instructing VoyraCloud to conduct audits in accordance with this clause. If you wish to change this instruction, you may do so by written request or in accordance with the provisions of standard contractual clauses, and such change shall be made in writing (for clarity, none of the above content requires VoyraCloud to provide any data, materials or information about any other VoyraCloud customer).

For the avoidance of doubt, none of the above content requires VoyraCloud to disclose any rights, privileges or immunities granted under any law or professional conduct rule relating to the disclosure of such information.

5. Your Responsibilities

You agree:

(a) To comply with all obligations under applicable data protection laws with respect to you: (i) using VoyraCloud services to process personal data; (ii) designating us as your processor under this appendix; and (iii) processing personal data contained in VoyraCloud services.

(b) This appendix, the Agreement, any other applicable agreements between you and VoyraCloud, and your configuration and use of VoyraCloud services shall together constitute your complete and final written instructions regarding data processing to VoyraCloud; and

(c) You shall not issue any instructions to VoyraCloud as your processor, nor use VoyraCloud services in any way, such that any applicable data protection law or any other applicable law or regulation may be infringed upon, or VoyraCloud or any of its affiliates may infringe any applicable data protection law or regulation. Subject to the general nature of these terms, you agree and acknowledge that when you disclose personal data to VoyraCloud, you shall: (i) obtain or obtain consent from the relevant data subject under applicable law, so as to process personal data of such data subject and disclose it to VoyraCloud for the purpose of collecting, using and/or disclosing (without affecting any other legal basis for VoyraCloud's processing of such personal data), and such consent has not been withdrawn; or (ii) under the scope of law where no consent is required, you have obtained all necessary legal basis under data protection law to process and disclose personal data to VoyraCloud for the purpose of providing VoyraCloud services under this appendix.

(d) You are responsible for the accuracy of your data and ensure it remains up-to-date, and you shall respond to any requests or complaints from data subjects.

6. International Transfer

6.1 You may decide where to store your data ("designated region"). You agree to store your data in the designated region and transfer your data to the designated region. If processing of your data involves transfer outside the designated region, VoyraCloud shall take the measures necessary as a processor to ensure that such transfer complies with applicable data protection regulations.

6.2 If you transfer data to VoyraCloud constituting a restricted transfer, you agree that the Standard Contractual Clauses shall be deemed to be concluded between you (as a data exporter) and VoyraCloud (as a data importer) by reference to this appendix, as follows:

6.2.1 For data protected by GDPR, the EU SCC shall apply as follows:

(a) If you are the controller of the data module, then the second provision shall apply; if you are the processor of the data module, then the third provision shall apply, in each case, as follows:

(i) In section 7, the optional access clause shall apply (but any new party joining the EU SCC shall be subject to VoyraCloud's prior written consent);

(ii) Option 2 in section 9 shall apply, and the notice period for changes in subcontractors shall be in accordance with the provisions of this appendix section 4(d);

(iii) Option 1 in section 11 shall apply, and the EU SCC shall be subject to Dutch law;

(iv) In section 17, option 1 shall apply, and the EU SCC shall be subject to Dutch law;

(v) The dispute in section 18(b) shall be subject to Dutch court jurisdiction;

(vi) The Annex I of the EU Standard Specifications shall be deemed to contain the complete content of this appendix and/or Annex I of this appendix, and Annex C of the EU Standard Specifications shall be determined by the European Standard Specifications Commission under section 13 of the EU Standard Specifications;

(vii) Annex II of the EU Standard Contractual Clauses shall be deemed to contain the information listed in the Annex C of the linked file in section 4(c);

(b) The following clarifications apply to the EU Standard Clauses:

(i) You may exercise the audit rights under the EU Standard Clauses by applying the provisions of section 4(h) of this appendix and complying with its requirements;

(ii) VoyraCloud may appoint subcontractors under the provisions of section 4(d) of this appendix and you may exercise your right to refuse subcontractors under the provisions of section 4(d) of this appendix;

(iii) Section 4(g) applies to the deletion or return of data transferred after the termination of this Agreement;

(iv) For the avoidance of doubt, considering the nature of VoyraCloud services, you are fully responsible for the accuracy of your data and the legality of your data collection, VoyraCloud has no obligation to check the accuracy of any data transmitted;

(c) You shall pay VoyraCloud the standard professional service fees at the time of the transaction, and shall also reimburse VoyraCloud for any reasonable costs incurred in connection with your use of any data transferred to VoyraCloud under the EU SCC, including but not limited to notification or assistance in processing data subject requests or responses to data subject requests, and cooperation with your deletion or correction of any data transferred;

6.2.2 For data protected by UK GDPR, the UK Addendum shall apply, as follows:

(a) The EU Standard Clauses as filled out in section 6.2.1 shall apply, and shall be modified in accordance with the UK Addendum (filled out under section (b) of this appendix); and

(b) Tables 1 to 3 of the UK Addendum shall be deemed completed, containing information from the EU SCC as described above, and the "exporter" and "importer" options in table 4 shall be deemed selected. The start date of the UK Addendum (as described in table 1) shall be the date of this appendix.

6.2.3. For data outside the scope of GDPR and UK GDPR, if such jurisdictions allow the use of EU SCC (which may be modified to comply with relevant data protection law), then the provisions of the EU SCC shall apply, and necessary modifications shall be made to comply with relevant data protection regulations of the relevant jurisdictions.

6.2.4. For data protected by PDPA, VoyraCloud shall take reasonable necessary measures to ensure that your personal data continues to be protected at least to the standard set out in PDPA. This may include entering into a written agreement with the recipient, including contract terms, company rules with binding effect, and other data protection agreements.

6.3 For further transfer to subcontractors, VoyraCloud shall only participate in such data transfer (including restricted transfer) if it is fully compliant with data protection regulations.

6.4 If any provision of this appendix directly or indirectly conflicts with the Standard Contractual Clauses, the Standard Contractual Clauses shall prevail.

6.5 Subject to any express provisions of this appendix, you agree and acknowledge that you are responsible for compliance with data protection regulations in the following respects: (a) you transfer data from one jurisdiction to another; and/or (b) you instruct VoyraCloud (as your processor) to transfer data from one jurisdiction to another. Subject to the general nature of these terms, you agree and acknowledge that you shall not instruct us or cause us to transfer any personal data to any country or region unless required under data protection regulations regarding such transfer, including but not limited to any obligations under applicable data protection law that may be applicable to you in connection with such transfer, to ensure that the level of protection of the transferred data is consistent with that required under data protection regulations.

7. Other

(a) For clarity, the total cumulative liability of VoyraCloud and its affiliates, employees, agents, subsidiaries, representatives or any representative acting on their behalf for any matter arising out of or related to this Agreement and/or this appendix and/or the Standard Contractual Clauses or any such matter shall not exceed the maximum liability of VoyraCloud under the VoyraCloud terms and conditions section 11.6.

(b) VoyraCloud may modify the terms of this appendix, for example to comply with data protection law or to implement any standard contractual clauses adopted by the Information Commissioner's Office, European Commission or any other supervisory authority under data protection law, but such modifications shall not lower the level of protection provided to you below the mandatory minimum required by data protection law (if applicable). If VoyraCloud modifies the terms of this appendix, then the appendix shall be a revised and restated version on the VoyraCloud platform, and VoyraCloud shall provide you with written notice of any significant revision of the appendix (which may be published on the VoyraCloud platform or displayed in your VoyraCloud account) at least 15 days in advance. Continuing to use the relevant product or service after receiving such written notice constitutes your agreement to be bound by the revised and restated appendix.

Appendix 1

A. List of Parties

Data exporter:

Name: Entity identified as "Customer" in VoyraCloud terms and conditions.

Address: Address of the customer associated with the customer's VoyraCloud account, or any other address specified in the data processing appendix or VoyraCloud terms and conditions.

Contact person name, title and contact details: Contact details of the customer account, or any other contact details specified in the data processing appendix or VoyraCloud terms and conditions.

Activity related to data transmitted according to this clause: Specified in sections 3 and 4 of the data processing appendix.

Signature and date: You clicked the "I agree" button when registering your account, which represents your confirmation, signature and acceptance of the terms and conditions and the data processing appendix on the same day.

Role (controller/processor): Controller or processor, as specified in the data processing appendix.

Data importer:

Name: "VoyraCloud" as described in VoyraCloud terms and conditions.

Address: VoyraCloud address specified in VoyraCloud terms and conditions.

Contact person name, title and contact details: Contact details of VoyraCloud specified in the appendix or VoyraCloud terms and conditions.

Activity related to data transmitted according to this clause: Specified in sections 3 and 4 of the data processing appendix.

