Privacy Policy

Communa is a Community Software as a Service ("SaaS") Platform ("Platform"), which is developed, owned and managed by Tvasan Technologies Pte. Ltd. ("TSG"), and which is available at https://www.communa.app/ ("Website"), and as a mobile application called Communa App ("App"). The Platform has been specially designed for member-organizations, collectively known as Professional Associations, Communities and Societies ("PACS"), including but not limited to: professional associations in medical, academic, and scientific fields; industry bodies across all sectors; government-backed social service agencies; trade associations; societies; professional communities such as alumni networks, special interest groups, and coaching/training groups; academic institutions like schools and colleges; and other purpose-driven organizations.

At Communa, we understand the paramount importance of the privacy and security of Your personal information and are dedicated towards maintaining transparency. We are committed towards upholding, protecting and securing the safety and security of Your personal information and its access, retention, usage, sharing, storage, deletion and any other permitted utilisation. This Privacy Policy explains how we collect, use, and disclose sensitive personal data or information attributable directly or indirectly to You, of any type, in any form or manner ("Personal Information") which has been disclosed on the Platform through our Website and App. This Privacy Policy also highlights the purposes of collection, manner of collection, any and every activity involving sharing and disclosure of Personal Information and how we undertake steps to ensure information security. Kindly go through this Privacy Policy and all documents which may be mentioned herein.

IMPORTANT NOTE: Usage of Communa is governed by this Privacy Policy and the Terms of Service. Undefined terminology in this Privacy Policy has the same meaning as in the Terms of Service.

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Introduction

• By using the Platform through Website or App, you explicitly consent to be bound by this Privacy Policy and all modified versions.
• Users are categorized as: Owners (PACS conducting activities) and Members (individuals participating in Communities)
• Owners use the Platform to conduct activities including member management, event organization, and course management
• Members join PACS and engage in organized activities
• Communa facilitates relationships between Owners and Members; Members are bound by Owner rules, Policies, and Platform Policies
• If conflict exists between Owner regulations and this Privacy Policy/Terms of Service, the latter prevail
• Visitors merely visit the Website without registering
• This Privacy Policy describes how the Platform obtains, stores, shares and uses Personal Information
• Capitalized words use the same meaning as in the Terms of Service

Governing Law

This Privacy Policy is drafted in compliance with Singapore's Personal Information Protection Act 2012 ("PDPA") and guidance from the Personal Information Protection Commission ("PDPC"). Non-Singapore users should review data protection laws in their territory.

Information We Collect and How We Use It

When you visit the Website, join/create a Community, interact through the Platform, or use the App, we collect Personal Information and other information ("Data"). We use your Personal Information to provide the Platform. Key points:

• Personal Information shared voluntarily
• Personal Information collected automatically when visiting the Website, using Platform or App
• We and Owners use your Personal Information to provide access, improve Platform, understand usage, and inform about products/services
• Data does not include your content or user-generated content — you retain ownership

Personal Information You Provide Directly

"Personal Information": Information relating to you from which you can be identified, directly or indirectly, including name, identification number, location, online identifier (IP address, device ID), or factors specific to your physical, physiological, genetic, mental, economic, cultural or social identity.

"Special Categories of Personal Information": Data revealing racial/ethnic origin, political opinions, religious/philosophical beliefs, trade union membership, health data, sex life or sexual orientation.

"Aggregated Data": Data in summary form for statistical analysis.

"Pseudonymisation": Processing Personal Information so it no longer identifies you without additional information kept separately.

Information Collected

• NAME AND ADDRESS: Real name and email address required at registration; both Communa and Owner receive access; used for communication; mailing address and zip code collected for paying Owners/Members for billing purposes
• SOCIAL MEDIA PROFILES: Can register with Google or Microsoft account; grants permission to access profile and photo, which becomes part of Community profile
• PROFILES AND TOPICS: Prompted to add profile with bio and choose topics to follow; customizable by Owner including special categories of Personal Information
• YOUR LOCATION: Collected to facilitate geographic interactions; optional GPS location collection in mobile app; other Members may see location if enabled
• OTHER PERSONAL INFORMATION: May be provided when using features like participating in conversations, polls, contacting support, responding to surveys; shared voiced comments and facial images if participating in recorded livestreams/events

