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 under it carefully. The Privacy Policy further informs You about Your rights and obligations, and how You can contact us regarding your queries about our privacy practices. 

IMPORTANT NOTE: Remember that in the course of Your usage of Communa, You are at all times governed by this Privacy Policy, while simultaneously being subject to the Terms of Service of the Platform. Any terminology used in this Privacy Policy that may not contain a specified definition within this Privacy Policy, shall be understood to have the same meaning as provided in the definition given to it in the Terms of Service.

 INTRODUCTION

1. By virtue of Your usage of the Platform through either the Website or through the App or both, You explicitly consent to be unconditionally, irrevocably and continuously bound by this Privacy Policy and all its subsequently modified versions. 

2. Users of the Website and the App have been categorised in 2 categories: Owners and Members. 

3. “Owners” are the PACS who, upon the due completion of the registration process described on the Platform, will use the Platform to conduct any activity(s) facilitated by the Platform for the Communities registered on the Platform, as well as for the individuals that are a part of such Communities, which broadly include member management, event organisation and management, inviting subscriptions, conducting paid courses and so on. 

4. “Members” are individuals who have joined the PACS, and who intend to join and use the Platform, upon completion of the registration process described on the Website and/or the App, to engage and participate in the PACS’ organised activities and gain access to the PACS’ provided resources. 

5. Communa is to be viewed as the Platform that facilitates the relationship between Owners and Members, hence Members are bound not only by the rules and Policies of the Owner, but also the Policies of the Platform. The Platform actively facilitates the relationship between an Owner and the Platform, a Member and the Platform and an Owner and a Member during the course of any Owners’ or Members’ interaction with the Platform at any time. Therefore, without prejudice to anything mentioned in this Privacy Policy, the Terms of Service or any other governing document or access and utilisation of the Platform, shall be bound unconditionally and irrevocably by the rules, regulations, Policies and other guidelines prescribed by the Owner with respect to its Members along with this Privacy Policy, the Terms of Service or any other governing document or law in force as outlined on the Platform. If there is any conflict between the regulations made by any Owner/PAC and this Privacy Policy and Terms of Service, this Privacy Policy and Terms of Service shall prevail. Individuals who merely visit the Website (without registering) at www.communa.app or visit a Community run by an Owner  (“Community”) are Visitors (but not Owners or Members). This Privacy Policy shall continue to be applicable to such Visitors to the extent specified hereunder. 

6. This Privacy Policy describes how the Platform obtains, stores, shares and uses Personal Information as well as other information about any Owner, Member or Visitor’s visits to or usage of our Website and App and their participation in a Community owned and operated by an Owner. Such Personal Information is used to offer a personalised experience to the users of the Website and the App. 

7. Unless explicitly defined under this Privacy Policy, capitalized words used herein shall have the same meaning as in the Terms of Service which also govern the usage of the Platform, the latest version of which is available at www.communa.app.

2. GOVERNING LAW

1. This Privacy Policy, Terms of Service and any other governing document endorsed by TSG and made available, applicable to the operation of the Platform/Website/App have been drafted and developed in compliance with Singapore’s data protection law, being the Personal Information Protection Act 2012 (“PDPA”) and any guidance, guideline, regulation or any other regulatory or advisory document issued by the Personal Information Protection Commission (“PDPC”).

2. For all intended users of the Platform/Website/App who are non-Singapore residents, i.e., who are users of Communa outside the territorial jurisdiction of Singapore, it is advised to read, understand and obtain necessary information regarding the data protection law regime of the particular territory within which such usage is taking place for additional conditions pertaining to collection and usage of Personal Information.