Signature and date: You clicked the "I agree" button when registering your account, which represents your confirmation, signature and acceptance of the terms and conditions and the data processing appendix on the same day.

Role (controller/processor): Processor

B. Transfer Description

Data subject categories of transferred personal data: Data subjects may include your customers, employees, suppliers and end users.

Categories of transferred personal data: The capitalized terms not defined here shall have the meanings given in VoyraCloud terms and conditions. Personal data may include any information, content, materials and data in electronic format contained in or related to member content.

Transmission of sensitive data (if applicable) and measures taken to limit or secure such data, such as strict purpose limitations, access restrictions (including only accessible to employees trained in a specific manner), maintaining data access records, restricting subsequent transfers or additional security measures: You may upload special categories of personal data to your VoyraCloud services, which may include (depending on your choice) revealing racial or ethnic origin, political views, religious or philosophical beliefs, trade union membership, genetic data, data relating to the unique identification of natural persons, data relating to health or data relating to the natural person's sex life or sexual orientation, and/or data relating to criminal convictions and crimes or related security measures. Before uploading any sensitive data, you are required to assess and confirm that VoyraCloud's technical and organizational measures are sufficient to handle the sensitive data you choose to upload.

Frequency of transmission (e.g., whether data is transmitted on a one-time or continuous basis): Data may be transmitted occasionally or continuously for the purpose of providing VoyraCloud services and any other provisions of this Agreement.

Nature of processing: We shall process and transmit personal data for the purpose of providing VoyraCloud services and any other provisions of this Agreement.

Purpose of data transmission and further processing: We shall process and transmit personal data for the purpose of providing VoyraCloud services and any other provisions of this Agreement.

Retention period of personal data (if not determinable, then standard): Data shall be processed and transmitted during the term of this Agreement.

For transfer to sub-processors, the subject, nature and duration of processing shall also apply to such transfer to sub-processors.

C. Supervisory Authority

Supervisory authority: For EU GDPR, the supervisory authority shall be interpreted in accordance with the EU SCC section 13; for UK GDPR, the supervisory authority shall be the Information Commissioner's Office.

Service Terms

Please read these terms and conditions carefully.

These terms and conditions (issued from time to time) ("Agreement") are a legally binding agreement between you as a registered member of VoyraCloud platform ("You") and VoyraCloud (Singapore) Private Limited ("VoyraCloud" or "We"), and govern your access and use of your member account ("Account") on VoyraCloud platform, currently located at URL: https://www.voyracloud.com ("VoyraCloud platform"), and VoyraCloud services (as defined below).

1. Applicability and Acceptance

1.1 By registering an account and clicking the "I agree" button, you confirm, agree and accept all the terms and conditions of this Agreement, the privacy policy, data processing appendix, and any other website or service rules and policies on VoyraCloud platform (collectively referred to as "Terms"). If you do not confirm, agree and accept all Terms, please do not register an account or use VoyraCloud platform or VoyraCloud services.

1.2 You may need to enter into any separate agreement or agree to any other terms and conditions (whether online or offline) with VoyraCloud, our affiliates or third parties, to use VoyraCloud services or any other services related to the use of VoyraCloud platform ("Additional Agreements"). If there is any conflict or inconsistency between this clause and any Additional Agreement, then the Additional Agreement shall prevail with respect to the relevant aspect of VoyraCloud services provided under this clause.

2. Using VoyraCloud Services

2.1 You may access, purchase, subscribe or use any and all products or services provided by VoyraCloud, including VoyraCloud and/or products and services provided by our affiliates on the cloud computing platform, as well as the features, functionalities and content of your account and VoyraCloud platform ("VoyraCloud Services"). VoyraCloud services do not include any content or services provided by third parties on VoyraCloud platform or with VoyraCloud services.

2.2 You must register a member account on VoyraCloud platform to purchase and/or use VoyraCloud services. You must ensure that all information provided to VoyraCloud platform is true, accurate, correct and complete, and not misleading, fraudulent or deceptive. You must be responsible for maintaining the confidentiality of your login credentials, and for all activities under your account. You hereby promise that if your account or login credentials are used without authorization or any other security breach or event occurs, you will immediately notify VoyraCloud.

2.3 General product terms.

a) The advantages, functionalities and features of any VoyraCloud service may vary depending on the country or region. VoyraCloud reserves the right to limit, refuse or create different levels of access and use of any VoyraCloud service (or its functionality) for different users.

b) You must comply with any relevant technical documentation for VoyraCloud services published and updated on VoyraCloud platform from time to time. You further agree that as a condition of your continued use of VoyraCloud services, you shall comply with all licensing terms and conditions of all third-party software components, libraries and application programming interfaces contained in VoyraCloud services.

c) VoyraCloud may temporarily or permanently discontinue, modify, upgrade, impose conditions, charge, suspend or stop providing any VoyraCloud service (or any specific feature, functionality or application) at any time, including login procedures and requirements, access to any VoyraCloud service through any URL related thereto, and any related fees and charges, without prior notice.

d) VoyraCloud reserves the right to introduce or delete features, functionalities, applications or conditions in any new version of VoyraCloud service. All new features, functionalities, applications, conditions, modifications, upgrades and changes shall be subject to this clause and any applicable Additional Agreement, unless VoyraCloud otherwise provides.

e) VoyraCloud may monitor your purchase or use of VoyraCloud services at any time at its discretion, to verify your compliance with the Terms. You agree that you will not interfere or obstruct our monitoring.

f) We may modify the terms of any service level from time to time. If you continue to use the relevant product or service after receiving written notice from VoyraCloud regarding such changes, it represents your agreement to the modified service level.

g) VoyraCloud may perform any upgrades or maintenance services at any time at its discretion. VoyraCloud shall use commercially reasonable efforts to notify you of any scheduled maintenance of VoyraCloud platform or VoyraCloud services in advance, and you shall comply with any maintenance requirements of VoyraCloud services.

h) You agree that VoyraCloud may identify and resolve any issues related to VoyraCloud services on its own initiative, and that such issues are believed to be due to your use of VoyraCloud platform or VoyraCloud services.

i) Some products require processing of personal data of your customers or employees. You agree that the legal basis for processing such data under local law is fully your responsibility, including providing sufficient privacy statements to your customers or employees and obtaining any necessary consent. You declare and warrant that you have the legal basis for processing such data under local law, including obtaining any necessary notifications and consent from you. You also declare that you will comply with any data protection law and regulations, including but not limited to obtaining consent and rules related to cross-border transfer of personal data, which may apply to your use of these products.

j) VoyraCloud may occasionally provide special terms or pricing plans ("Special Plans") for VoyraCloud services. VoyraCloud may stop accepting applications for any Special Plan or stop providing any Special Plan at any time without prior notice. If you choose to participate in a Special Plan, you must agree to the terms and conditions of the Special Plan.

2.4 If you subscribe to VoyraCloud's virtual private server service ("VPS service"), you agree:

a) VoyraCloud and our affiliates may collect, use and disclose any information or data we obtain from your use of VPS service or any information defined in our privacy policy ("Subscriber Information"), for the purposes set out in our privacy policy, including sections A, B and C, although any such Subscriber Information may not constitute personal data. You may withdraw your consent to our collection, use and disclosure of your Subscriber Information by following the procedures outlined in our privacy policy section H; and

b) Any third party in the event of a transfer, update, sale or acquisition of any business, asset or equity of VoyraCloud, or in the development or marketing of any goods or services, may collect, use and disclose your Subscriber Information.

2.5 You acknowledge and agree that if any VoyraCloud Service involves any software application provided by a third party, such software application will be provided directly to you by another company or individual on a pass-through basis in accordance with separate terms and conditions (including separate fees and charges). VoyraCloud has not independently tested or screened such software applications, and you use such software applications at your own risk.

2.6 The VoyraCloud Platform and VoyraCloud Services may contain links to third-party websites, services or other resources on the internet, and such third-party websites, services or other resources may also contain links to our VoyraCloud Platform and VoyraCloud Services. When you access third-party resources on the internet, you acknowledge and agree that you do so at your own risk. These third-party resources are beyond our control, and to the maximum extent permitted by law, we assume no responsibility for the content, functionality, accuracy, legality, appropriateness or any other aspect of such resources. The inclusion of any such link does not imply that we endorse, or that there is any association between us and, any third party. To the maximum extent permitted by law, we shall not be directly or indirectly liable for any damage or loss caused or alleged to be caused by the use of or reliance on any such third-party resources.