Personal Information and Information We Collect Automatically

• INFORMATION ABOUT YOUR USE: Servers automatically record visits; compiles logs with date, time, browser, device type, operating system, and originating IP address
• COOKIES: Used to collect information about visits; text files placed on your computer recording standard log information and visitor behavior; collects: previous websites/ads visited, pages visited, time spent on Platform sections, search requests/results; used for tracking usage, measuring unique visitors, understanding Member acquisition, improving Platform; sometimes hashed data (email addresses) used instead of cookies to measure advertising effectiveness; mobile apps on iOS and Android interact with servers; device token assigned to avoid repeated login; you can refuse cookies but some Platform features may not work properly
• INFORMATION ABOUT YOUR LOCATION: IP address reveals general location (city); location initially chosen based on Internet connection IP; can be updated/removed anytime via account login

Personal Information and Information Collected Automatically by Third Parties

• THIRD PARTY COOKIES FOR SITE USE ANALYTICS: Google Analytics used; Google uses cookies recognized by Google/DoubleClick on other websites; details available at https://www.google.com/policies/privacy/partners/
• THIRD PARTY COOKIES TO TARGET OWNER ADS: "Beacons" (transparent pixel images) used for collecting website usage information across websites/time; Owners use own or Third-Party cookies/beacons to target ads when visiting other websites; works with companies using cookies/beacons for targeted ads based on prior visits (online behavioral advertising/"OBA"); Communa has no access to these cookies
• THIRD PARTY COOKIES TO TARGET COMMUNA ADS: Works with Third Parties to serve ads about Platform through third-party operated websites/platforms/services, often targeted at Visitors/Members

Our Sharing of Your Personal Information and Other Information

Personalizing your Communa experience is important; understanding what Personal Information is shared is essential.

"Third Party": Person/company/entity not an Owner/Member; includes government bodies/agencies/authorities; includes service providers authorized through data processing agreements to help with development, maintenance, support of websites/mobile applications, marketing/advertising, research/analysis, communications, customer service; restricted from using Personal Information for other purposes.

"Processing"/"Process": Any operation performed on personal data including collecting, recording, organizing, structuring, storing, adapting, altering, retrieving, consulting, using, disclosing, transmitting, sharing, making available, aligning, combining, restricting, erasing, destroying.

"Consent"/"Agree": Freely given, specific, informed, unambiguous expression of wishes through statement or clear affirmative action (checking box).

Note: If above-mentioned sharing types are not permissible, we advise not using the Platform.

Personal Information Shared Within the Platform

• YOUR OWNER: Owner has access to name, email address, all personal/contact information provided at registration; accesses data regarding usage activity in aggregated and personally identifiable forms; can associate your content with contact information; may communicate outside Platform about Community; may retain personal information after you leave unless requested otherwise
• SEARCH AND MESSAGING BY OTHER: Visitors can search for you by name/location if you're a Member; Community Members can search by location/topics/other Personal Information for messaging; availability depends on Public/Private Community status
• PUBLIC COMMUNITIES: Visible in Communa's "Community Discovery"; Visitors can view limited public information but must adhere to regulations and gain approval to join/access full content
• PRIVATE COMMUNITIES: Accessible only via direct invitation/private link/website integration; complete access granted only upon approval (Public) or invitation (Private)
• PERSONAL INFORMATION INCLUDED IN YOUR CONTENT: If you include Personal Information in content, it displays to other Members based on defined privacy levels

Personal Information and Information Shared With Third Parties

• BUSINESS TRANSFERS: As business develops, may sell/buy businesses/assets; Personal Information may be part of transferred assets
• AGENTS, CONSULTANTS AND THIRD PARTIES WITH CONTRACTS: TSG hires companies for business functions; only provides necessary Personal Information; service providers not authorized to use/disclose Personal Information except as needed

Third Party Service Providers

• Amazon Web Services (Virtual Infrastructure)
• MongoDB Atlas (Data Platform)
• Apple (iOS mobile apps, notification, analytics)
• Google (Sign in; Email, Cloud File Storage, Analytics)
• Post Mark (Communication Delivery)
• Google Crashlytics (Error logging & alerts for mobile apps)
• Linear (Project Management)
• Zoho Desk (Internal Ticketing)
• Nucilino (Product documentation)

• LEGAL REQUIREMENTS: May disclose Personal Information if required by law or good faith belief such action is necessary to comply with legal obligation, cooperate with government/regulatory authority, protect TSG rights/property, protect safety/security of Platform users, prevent fraud, or act in urgent circumstances to protect personal safety
• AGGREGATED DATA SHARED: Disclose aggregated statistics to current/prospective business partners and Third-Party service providers for legitimate interests/lawful purposes