3. INFORMATION WE COLLECT AND HOW WE USE IT

1. When You visit our Website, join or create a Community, interact with us or Your Owner through the Platform, or use our App, we, as the Platform provider for Your Owner, collect Personal Information and other information from You (collectively, “Data”). We use Your Personal Information to be able to provide the Platform to You. Some things which You may note about this collection and usage of the Data are as follows:

1.  Personal Information shared voluntarily; 

2.  Personal Information collected automatically when You visit our Website, use the Platform or the App; 

3.  We and the Owners use Your Personal Information to provide access to and improve the Platform, understand how You and other Members are using Communa and to inform You about products and services that may be of interest to You; and

4.  Data does not include Your content or user generated content. As explained in our Terms of Service, You (and the people You license Your content from) keep complete ownership of all Your content. By posting Your content on the Platform, You grant us a license to use it, but You and Your licensors still own it.

4. PERSONAL INFORMATION YOU PROVIDE DIRECTLY

1. “Personal Information” means any information relating to You from which You can be identified, directly or indirectly, including Your name, identification number, location, online identifier such as Your IP address or device ID, or one or more factors specific to Your physical, physiological, genetic, mental, economic, cultural or social identity.

2. “Special Categories of Personal Information” means data revealing Your racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and data concerning Your health, sex life or sexual orientation.

3. “Aggregated Data” means data in a summary form for statistical analysis. A common purpose of aggregation is to get more information about particular groups based on specific variables such as age, profession, or income level.

4. “Pseudonymisation” means the processing of Your Personal Information in a way that such information can no longer identify You without the use of additional information, so long as the additional information is kept separately and is subject to technical and organizational measures to prevent You from being identified or identifiable. We store and use Your Personal Information together with an ID we assign each time You join a new Community. We assign You one ID per Community to ensure You have a personalized experience in each one. 

5. NAME AND ADDRESS: When You register as an Owner or Member of a Community, we ask You for Your real name and Your email address. Both we and the Owner of the Community receive access to this information and use it to communicate with You about the Platform. In addition, we and Your Owner may use this address to email You about products or services believed to be of interest to You. If You are a paying Owner or Member, we may also collect Your mailing address and zip code for billing purposes. Owners may decide to collect Your mailing address, via our Platform.

6. SOCIAL MEDIA PROFILES: You can also register on the Platform with Your Google or Microsoft account. When You register this way, You give us permission to access Your Google or Microsoft profile and photo. Your profile and photo will become part of Your Community profile. 

7. PROFILES AND TOPICS: When You join a Community, You will be prompted to add a profile, including a short bio, and to choose topics to follow (“Topics”). From this information, Communa personalizes Your experience in each Community. Your Owner can also choose and customize categories of Personal Information to collect from You including, if You agree, special categories of Personal Information.

8. YOUR LOCATION: We ask You for Your location so that we can facilitate interactions with other Members in Your geographic area. In addition, if You opt-in, our mobile app collects Your GPS location information. If You enable location features, or do not disable GPS on Your mobile device, other Members may be able to see Your location.

9. OTHER PERSONAL INFORMATION YOU PROVIDE DIRECTLY: You may also provide us Personal Information when You use certain features of the Platform such as participating in conversations or polls in Your Communities, contact us with inquiries, or respond to one of our surveys. When You agree to participate in a recorded livestream or other Community event, You share Your voiced comments and images of Your face on camera.

5. PERSONAL INFORMATION AND INFORMATION WE COLLECT AUTOMATICALLY 

1. INFORMATION ABOUT YOUR USE OF THE PLATFORM AND WEBSITE/APP: Our servers automatically record Your visits to the Platform and the Website/App. Like all other website and mobile app servers, ours compiles a log that records the date, time, browser (i.e., Firefox), device type (i.e., iPhone), operating system (i.e. Android), and originating IP address of each page Your visit.

2. COOKIES: We use cookies and other technologies to collect information about Your visits to our Website and Platform. Cookies are text files placed on Your computer by websites to collect standard log information and visitor behaviour information. Our cookies collect the following information about You: which website or ad You visited right before ours, which pages You visited on our Platform, and how much time You spent on each section of our Platform. We may also collect other data about Your visit, such as search requests and results. We use this information for our legitimate interests to track usage of our Platform, to measure the number of unique visitors to the different sections of our Platform, to understand how Members find and join Communa (ad effectiveness), and to help us make our Platform more valuable to every Owner and Member. The use of this information is called “analytics.” Often information used for analytics is aggregated.