2.7 VoyraCloud may, at its sole discretion, remove, modify or reject Member Content (as defined below) or any content related to VoyraCloud Services that we consider (a) unlawful, (b) in breach of the Terms, (c) likely to subject VoyraCloud or our affiliates to liability, or (d) likely to disrupt, threaten or harm the operation and functionality of the VoyraCloud Platform or other users of the VoyraCloud Platform. VoyraCloud may further, at its sole discretion, take any action it deems appropriate, including but not limited to issuing you a written warning, removing any Member Content you have submitted or posted to the relevant features/functions of the VoyraCloud Platform or VoyraCloud Services, recovering damages or other monetary compensation from you, suspending or terminating your VoyraCloud account, or suspending your subscription to any VoyraCloud Service. VoyraCloud may further restrict, refuse or prohibit your future use of any other services provided by VoyraCloud.

3. Member Responsibilities

3.1 You agree (whether as part of the account registration process, when using VoyraCloud Services or otherwise) to:

a) Provide your own true, accurate and up-to-date information, as well as information about your credit card, bank account or other payment method, as required by VoyraCloud;

b) Maintain and promptly update all information provided to VoyraCloud to ensure it remains true, accurate and up-to-date;

c) Provide VoyraCloud with any other information related to customer service, risk control, anti-fraud and compliance procedures within the time frame required by VoyraCloud;

d) Be responsible for the development, operation, maintenance, transmission, processing, storage and use of content you run on the VoyraCloud Services resulting in interaction with the VoyraCloud Services, and content submitted, uploaded, posted or displayed on the VoyraCloud Services under your account ("Member Content");

e) Comply with these Terms and any and all applicable laws and regulations (including but not limited to any applicable data protection, import, re-import, export, strategic goods control and re-export control laws, including any applicable licensing requirements and international or country-specific sanctions programs), bear full legal responsibility for any conduct constituting a violation of applicable laws and regulations arising from your access to and use of the VoyraCloud Services, and not engage in any fraudulent or deceptive conduct when using the VoyraCloud Services;

f) Proactively maintain appropriate security, protection and backup of Member Content, and bear full responsibility for Member Content;

g) Be responsible for the activities of your End Users (as defined below) and your End Users' direct or indirect use of Member Content and VoyraCloud Services through the use of VoyraCloud Services, and ensure that such End Users' conduct complies with the Terms and any other terms imposed by VoyraCloud from time to time. For the purposes of this Agreement, "End User" means any individual or business entity that accesses or uses Member Content or uses VoyraCloud Services directly or indirectly through you. VoyraCloud is not responsible for any loss or damage arising out of or related to any Member Content or any use of or reliance on it.

3.2 You must not (whether through your End Users or otherwise):

a) Sell, transfer or sublicense your VoyraCloud account to others, or resell or sublicense any VoyraCloud Service, without VoyraCloud's prior written consent;

b) Violate any applicable law, regulation, ordinance or rule (including but not limited to any applicable data protection, consumer protection, unfair competition, anti-discrimination, false advertising, import, re-import, export, strategic goods control and re-export control laws, including any applicable licensing requirements and international or country-specific sanctions programs);

c) Infringe, misappropriate or otherwise abet or encourage the infringement, misappropriation or violation of the intellectual property rights (as defined below) or other proprietary rights or rights of publicity and privacy or other rights recognized by law of any third party;

d) Engage in any conduct that subjects VoyraCloud or our affiliates to any claim, liability or prosecution;

e) Participate or engage in any scheme to deceive, mislead or defraud VoyraCloud, other members, other users of the VoyraCloud Platform, any other third party or for any unlawful purpose; impersonate any individual or entity, misrepresent yourself or your affiliation with any individual or entity, use a false identity or otherwise engage in fraudulent representations or conduct, and engage in any unlawful activity that may interfere with the normal operation of the VoyraCloud Platform, such as phishing, spamming, flooding attacks or scanning within our network, including but not limited to unauthorized access to other computers, networks, devices or accounts, transmitting, distributing or storing information, data or materials that violate the laws and regulations of Singapore and your country/region, and infringing copyrights, trademarks, trade secrets or other intellectual property rights. Such activities are strictly prohibited and may result in immediate suspension or termination of service without refund;

f) Distribute, send or assist in sending any unsolicited electronic commercial messages, or engage in any form of spamming activity or email marketing that violates the laws and regulations of any relevant jurisdiction, or otherwise do anything that VoyraCloud considers to constitute abuse of promotional and marketing messages;

g) Use the VoyraCloud Services for any activity related to the construction or operation of blockchain systems based on resource-intensive consensus mechanisms (proof of work, proof of capacity, etc.), including but not limited to cryptocurrency mining; or operate any public-facing network service that may be abused, such as open proxies, open mail relays, open recursive domain name servers, tor exit nodes, etc.;

h) Submit, provide or disseminate to VoyraCloud any information or content (including Member Content), or engage in, encourage or assist any conduct, that:

i) Is or may be defamatory, offensive, disparaging, abusive, unlawfully threatening or unlawfully harassing;

ii) Is or may be obscene, or contains or implies any pornography, child pornography or sex-related goods or any other content promoting pornographic material, or otherwise may be harmful to minors;

iii) Promotes discrimination based on race, gender, religion, nationality, disability, sexual orientation or age;

iv) Involves any computer virus or other destructive device and code that has the effect of damaging, interfering with, intercepting or expropriating any software or hardware system, data or personal information, or spreads viruses, malware or other malicious code; or

v) Is objectionable in the interests of public interest, public morality, public order, public security or national harmony, or is prohibited by applicable law;

i) Modify, alter, tamper with, repair or create derivative works of any software contained in the VoyraCloud Services (unless expressly permitted otherwise by the relevant software contained in the VoyraCloud Services); decipher, reverse engineer, disassemble or decompile any part of the VoyraCloud Services (or their underlying ideas, algorithms or source code); access any process or program to obtain the source code of any software in the VoyraCloud Services;

j) Copy, reproduce, download, republish, sell, distribute or resell any VoyraCloud Service or any information, text, images, graphics, video clips, sound, directories, files, databases or listings, etc. made available through the VoyraCloud Services (for the avoidance of doubt, excluding your Member Content) ("Content"); without limiting the generality of the foregoing, copy, reproduce, download, compile or otherwise use any Content for the operation of a business that competes with VoyraCloud, or otherwise commercially exploit the Content; systematically retrieve Content from the VoyraCloud Services to directly or indirectly create or compile a collection, compilation, database or directory (whether through robots, spiders, automated devices or manual processes) without VoyraCloud's written permission;

k) Compromise the integrity of the servers, computers or communication systems, networks, software applications or computing devices used by VoyraCloud and/or any user of the VoyraCloud Services or used in connection with the VoyraCloud Services; attempt to gain unauthorized access to such servers, computer systems or networks, including accessing or scanning others' accounts;

l) Hack, abuse security vulnerabilities or otherwise do anything that VoyraCloud considers to constitute network abuse of any VoyraCloud Platform; probe, test or scan any VoyraCloud Platform for vulnerabilities or breach any security or authentication measures related thereto; forge your origin, including forging TCP-IP packet headers, email headers or any part of any message describing its origin or routing; engage in or attract (or attempt to engage in) any denial-of-service (DoS) attack, distributed denial-of-service (DDoS) attack or any other form of cyber attack; engage in any conduct that may interfere with the normal operation of any VoyraCloud Platform; or otherwise do anything that VoyraCloud considers may compromise the security of any VoyraCloud Platform;

m) Access or use the VoyraCloud Services in a manner that avoids relevant fees or charges, and use third-party software without appropriate license or permission; or

n) Use abusive language toward our staff, send the same question or query to our support ticketing queue, make threats of any kind, and any other conduct that we reasonably consider unacceptable.

3.3 You acknowledge and agree that, by disclosing and/or submitting any information to us, you warrant that you have full power, legal capacity and authority to disclose and/or submit such information, and that the use of such information under these Terms will not expose us to any claim, liability or prosecution.

3.4 In addition to the matters agreed in this Privacy Policy regarding personal information, you also agree to the following undertakings with respect to any data or information (other than personal information) that you provide to us for processing, storage, hosting or any other purpose related to your purchase and use of our services ("Information").

a) Except as described below, the Information you provide to us will be transferred to, stored and processed in the country/region where we, our affiliates or our subcontractors maintain facilities for the VoyraCloud Services. That country/region may differ from your location, and therefore such Information may need to be transferred to an overseas jurisdiction.

b) You acknowledge and agree that any such overseas transfer or processing of such Information is necessary for the processing and management of your customer account and the provision of the VoyraCloud Services, and you consent to it. You further agree and consent to VoyraCloud processing such Information on your behalf under these Terms, and you designate us to transfer such Information to any such country/region and to store and process such Information to provide our services.

c) You acknowledge and agree that information related to your payment instrument (such as a credit card), including information about your payment instrument organization, the last few digits of your payment instrument number, the security code and the expiration date of your payment instrument, will be transferred directly to, and stored and processed by, our third-party payment service provider so that they can process your payment transactions, and we generally do not store any such information.

d) For any other information you provide to us or that we collect, including information provided at registration, information we record related to your activities and information you voluntarily provide, you acknowledge and agree that we may, based on our business judgment, store and/or transfer such information to any of our affiliates, including affiliates located in other countries.

e) We will not disclose such information outside of us, our affiliates or our third-party service providers, except: i) you request us to do so; ii) your End User has consented to us doing so; iii) as provided in the Terms or under an agreement between you and us; or iv) as required by and to comply with applicable law, legal process or lawful government requirements, or for any claim or potential claim against us or our shareholders, subsidiaries or affiliates.