Your Personal Information Rights

You have rights regarding Personal Information we hold about you:

• May object to or restrict collection, use, sharing, transfer, storage of Personal Information
• May request copy of information we have about you
• May ask us to correct or remove incorrect Personal Information
• To extent Owner (data controller) processes your Personal Information, contact Owner; for help finding Owner's privacy officer contact dpo@communa.app
• If you have registered account, may object, restrict, access, correct, request deletion or copy by logging in
• If you don't have registered account and want to object, restrict, access, correct, delete, or request copy, email: dpo@communa.app or write to Tvasan Technologies Pte Ltd., 192 Waterloo Street, #05-03, Skyline, Singapore 187966
• We keep Personal Information as long as necessary to provide Platform; also keep to comply with laws including tax laws; keep for backup, archiving, audit, fraud prevention, dispute resolution, troubleshooting

Your Choices and Rights

• JOIN COMMUNA AND OWNERS YOU TRUST: You decide Communities to join and whether you trust the Owner with information sharing described in Policy
• PUBLIC OR PRIVATE COMMUNITY SETTINGS: Owner discretion to manage/change Community settings as Private/Public
• NOTIFICATION SETTINGS: Control frequency, type, mode of notifications received in account settings; choose email/mobile alerts/both/neither; turn on/off by type
• OPT OUT OF EMAIL: If agreed to marketing messages, may opt-out anytime; opt-out link at bottom of each email; may take weeks for opt-out to take effect
• MOBILE ADVERTISING ID CONTROLS: iOS and Android operating systems provide options to limit tracking/reset advertising IDs

Account Termination

You can leave Communities or delete Community accounts. Upon leaving, we stop collecting Personal Information for that Community.

Exclusions

• This Privacy Policy doesn't apply to Personal Information collected outside Platform (telephone calls)
• Doesn't apply to unsolicited information provided through Platform or other means such as public area posts, product ideas, modifications, submissions ("Unsolicited Information")
• All Unsolicited Information deemed non-confidential; TSG free to reproduce/use without limitation/attribution
• Copyrights in your content respected as outlined in Terms and Conditions

Disputes With Owners or Other Members

Communa cannot control Owner/Member actions; privacy disputes with them should contact them directly. Alert us at dpo@communa.app if Owner/Member violated this Privacy Policy or Terms and Conditions.

Children

• Communa does not knowingly collect Personal Information from children under 18
• If under 18, do not use Platform or submit Personal Information
• If reason to believe child under 13 provided Personal Information, contact dpo@communa.app for deletion

Links to Other Web Applications

This Privacy Policy applies only to Platform/Website/App. Platform may contain links to other websites not operated/controlled by TSG ("Third Party Sites"). Described policies don't apply to Third-Party Sites. Links don't imply TSG endorsement. Contact those sites directly for their Privacy Policies/practices.

Security of Your Personal Information

• Use appropriate technical/organizational measures including encryption, aggregation, pseudonymization to protect Personal Information from loss, misuse, unauthorized access/use, disclosure, alteration, destruction
• No Internet/email/electronic transmission 100% secure/error-free; cannot guarantee Personal Information never accessed/used/disclosed
• "Phishing" is an online cyber scam stealing Personal Information; if you receive a suspicious email claiming Communa affiliation asking for information, contact dpo@communa.app

Your State Privacy Rights and Additional Details

If resident of non-Singapore jurisdiction where Platform offered, TSG takes relevant steps ensuring compliance with local privacy laws. Encourage familiarity with jurisdiction's privacy laws/regulations. If you receive a suspicious email, contact dpo@communa.app.

Access to Information and Contact Us

To keep Personal Information accurate, current, complete, update account settings or contact us. We take reasonable steps to update/correct Personal Information previously submitted.

Contact for Privacy Policy questions/information practices:

• Email: dpo@communa.app
• Postal: Tvasan Technologies Pte Ltd., 192 Waterloo Street, #05-03, Skyline, Singapore 187966

Changes to Communa's Privacy Policy

• Endeavor to regularly review Privacy Policy
• Will notify when making material changes
• Review periodically, especially before providing Personal Information
• Updates placed on Website/App

Conflicting Provisions in Owners' Privacy Policy

No liability/responsibility for upholding/managing/effectuating Owner privacy policies/practices enabled within Platform. If Owner Privacy Policy conflicts with Communa Privacy Policy, Communa's Privacy Policy prevails.