3. Instead of Cookies, sometimes we or our service providers, such as Google, use hashed data, such as email addresses, to measure the effectiveness of our advertising. Our mobile applications on iOS (Apple) and Android (Google) have to interact with our computer servers. We assign Your device a token so that You do not have to log in every time You use the Platform via our mobile apps. You can reset Your browser to refuse all cookies or to indicate when a cookie is being sent. However, some of our Platform features may not work properly without cookies. Most browsers accept cookies automatically but allow You to disable them.

4. INFORMATION ABOUT YOUR LOCATION: From Your IP address, we can tell generally where You are accessing our Platform, such as which city. We start by choosing a location for You based on the IP address of Your Internet connection. You can update or remove this location at any time by logging in to Your account on the Platform.

6. PERSONAL INFORMATION AND INFORMATION COLLECTED AUTOMATICALLY BY THIRD PARTIES

1. THIRD PARTY COOKIES FOR SITE USE ANALYTICS: We use Third Parties such as Google to help us analyse how people are using our Platform. We also use the Google Analytics service to provide us with demographic data about our Visitors, Owners and Members, such as age and gender. Google uses a cookie that can be recognized by Google or its affiliate DoubleClick when You visit other websites. For more information about how Google collects, uses, and shares Your information, please visit the Google Privacy Policy-Partners website at https://www.google.com/policies/privacy/partners/. 

2. THIRD PARTY COOKIES TO TARGET OWNER ADS ON OTHER WEBSITES: “Beacons” are transparent pixel images that are used in collecting information about website usage across websites and over time. Our Owners may use their own or Third-Party cookies or beacons to target Owner ads to You when You visit other websites. Our Owners may also work with other companies who use their cookies or beacons to target Third Party ads to You on other websites based on Your prior visits to the Owner’s Network on our website Service. This is called online behavioural advertising (“OBA”), because You receive ads based on Your prior online behaviour. We do not have access to these cookies; it is Third Parties who engage in OBA.

3. THIRD PARTY COOKIES TO TARGET COMMUNA ADS ON OTHER WEBSITES: We work with Third Parties to serve ads about the Platform through websites, platforms, and services operated and owned by Third Parties. Often these ads are targeted at people who are Visitors or Members of Communities.

7. OUR SHARING OF YOUR PERSONAL INFORMATION AND OTHER INFORMATION 

1. We consider personalizing Your Communa experience an important part of the features of our Platform. We want You to understand what Personal Information gets shared with Your Owners, other Members of Your Community, other Owners or Members of our Platform, and other Third Parties as part of the operation of our Platform.

2. “Third Party” means a person or company or entity who is not an Owner or Member, and government bodies and public agencies and authorities. Third Parties include our service providers whom we authorize, through a data processing agreement, to process Your personal data or information to help us with: development, maintenance, and support of our websites and mobile applications, marketing and advertising, marketing research and analysis, communications, and customer service. We do not permit our Third-Party service providers to use Your Personal Information for any other purpose. We do not share Personal Information with any person or company unless we have an agreement with them that controls their use of the Personal Information.

3. “Processing” or “Process” means any operation or set of operations performed on personal data or on sets of personal data, including by automatic methods, such as collecting, recording, organizing, structuring, storing, adapting or altering, retrieving, consulting, using, disclosing, transmitting, sharing or otherwise making available, aligning or combining, restricting, erasing or destroying.

4. “Consent” or “Agree” means Your freely given, specific, informed and unambiguous expression of Your wishes through a statement or other clear affirmative action such as checking a box which indicates Your agreement to our processing of Personal Information relating to You.

5. However, in case any of the above-mentioned types of sharing are not permissible by You, we advise You not to use our Platform. 