3.5 You also acknowledge and agree that information you provide to VoyraCloud forums (such as our discussion forums and responses to frequently asked questions) shall be subject to these Terms.

3.6 You agree and acknowledge that we have the right, at our sole discretion and at any time, to designate the domain name or URL through which you are permitted to access the VoyraCloud Services and/or VoyraCloud Platform. You shall be solely responsible for implementing any necessary changes at any time so that your systems can interact with it, at your own expense.

3.7 You are responsible for maintaining the security of your data, login credentials and End User accounts (including updating software and making and storing backups). You shall establish your own data backup strategy and continuously verify your ability to effectively recover data. VoyraCloud disclaims all liability and obligations related to the loss or corruption of your data and any indirect damage arising from such events.

3.8 You shall be responsible for your own use of and/or the services you provide on the VoyraCloud Platform, even if such use is carried out by unauthorized persons or hackers.

3.9 You agree that if you discover any violation of this Section 3, you shall immediately report such violation to us.

4. Intellectual Property

4.1 VoyraCloud is the sole owner or lawful licensee of all rights and interests in the VoyraCloud Platform and its content. All title, ownership and intellectual property rights in the VoyraCloud Platform shall vest in VoyraCloud, our affiliates or the licensors of the VoyraCloud content (as applicable). All rights not expressly stated in these Terms or by VoyraCloud are hereby reserved. "VoyraCloud" and related icons and logos are registered trademarks or trademarks or service marks of VoyraCloud in various jurisdictions, and are protected by applicable copyright, trademark and other proprietary rights laws. Unauthorized copying, modification, use or publication of these trademarks is strictly prohibited.

4.2 "Intellectual Property Rights" means:

a) All rights, title and interest in all intellectual property, including all copyrights, patents, trademarks, service marks, logos, trade dress, trade names, internet domain names, design rights, computer software rights, database rights, semiconductor topography rights, utility models and know-how rights, whether registrable or not, including any applications for registration, and all rights or forms of protection having equivalent or similar effect anywhere in the world, on all platforms and media (whether now known or hereafter invented);

b) All rights obtained under license, consent, order, statute or otherwise in relation to any of the rights described in paragraph (a) above;

c) All rights of the same or similar effect or nature as the rights set out in paragraphs (a) and (b), whether now or hereafter existing;

d) All rights to income, royalties, damages, claims and payments now or hereafter due or payable; and

e) All rights to bring an action for past or future infringement of any of the foregoing rights, at law or in equity.

4.3 You retain any rights you may have in any Member Content. VoyraCloud will not access or use your Member Content except as necessary to maintain or provide the VoyraCloud Services or to comply with applicable laws or regulations. Except as otherwise provided in these Terms or other applicable agreements governing your use of the VoyraCloud Services, these Terms do not grant either party any rights to the other party's content or any of the other party's intellectual property rights. As between you and VoyraCloud, you own all intellectual property rights in the Member Content, and VoyraCloud owns all intellectual property rights in the VoyraCloud Services.

4.4 If you believe that your work has been copied in a way that constitutes copyright infringement, you may provide VoyraCloud with written notice containing the full details required by Part IXA of the Copyright Act (Chapter 63) of Singapore, and serve it at VoyraCloud's registered address in Singapore.

4.5 VoyraCloud will only process notices in English that comply with the Singapore Copyright Act, other applicable laws and these Terms. Any notice that does not comply with the foregoing will be rejected. Upon receipt of a compliant infringement notice, VoyraCloud will give due consideration to all infringement notices in the manner described above, and may take further action depending on the nature of the alleged infringement described in the notice, which may include matters applicable to network service providers as described in applicable law. You agree that you shall not take any legal action or exercise any legal remedy you may have against us with respect to any infringing material unless you first serve us with an infringement notice and give us a full opportunity to remove the infringing material, and we subsequently refuse or fail to remove the infringing material within a reasonable time. If we remove infringing material pursuant to your infringement notice, you agree not to exercise, and hereby waive, any right to take action against us under applicable law, whether or not that right arose in our services before we removed such infringing material.

5. Investigation and Enforcement

5.1 VoyraCloud may investigate any violation or breach of these Terms by any End User or you.

5.2 If VoyraCloud believes that any activity violates these Terms or any regulation or law of any jurisdiction, VoyraCloud will report to the relevant law enforcement agencies, regulatory bodies, government agencies and any other appropriate third parties, and VoyraCloud may, for the relevant purpose or to comply with applicable law, legal process or lawful government requirements, or for any claim or potential claim against VoyraCloud or its shareholders, subsidiaries or affiliates, access, retain, disclose and/or delete any content (including any Member Content) you post or submit on VoyraCloud or the VoyraCloud Platform.

6. Fees, Payment and Taxes

6.1 You will pay VoyraCloud the applicable fees for using the relevant VoyraCloud Services through the payment methods supported by the VoyraCloud Platform and in accordance with these Terms.

6.2 Payment processing and related services for individual users on the VoyraCloud Platform are provided by third-party processing providers, and such third-party processing providers collect, process, disclose and store transaction data related to the provision of the VoyraCloud Services in accordance with their privacy policies. We are not responsible for the acts or omissions of the payment processing providers. The service agreement of the third-party payment processing provider applies to you and is incorporated into these Terms by reference. You agree that the third-party payment processing provider and (if applicable) VoyraCloud may collect, process, disclose and store all data (including personal data) of any transaction related to the provision of the VoyraCloud Services. You further represent, warrant and agree that all information you provide to the third-party payment processing provider and VoyraCloud for such transactions is complete, true and accurate, and that you will promptly update all such information when changes occur. If your payment method is cancelled (whether due to loss or theft) or otherwise becomes unavailable, you must also promptly notify us or the payment processing provider.

6.3 Any and all amounts payable by you shall not be subject to set-off or counterclaim, and shall not be deducted or withheld, unless agreed in writing by VoyraCloud.

6.4 The fee, charge and tax terms for the VoyraCloud Services contained in these Terms may be updated on the VoyraCloud Platform from time to time and take effect upon publication on the Platform.

6.5 Product prices listed on the VoyraCloud Platform are denominated in US dollars, and the calculation of payment amounts in currencies other than US dollars is reasonably determined by VoyraCloud.

6.6 VoyraCloud currently supports a prepaid subscription option or a one-time purchase option:

a) The prepaid subscription option charges you based on the subscription term or usage plan of the product you subscribe to. Prepaid subscriptions will automatically renew at the end of the selected subscription term. If you do not wish to renew the product or service, you need to log in to your account and configure your account settings to turn off the auto-renewal option for the prepaid subscription. We may offer you a manual recurring payment option or an automatic recurring payment option. Under the manual recurring payment option, you shall make manual payment when the prepaid subscription renews or when you owe us additional fees. Under the automatic recurring payment option, you authorize us to charge your default payment method when you place an order to purchase prepaid VoyraCloud Services or when you owe us additional fees.

b) The one-time purchase option allows you to use the applicable product only during the purchase period. After the purchase period ends, your access to such products will automatically terminate. If you wish to continue using the product or service, you need to make another one-time purchase or start a prepaid subscription for these products.

6.7 We support payment by credit card in US dollars. Multiple payment methods may be registered simultaneously for each account, but only one default payment method may be used for all your payments. For example, if you use a credit card to pay for prepaid services, this credit card will become your default payment method, and you may only use it for other purchases. If you do not currently have any other existing product or service being paid for with another payment method, you may only use another registered payment method for payment. Each registered payment method may only be bound to one account.

6.8 If, due to reasons attributable to you or your registered payment method, we are unable to bill you or otherwise process your payment, we will notify you by email at your registered email address and ask you to resolve the issue. In such case, you will be unable to continue using your product until the payment is processed, and VoyraCloud will suspend your service until the payment is processed or terminate your service, without any liability to you. Before any service suspension or termination, an email will be sent to your registered email address. The parties confirm and agree that this Section 6.8 applies only to post-payment scenarios for services or prepaid renewal scenarios, and is subject to the termination and suspension provisions in Section 8 of this Agreement.

6.9 Upon termination of your service, VoyraCloud may immediately release all your instances from the date of termination of your service, without any liability to you.

6.10 All fees and amounts payable by you to us (collectively, "Fees") do not include any taxes required by applicable law (including local laws or ordinances), including value-added tax, goods and services tax, sales tax and communications tax (collectively, "Taxes").

6.11 You agree to promptly notify us of any Taxes applicable to any Fees you pay under this Agreement, and to provide us with any supporting documents and information, including your registration number for such Taxes. If you are entitled to any tax exemption by law, you agree to provide us with any current tax exemption documents required for each applicable tax jurisdiction. We will apply the tax exemption certificate to fees incurred under your account after the date we receive the tax exemption certificate. If the tax exemption certificate you provide is challenged as invalid when a tax authority audits the transactions we conduct with you under this Agreement, resulting in us being assessed any Taxes, you agree to reimburse us for the resulting Taxes, interest and penalties.

6.12 If any Fees you pay to us are subject to deduction or withholding, you agree to pay us any additional amount to ensure that the net amount we receive (after deduction or withholding) equals the amount we would have received without deduction or withholding. In addition, you agree to provide us with supporting documents within thirty (30) calendar days after payment, proving that any such deduction or withholding has been timely and correctly remitted to the relevant tax authority.

6.13 You may be eligible for a refund of the relevant VoyraCloud Service usage fees in the following circumstances:

a) If VoyraCloud is unable to provide the VoyraCloud Services you have purchased, you are entitled to a full refund of the fees paid for the unavailable VoyraCloud Services;

b) For virtual private server services: (i) if you cancel or terminate the VoyraCloud Service within 24 hours of purchase, and you have used less than 5GB of data transfer for such VoyraCloud Service, you are eligible for a full refund of the fees you paid for such VoyraCloud Service; or (ii) if you cancel or terminate the VoyraCloud Service 24 hours after the subscription begins, or you have used at least 5GB of data transfer for such VoyraCloud Service, you are eligible for a pro-rated refund of the unused portion of the service based on the remaining unused period of the billing cycle or the remaining unused transferred data volume (whichever is lower), less a handling fee;

c) If you have prepaid for VoyraCloud Services before the billing period, you are entitled to a refund of the prepaid fees less a handling fee; and

d) If, after VoyraCloud cancels an invoice issued to you for VoyraCloud Services, you have already paid the fees for such VoyraCloud Services, you are eligible for a full refund of the paid fees for such VoyraCloud Services, provided that you have not used any such VoyraCloud Services.

6.14 Notwithstanding Section 6.13, you are not entitled or eligible for a refund in the following circumstances:

a) In VoyraCloud's sole opinion, you or your End User may have violated or has violated these Terms;

b) The relevant VoyraCloud Service has been marked as non-refundable, or VoyraCloud has otherwise indicated to you before you ordered the VoyraCloud Service that no refund is provided;

c) The billing period for which you wish to apply for a refund has ended, regardless of whether you used the VoyraCloud Service;

d) For the portion of an order cycle exceeding one month, you will only be entitled to a discretionary refund within one month;

e) The VoyraCloud Service you ordered or seek a refund for has not been paid, or you have not fully settled any amounts owed to us;

f) The third-party processing provider is unable to provide you with a refund for any reason whatsoever;

g) Your refund request is accepted and/or submitted to the third-party payment processing provider after the refund time limit specified by the third-party processing provider has ended; and

h) When you purchased the VoyraCloud Service, a promotional code, free credit or other discount was applied.

6.15 For each refund application, VoyraCloud will charge a handling fee of 10% of the approved refund amount.

6.16 VoyraCloud reserves the right to reject your refund application (for example, when the refund amount is lower than the minimum refund amount required by the third-party processing provider), to modify and interpret the refund terms and conditions, to refund fees to you through other channels or provide other forms of compensation as an alternative to a refund, and to determine at its sole discretion at any time all matters arising out of or related to a refund application (including but not limited to the method, mode and calculation of the refund), without any reason.

6.17 Account Balance Policy

a) Account balances are only used to pay for VoyraCloud services and cannot be directly withdrawn or transferred to other accounts.

b) All recharge payments are final and refunds are not provided in principle.

c) In special circumstances (such as payment errors, new user misoperations, account anomalies, etc.), you may apply for a refund by submitting a support ticket. We will review each case individually, and refund applications are not guaranteed to be approved and may deduct consumed amounts and handling fees.

d) Promotional gift balances and expired balances are non-refundable.

e) After closing or deleting an account, any remaining balance will automatically become invalid and cannot be recovered.

7. Term, Account Termination or Suspension, Effects of Termination

7.1 These Terms take effect from the date VoyraCloud sends you a notice under these Terms indicating that you have successfully activated your account.

7.2 Without prejudice to its rights and remedies at law or in equity (including but not limited to the rights and remedies set out in these Terms), if, in VoyraCloud's sole opinion, you or your End User have engaged (or may engage) in any of the following, VoyraCloud may suspend or terminate your account and your access to the VoyraCloud Services, or restrict or limit your rights (including your rights of access or use) to your account, the VoyraCloud Platform or the VoyraCloud Services, or terminate these Terms with you, or take any action VoyraCloud deems appropriate:

a) Breach of the Terms;

b) Using the VoyraCloud Services in a manner that poses a security or system stability risk to the VoyraCloud Platform or any third party, or that disrupts or denies any service to any customer (including by attracting DoS or DDoS attacks);

c) Using the VoyraCloud Services in a manner that causes or will cause VoyraCloud or our affiliates to incur liability;

d) Using the VoyraCloud Services to continuously consume computing, storage or network resources in a manner that violates the "fair use" principle;

e) Fraud, deception or unlawful conduct;

f) Any conduct that violates the law or infringes or misappropriates the rights of any third party; or

g) Becoming the subject of any bankruptcy, reorganization, liquidation, dissolution or similar proceeding.

7.3 If VoyraCloud suspends your use of your account or any VoyraCloud Service, you shall remain liable for any and all fees and charges incurred by you for the VoyraCloud Services up to the date of service suspension. You shall be liable for the fees and charges of the VoyraCloud Services you continue to be entitled to access or use.

7.4 Upon termination of your service or account, your rights under any license granted to you by VoyraCloud in connection with your use of the VoyraCloud Services will immediately terminate.

7.5 You have the right to terminate this Agreement at any time by terminating the relevant VoyraCloud Services on the VoyraCloud Platform. If you terminate the VoyraCloud Services, you must pay for the VoyraCloud Services provided by VoyraCloud up to the termination of the VoyraCloud Services.

7.6 If these Terms are terminated for any reason, or your use of your account or any VoyraCloud Service is terminated:

a) You shall delete any information, text, images, graphics, video clips, sound, directories, files, databases or listings, etc. that you possess and that were made available to you through the VoyraCloud Services;

b) You will lose access to any Member Content you have provided to VoyraCloud, and VoyraCloud may, at its discretion, delete such Member Content, unless retention is required by applicable law;

c) Notwithstanding the foregoing suspension or termination, the license you grant to VoyraCloud to use your Member Content (as described in Section 4.3) will continue; and

d) Any provision that is reasonably implied to survive termination of these Terms shall survive the expiration or termination of these Terms. Without limiting the generality of the foregoing, Sections 4, 5, 7, 8, 9, 10 and 12 shall survive termination of these Terms.

8. Representations and Warranties

8.1 You represent and warrant that:

a) You, your End Users or your licensors own any and all rights, title and interest in the Member Content;

b) You own all rights in the Member Content necessary to grant VoyraCloud the rights it enjoys under these Terms, and all information and Member Content you provide to VoyraCloud is true, accurate, correct, complete and not deceptive, fraudulent or misleading;

c) None of your Member Content will violate these Terms or any applicable law or the rights of any other third party (including any intellectual property rights);

d) You have the right to perform these Terms and to be legally bound by these Terms;

e) You have the right to operate your account on the VoyraCloud Platform; and

f) You have the right to use, purchase or subscribe to the VoyraCloud Services.

9. Indemnification

9.1 You hereby agree to defend, indemnify and hold harmless VoyraCloud, our respective affiliates and licensors, and each director, officer, employee, agent, contractor and representative of VoyraCloud, its affiliates and licensors, from all losses, damages, claims, liabilities, costs (including legal costs on a full indemnity basis) and expenses (including reasonable attorney's fees):

a) Arising directly or indirectly out of your use of the VoyraCloud Services (including but not limited to displaying your information on the VoyraCloud Platform, submitting unlawful material to the relevant ancillary features of the VoyraCloud Platform or any service, etc.) or out of your breach of any of the Terms;

b) That may arise directly or indirectly out of, or in connection with, any claim by any third party regarding you and/or your End Users:

i) Use of the VoyraCloud Services;

ii) Submission of unlawful material to the VoyraCloud Platform or the relevant ancillary features of any VoyraCloud Service;

iii) Breach of the Terms;

iv) Breach of any applicable law;

v) Alleged infringement (including infringement of any intellectual property rights) or misappropriation of the third-party rights of any Member Content, or infringement of third-party rights through the use, development, design, advertising or marketing of Member Content; and/or

vi) Any dispute between you, your End Users and/or other third parties.

9.2 You acknowledge and agree that sharing your account with others, or allowing multiple users other than you or your business entity to use your account, will cause irreparable harm to VoyraCloud, and you shall indemnify VoyraCloud for any loss or damage (including but not limited to loss of profits) suffered by VoyraCloud as a result of such sharing of your account.

9.3 You further agree that VoyraCloud is not responsible or liable to you, your users, End Users or any third party for any material posted or submitted by others (including defamatory, offensive or unlawful material), and the risk of damage caused by such material rests entirely with you. VoyraCloud reserves the right to exclusively defend and control any matter for which you are required to indemnify, in which case you shall cooperate with VoyraCloud in asserting any available defenses, and indemnify and hold VoyraCloud harmless from the reasonable legal costs incurred by VoyraCloud in connection therewith. To the maximum extent permitted by applicable law, VoyraCloud shall not be liable to you, your users, End Users or any third party for any special, direct, indirect, punitive, incidental or consequential damages or any damages (including but not limited to damages for loss of profits or savings, business interruption or loss of information), whether in contract, negligence, tort, equity or otherwise, or any other damage caused by any of the following:

(a) Your use of or inability to use the VoyraCloud Services (whether due to interruption, change or termination of the VoyraCloud Services or otherwise); any delay, inaccuracy, error or omission in any communication, transmission or delivery of all or part of the VoyraCloud Services; or any defect in goods, samples, data, information or services purchased or obtained through the VoyraCloud Services from you or any other third party;

(b) Your infringement of the rights of any third party, or any claim made against you by any party entitled to defend or indemnify against the assertion, demand or claim of the rights of any third-party claimant;

(c) Unauthorized access by a third party to your account, login credential data or private information, or your, your employees', agents', affiliates' or representatives' failure to comply with Section 2.3;

(d) Your statements or conduct; or

(e) Any matter related to the service, howsoever arising, including negligence.

9.4 VoyraCloud will promptly notify you of any claim related to the foregoing, but VoyraCloud's failure to notify you will affect your foregoing obligations only to the extent that our failure to notify you prejudices your ability to defend the claim. VoyraCloud reserves the right to control the defense and settlement of a claim at any time.

9.5 The limitations and exclusions of your liability under these Terms shall apply to the maximum extent permitted by law, and shall apply whether or not VoyraCloud has been advised of or should have been aware of the possibility of such loss occurring.

10. Disclaimer and Limitation of Liability

10.1 To the maximum extent permitted by applicable law, the VoyraCloud Services are provided on an "as is", "as available" and "with all faults" basis, and VoyraCloud hereby expressly disclaims any and all express, implied or statutory warranties, including but not limited to any warranties regarding condition, quality, durability, performance, accuracy, reliability, merchantability or fitness for a particular purpose and non-infringement, any warranties arising from a course of dealing, usage or trade, any warranties regarding availability, accuracy, error rate, system integrity, uninterrupted access, or any warranties that the VoyraCloud Services will be uninterrupted, error-free, free of harmful components, secure, or will not cause damage or loss of functionality or data.

10.2 To the maximum extent permitted by applicable law, (A) VoyraCloud makes no representation or warranty as to the validity, accuracy, reliability, quality, stability, completeness or timeliness of any information provided on or through the VoyraCloud Platform; and (B) in no event shall VoyraCloud be liable to you or any third party for any inability to use the VoyraCloud Services due to your use of the VoyraCloud Services (whether caused by interruption, change or termination of the VoyraCloud Services or otherwise), or any delay, inaccuracy, error or omission arising from all or part of any communication, transmission or delivery, or any damage (direct, indirect, consequential or otherwise) arising from the use of or inability to use the VoyraCloud Services.

10.3 VoyraCloud does not represent or warrant that the manufacture, import, export, distribution, provision, display, purchase, sale and/or use of products or services provided or displayed through the VoyraCloud Services does not infringe the rights of any third party; and VoyraCloud makes no representation or warranty of any kind regarding any product or service provided or displayed through the VoyraCloud Services. Any material downloaded or otherwise obtained through the VoyraCloud Services is at your own discretion and risk, and you shall be solely responsible for any damage to the VoyraCloud Platform or loss of data resulting from downloading any such material. No advice or information (whether oral or written) obtained by you from VoyraCloud or through the VoyraCloud Services constitutes any warranty not expressly stated herein. Except for any warranties, representations, conditions and undertakings of VoyraCloud expressly set out in these Terms, VoyraCloud hereby excludes all other express or implied warranties, representations, conditions and undertakings, to the maximum extent permitted by applicable law.

10.4 The VoyraCloud Platform may provide you, on a pass-through basis, with services or products provided by independent third parties. We make no warranty or representation regarding such services or products. In no event shall VoyraCloud and its affiliates be liable for any such services or products.

10.5 VoyraCloud shall not be liable for any special, indirect, punitive, incidental or consequential damages or any damages (including but not limited to damages for loss of profits or savings, business interruption or loss of information), whether in contract, negligence, tort or otherwise, or any other damage caused by any of the following:

a) The use of or inability to use the VoyraCloud Services;

b) Any defect in goods, samples, data, information or services purchased or obtained from third-party service providers through the VoyraCloud Platform;

c) Unauthorized access by a third party to your data or private information;

d) The statements or conduct of any user of the VoyraCloud Platform; or

e) Any other matter related to the VoyraCloud Services, howsoever arising, including negligence.

10.6 Except for any warranties, representations, conditions and undertakings of VoyraCloud expressly set out in these Terms, VoyraCloud hereby excludes all other express or implied warranties, representations, conditions and undertakings, to the maximum extent permitted by applicable law. Notwithstanding anything to the contrary in these Terms, unless VoyraCloud provides otherwise in other applicable terms, the total liability of VoyraCloud, our employees, agents, affiliates, representatives or any person acting on their behalf for any and all claims arising out of or related to the VoyraCloud Services or the VoyraCloud Platform or the use or inability to use them, if not otherwise excluded or limited, shall in aggregate be limited to the greater of: (a) the amount of fees you paid to VoyraCloud or our affiliates for the VoyraCloud Services within the calendar year, or (b) US$100, or (c) the amount provided in the terms related to your use of the specific VoyraCloud Service. The preceding sentence does not exclude the requirement that you prove actual damages. All claims against VoyraCloud with respect to any matter described in this Section 10.6 must be brought within one (1) year from the date the cause of action arises.

11. Notices

11.1 We may provide you with notices under these Terms by posting a notice on the VoyraCloud Platform or by sending an email to your account. Notices will be deemed effective upon posting, and email notices will be deemed effective upon the email being sent.

12. General Provisions

12.1 These Terms constitute the entire agreement between you and VoyraCloud regarding the use of the VoyraCloud Services and govern such services, superseding any prior written or oral agreements on the same subject matter.

12.2 VoyraCloud may modify these Terms and any of their appendices from time to time by posting updates on the VoyraCloud Platform or otherwise notifying you in accordance with Section 11.1 of this Agreement. Unless VoyraCloud provides otherwise, material changes to this Agreement, these Terms and any of their appendices will take effect 15 days after posting, unless the changes apply to new VoyraCloud Services, new features or to comply with applicable law, in which case the changes will take effect immediately or on the date specified by VoyraCloud. Continuing to use the relevant product or service after VoyraCloud posts such changes constitutes your agreement to be bound by the revised and restated Terms.

12.3 VoyraCloud has the final right to interpret these Terms. You agree and acknowledge that our interpretation of these Terms is final and binding on you.

12.4 VoyraCloud may assign and/or transfer any part or all of these Terms (including any of our rights, title, interests and benefits, as well as obligations and duties, under these Terms) to any individual or entity (including any affiliate of VoyraCloud). VoyraCloud may effect such assignment of these Terms or any part thereof by giving you written notice (which may be posted on the VoyraCloud Platform), and you hereby irrevocably agree and acknowledge any such assignment, whereupon VoyraCloud will be released from all its obligations under these Terms and from all claims, actions and demands arising under these Terms as of the time of such assignment.

12.5 You may not delegate, assign, novate, sublicense or subcontract any or all of your rights and/or obligations under these Terms to any individual or entity without our prior written consent.

12.6 These Terms are not intended to and do not create any agency, partnership, joint venture, employee-employer or franchisor-franchisee relationship between you and VoyraCloud.

12.7 If any provision of this Agreement is held by a court or tribunal of competent jurisdiction to be invalid or unenforceable, the validity or enforceability of the remaining provisions of this Agreement shall remain in full force and effect.

12.8 VoyraCloud's failure to enforce any right under these Terms or to take action against any breach by you does not constitute a waiver of that right, nor a waiver of VoyraCloud's right to take action against subsequent or similar breaches.

12.9 Unless a right or remedy of you or VoyraCloud is expressly stated to be an exclusive right or remedy, the exercise of that right or remedy by either party shall not affect either party's other rights and remedies at law and/or in equity.

12.10 You shall take and perform, or cause to be taken and performed, all further acts, deeds, matters and documents necessary to give effect to these Terms.

12.11 Except for VoyraCloud and our affiliates, no person who is not a party to this Agreement has the right to enforce any term of this Agreement under the Contracts (Rights of Third Parties) Act (Chapter 53B) (Revised Edition 2002).

12.12 Unless otherwise provided in the terms and conditions of the relevant VoyraCloud service, in no event shall VoyraCloud be liable for any delay, failure or interruption in the delivery of content or services through VoyraCloud platform (including VoyraCloud services), such delay, failure or interruption being directly or indirectly caused by natural disasters, forces or causes beyond our reasonable control, including but not limited to internet failures, computer failures, computer viruses, cyber attacks, telecommunications or any other equipment failures, power failures, strikes, labor disputes, riots, uprisings, civil unrest, labor or material shortages, fires, floods, storms, explosions, natural disasters, wars, government actions, orders of domestic or foreign courts or tribunals, or non-performance by third parties.

12.13 To the extent that you receive or possess any non-public or confidential information from us, you agree to maintain strict confidentiality of such information and not to disclose or use such information unless it is related to your use of VoyraCloud services as permitted by these terms or separately authorized by us in signed writing.

12.14 This Agreement is governed by Singapore law, without regard to its conflict of law provisions. The parties to these terms hereby submit to the exclusive jurisdiction of the courts of Singapore.

VoyraCloud (Singapore) Private Limited

Singapore

Privacy Policy

This Privacy Policy applies to access and use of the VoyraCloud website currently located at https://www.voyracloud.com/ ("VoyraCloud Platform"), and the use of VoyraCloud products and services ("Cloud Services") provided by VoyraCloud (Singapore) Private Limited (hereinafter referred to as "we" or "our") by registered users of the VoyraCloud Platform. Terms not defined in this Privacy Policy shall have the same meaning as in our Terms and Conditions.

This Privacy Policy sets out how we collect, use, transmit, retain, protect and disclose your personal data and/or personal data about your customers or end users that you provide to us when using the VoyraCloud Platform and/or our Cloud Services, and other terms related to data location. It also describes your choices regarding the use, access and correction of your personal data.

Many of the cloud services we provide through the VoyraCloud Platform are for personal use. If you are an organization and register an account using an organizational email address and purchase or use our cloud services, the owner of the domain associated with the organizational email address and/or your organization may monitor or control your account on the VoyraCloud Platform and access, process and/or control your personal data as well as the content of your communications and files. Your organization's use of our cloud services may be subject to the organization's own rules or policies, and you should direct all privacy inquiries related to such rules or policies directly to your organization's administrator. We are not responsible for your organization's privacy or security practices.

Our customers (i.e., registered users of the VoyraCloud Platform) may use cloud services to develop or host their own services and products for their end users. In such cases, any information collected or processed by VoyraCloud is processed on behalf of our customers, and customers control the collection and use of such information. We have no direct relationship with our customers' end users. In such cases, end users should direct all privacy inquiries (such as any request to access, correct, modify or delete personal data) directly to the VoyraCloud customer providing their service or product. We are not responsible for our customers' privacy or security incidents.

A. Collection of Personal Information

• If you are (i) an individual or (ii) a representative of a business organization when registering as a user of the VoyraCloud Platform and/or purchasing cloud services, you may be required to fill out a registration form that requires you to provide information such as email address, country/region, name, contact address, etc. You may also provide us with other optional contact information in your account profile, such as the account's email address and other contact phone numbers.
• When you use the VoyraCloud Platform and/or certain cloud services for legal and/or business purposes, we record details of your activities (including purchases or use of our products and services). If you make purchases through the VoyraCloud Platform or otherwise transact online, we also collect information related to such transactions, including but not limited to the type and specifications of cloud services, pricing information, and any trade dispute/complaint records.
• When you contact our customer support, sales or other departments, we may record communications for security and customer service purposes and collect other information to verify your identity.
• If you purchase our cloud services online through the VoyraCloud Platform, you may need to provide information related to your payment instrument (such as a credit card) directly to our payment service provider, including information about your payment instrument organization, your payment instrument number, security code and the expiration date of your payment instrument.
• Please note that certain categories of data are necessary for us to provide cloud services, such as username (which should be an email address) and email address. These categories will be specified at the time of collection. If you do not provide any or sufficient data marked as required, we may not be able to complete the registration process or provide our cloud services to you.
• We also record users' purchasing and browsing activities on the VoyraCloud Platform, including but not limited to Internet Protocol ("IP") addresses, browsing patterns and purchasing patterns. Additionally, we automatically collect statistical information about our VoyraCloud Platform and VoyraCloud Platform visitors, including but not limited to IP addresses, browser software, operating systems, software and hardware attributes, pages browsed, session counts and unique visitors.
• We may collect other information from you from time to time (such as copies of identity documents) and obtain information about you from third parties for risk control, fraud prevention and compliance procedures. For example, we may collect payment-related information from third parties and combine it with information we collect about you for fraud prevention and risk control purposes.
• VoyraCloud is only a controller of personal data when collecting personal data and determining the purpose and method of processing such personal data. For example, when our cloud service customers register accounts with us or provide contact information for customer support, we are the controller of such data. When customers host their own services on our cloud services or store personal data of their end users, we act as a data processor for such data.

B. Purposes for Collecting, Retaining, Using, Disclosing and Transmitting Personal Data

We collect, retain, use and disclose your personal information for the following purposes:

• Process your registration as a user and maintain and manage your registration;
• Provide you with customer service and respond to your questions, feedback, claims or disputes;
• Provide cloud services to you and/or your end users;
• Process your purchase and/or subscription to cloud services;
• Personalize our communications with you based on your order history and conduct research or statistical analysis to improve our products and services;
• Publish any information you voluntarily submit (which may include but not be limited to photos or other personal data you provide) to our VoyraCloud Platform and publish on our VoyraCloud Platform through publishing tools (such as our discussion forums);
• To comply with applicable laws, legal procedures or legitimate government requirements, or for any claims or potential claims against us or our parent company, shareholders, subsidiaries and affiliates;
• Perform risk control, legal compliance and sanctions screening; and
• Conduct screening and inspection for illegal, fraudulent, deceptive or malicious activities.
• With your specific consent (or as otherwise permitted by applicable law in your jurisdiction), we may use your name and email address to provide you with notifications, surveys, product alerts, related communications and other marketing and promotional materials related to goods and services we provide on the VoyraCloud Platform.

Legal Basis for User Processing

The legal basis for our processing of your personal data includes the following processing: necessary for the performance of the contract between you and VoyraCloud (e.g., providing you with the cloud services you request and identifying and verifying your identity so you can use the website or cloud services); necessary for compliance with legal requirements (e.g., complying with applicable accounting rules and mandatory disclosures to law enforcement); necessary for the pursuit of our legitimate interests (e.g., managing our relationship with you and improving our services); and based on your consent (e.g., communicating with you about our products and services and providing you with marketing information), which consent may be withdrawn at any time thereafter without affecting the legality of processing based on consent prior to withdrawal. You may contact us at voyracloud@gmail.com to withdraw any consent.

C. Disclosure of Personal Information

• We may disclose your personal data to third-party service providers we engage to assist in providing our services to you (including providing customer service to you, contacting you about promotional products and services, performing risk control, fraud prevention and legal compliance procedures and conducting payment processing services) ("Third-Party Service Providers"). Such third-party service providers may be located in Singapore or outside Singapore and are engaged on terms that comply with applicable data protection laws and/or impose appropriate confidentiality obligations on us, and are only permitted to use your personal data for purposes related to the purposes specified in section B above, and not for their own purposes. Such third-party service providers may further subcontract certain components of the services they provide to us to other service providers. These other service providers may also be located in Singapore or outside Singapore and are subject to confidentiality obligations to our third-party service providers, and are only permitted to use your personal data for purposes related to the purposes specified in section B above, and not for their own purposes.
• We may share your personal data with our affiliates and/or their designated service providers to achieve the purposes specified in section B above. We have entered into appropriate agreements with our affiliates to share your personal data and/or outsource the processing of your personal data to affiliates. Our affiliates' designated service providers (and their sub-processors, if any) will be engaged on terms that comply with applicable laws and appropriate confidentiality obligations, and are only permitted to use your personal data for the purposes specified in section B of the Privacy Policy.
• We may provide aggregated or anonymized data to third parties, but when we do so, the information we share is in de-identified format and will not identify you personally.
• We have and will continue to establish relationships with other parties and websites to provide you with the benefits of their products and services. We provide you with access to these other parties and their websites through hyperlinks from our VoyraCloud Platform. In some cases, you may need to submit personal data to register or apply for products or services offered by such third parties or co-branded partners. This Privacy Policy does not apply to these third-party websites or co-branded websites. These other parties' privacy policies may differ from ours, and we have no control over the information you submit to these third parties. Before responding to any offers, products or services advertised by these parties, you should read the relevant privacy policies of these third-party websites and co-branded websites.

D. Transfer of Personal Information

• As part of providing cloud services to you, we may need to transfer your personal data from your jurisdiction to overseas jurisdictions. Data recipients in these jurisdictions may be subject to data privacy laws that provide a lower level of protection than or are not equivalent to the laws in your jurisdiction. Such overseas transfers or processing of your personal data may be necessary for processing and managing your customer account and providing cloud services (including providing customer service to you, contacting you about promotions, products and services, performing risk control, fraud prevention and legal compliance procedures and conducting payment processing services).
• You may decide where to store your member content (as defined in our Terms and Conditions) ("Designated Region"). You agree to store your member content in the designated region and transfer your member content to the designated region. Unless otherwise agreed in writing between you and us, you agree that we may at our discretion transfer and store your data in other geographic regions or jurisdictions. You declare and warrant that such storage and transfer have been fully consented to by you and are permitted under applicable laws, regulations, rules and third-party rights.
• These terms only apply if you are located in Singapore, the European Economic Area, the United Kingdom or Europe (but outside the European Economic Area). If you are located in Singapore, we will take reasonable necessary measures to ensure that your personal data continues to receive protection at least equivalent to the protection standards provided by Singapore privacy laws. Our business may require us to transfer your personal data to countries/regions outside Singapore, the European Economic Area or the United Kingdom, including countries/regions that may not provide the same level of data protection as your country/region. We strive to take appropriate measures to ensure adequate levels of protection for your personal data, such as entering into written agreements with recipients, including standard contractual clauses, binding corporate rules and other data protection agreements. If you believe that our processing of your personal data violates applicable laws, you may file a complaint with the supervisory authority.

E. Security Measures

• We use commercially reasonable efforts to protect the personal data you provide to us. We have also adopted various security technologies, including but not limited to the use of industry-standard Transport Layer Security (TLS) encryption to transmit personal data in registration information and payment information, and the adoption of identity, credential and access management measures to transmit such personal data to prevent security breaches and unauthorized access to personal data. We restrict access to your personal data and other data to only those personnel who need access to such data to perform their work.
• However, data transmission over the internet or any wireless network cannot guarantee absolute security. Therefore, while we strive to protect your personal data, we cannot guarantee the security of any personal data you transmit to us, and you do so at your own risk. We cannot and will not guarantee your security when using the VoyraCloud Platform and our cloud services.
• We will retain your personal data as long as you have an account with us to provide you with services or products, resolve disputes, for research and statistical analysis purposes, or as required or permitted by applicable laws (such as tax laws and accounting laws).

F. Retention and Processing Period of Personal Information

• We retain your personal data for the purposes described in this Privacy Policy when we have an ongoing legitimate business need (such as providing you with the services you request or complying with applicable legal, tax or accounting requirements). In some cases, after our relationship ends, we need to retain your personal data for legal reasons. The specific retention period depends on the nature of the personal data, the reason for collecting and processing the personal data, and the nature of the legal requirements.
• When we have no ongoing legitimate business need or legal reason to process your personal data, we will delete or anonymize your personal data, or, if this is not possible, we will securely store your personal data and isolate it from any further processing until it can be deleted.

G. Process and Methods for Destruction of Personal Information

VoyraCloud will delete your personal data as described in section F of this Privacy Policy. When deleting personal data, we will take standard commercially reasonable measures to make the personal data practically unrecoverable or non-reproducible. The specific method of deletion depends on the data being deleted, how the data was collected and stored, and your interactions with us. Electronic documents or files containing personal data will be deleted using technical methods that make recovery or retrieval of such information practically impossible or make the data no longer personally identifiable. Non-electronic documents or files containing personal data will be shredded, incinerated, or both.

H. Rights to Access/Correct Personal Data; Contact Us

• You have the right to request access to your personal data held by us (or on our behalf) and request correction or deletion of such personal data. Additionally, upon request, we will provide you with information about whether we hold your personal data. You may contact us at voyracloud@gmail.com to request access, correction or deletion of your personal data. We will respond to your request within a reasonable time. Under applicable law, you may also have supplementary rights related to your personal data. For example, if you are an EEA or UK user, you have the right to object to or request restriction of processing of your personal data, and contact us at voyracloud@gmail.com to request data portability.
• In cases where we act as a processor, we have no direct relationship with individuals whose personal data we process. Individuals seeking access or seeking correction, modification or deletion of inaccurate data should submit their inquiries to VoyraCloud customers (data controllers).
• You may receive electronic communications from us. If you wish to stop receiving this information, you may update your email preferences using the "unsubscribe" link in the emails we send you or in your member profile.
• We do not knowingly collect personal data from minors (persons under 18 years of age). If a minor provides us with personal data, their parent or guardian may contact us on behalf of the minor to request that we stop further collection, use and/or disclosure of personal data and delete any personal data we may hold related to the relevant minor.
• If you have any questions about this Privacy Policy, or if you wish to exercise any rights or other rights you may have under applicable law related to your personal data, you may send us a request in writing at voyracloud@gmail.com.

I. Cookies

• We and our partners use "cookies" and/or similar technologies, such as web beacons and javascript, to store specific information about you and track your visits to our VoyraCloud Platform. We may also use "cookies" to store specific information about your use of certain cloud services as part of their functionality and facilitate or enhance your user experience with the relevant services. A "cookie" is a small amount of data sent to your browser and stored on your device. Cookies are only sent to your device when you use the device to access our VoyraCloud Platform. If you do not disable or delete cookies, each time you use the same device to access our VoyraCloud Platform, our web vps will receive notification of your visit to our VoyraCloud Platform, and in turn we may learn about your visit and usage patterns.
• Generally, we use cookies to identify you and enable us to i) access your registration information so you don't have to re-enter it; ii) collect statistical information about user usage; iii) study visit patterns and help target advertisements based on user interests; iv) assist our partners in tracking user visits to the VoyraCloud Platform and processing orders; v) track the progress and participation of promotional activities; vi) track purchases and orders to manage our affiliate programs; and vii) facilitate your use of any relevant cloud services that may involve the use of cookies. We may partner with third parties to manage our advertising on other websites. Our third-party partners may use cookies and/or similar technologies to provide you with advertisements based on your browsing activities and interests.
• You can determine whether and how to accept cookies by configuring the browser installed on the computer you use to access the VoyraCloud Platform. You can change these configurations if you wish. You can change browser preferences or settings to reject all cookies, or choose to consent each time a cookie is sent. If you reject all cookies by selecting the cookie disable function in your browser, you may need to re-enter information on our VoyraCloud Platform more frequently, and certain features of our VoyraCloud Platform may not be available.
• By accessing and using our VoyraCloud Platform and/or cloud services and accepting cookies, you consent to the storage of cookies on your device. You also consent to us and the above-mentioned partners accessing such cookies.

J. Changes to This Privacy Policy

This Privacy Policy may be modified from time to time, so please check it frequently. We will communicate any changes to this Privacy Policy by posting the revised Privacy Policy on our VoyraCloud Platform. The new Privacy Policy will take effect immediately upon posting on the VoyraCloud Platform, or on the date specified by VoyraCloud. We may also provide you with notice of any changes to the Privacy Policy at our discretion. If we make any material changes, we will notify you by email (sent to the email address specified in your account) or through notices on this website before the changes take effect. Any information and/or personal data we hold about you (as described in this Privacy Policy, whether collected before or after the effective date of the revised and restated policy) will be subject to our latest version of the Privacy Policy. We strongly recommend that you visit the VoyraCloud Platform from time to time to view the Privacy Policy. Your continued use of the VoyraCloud Platform and/or cloud services constitutes your acceptance of changes to the Privacy Policy.