8. PERSONAL INFORMATION SHARED WITHIN THE PLATFORM

1. YOUR OWNER: Your Owner, or Owners, in case there may be multiple, will have access to Your name, email address, and all personal or contact information that You provide when You register for that Owner’s Community. In order to facilitate Member engagement, our Owner will also have access to data regarding Your usage activity, in both aggregated and personally identifiable forms. For example, Owners will be able to see aggregated Member activity within a Community, as well as specific information like how many people reacted in response to a comment You made. Your Owner also will be able to associate Your content, and any Personal Information it contains, with Your contact information. Your Owners may communicate with You outside of the Platform about the Community or relevant topics of interest to You and may retain Your personal information after You leave the Community, unless You request otherwise. Owners have committed in the Terms of Use to comply with applicable laws and regulations about their handling of Personal Information. You should only join a Community if You are comfortable sharing Your Personal Information with the Owner of that Community. If Your Owner has an additional privacy Policy covering the Owner’s use of Personal Information, You should review it carefully to understand how Your Owner may use Personal Information pertaining to You.

2. SEARCH AND MESSAGING BY OTHERS: Visitors to our Platform may be able to search for You by Your name and location if You are a Member of a Community. Members of Your Community can search for You by location, topics, or other Personal Information so that they may message You within the Community. Whether Your information is available to other Visitors and Members depends on whether the Community is Public or Private.

3. PUBLIC AND PRIVATE COMMUNA: Communities on the Platform can be designated as either Public or Private by the Owner. Public communities are visible in the Communa's "Community Discovery" section, while Private communities are not. For Public communities, Visitors can view limited information explicitly made public, but must adhere to community regulations and gain approval through a request or application process to join and access full content. Private communities are accessible only via direct invitation, using a private link or through website integration. The choice between Public and Private status may depend on the community's subscription plan. In both cases, complete access to user content, community members, and resources is granted only upon approval (for Public) or invitation (for Private). Owners retain discretion over membership approval and the level of visibility for their community.

4. PERSONAL INFORMATION INCLUDED IN YOUR CONTENT: If You include Personal Information in Your content, it will be displayed to other Members based on the privacy levels defined above.

9. PERSONAL INFORMATION AND INFORMATION SHARED WITH THIRD PARTIES

1. BUSINESS TRANSFERS: As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganisation, dissolution, or similar event, Personal Information may be part of the transferred assets.

2. AGENTS, CONSULTANTS AND THIRD PARTIES WHOM WE HAVE CONTRACTS WITH: TSG, like many businesses, sometimes hires other companies to perform certain business-related functions. Examples include emailing information to You, maintaining our Website, databases and mobile applications, processing payments, marketing and advertising, marketing research and analysis, and customer service. When we employ another company to perform a function of this type, we only provide them with the Personal Information and other information they need to perform their specific function, and we do not authorize these service providers to use or disclose Your Personal Information except as necessary to perform the tasks we have asked them to do for us or to comply with legal requirements. Our list of the Third Parties we use to assist us with our personal data or Personal Information needs is here. 

3. LEGAL REQUIREMENTS: We may disclose Your Personal Information if required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, (ii) cooperate with a legal investigation or a request from a government/regulatory/administrative authority, (iii) protect and defend the rights or property of TSG., (iv) protect the legal rights, safety, and security of users of our Website/App and the Platform, (v) protect our legal rights and legitimate interests, and those of our business partners, service providers, and customers; (vi) prevent fraud; (vii) act in urgent circumstances to protect the personal safety of users of the Platform or the public, or (v) protect against legal liability. 

4. AGGREGATED DATA SHARED: We disclose aggregated statistics, such as number of Owners and Members, in order to describe our Platform to current and prospective business partners, and to our Third-Party service providers for our legitimate interests and other lawful purposes.

10. YOUR PERSONAL INFORMATION RIGHTS

1. It is imperative for You, as a part of Communa, to be aware of Your rights regarding the Personal Information and other information we have about You.

2. You may object to, or restrict, our collection, use, sharing, transfer and/or storage of Your Personal Information. You may also request a copy of the information that we have about You. You may also ask us to correct or remove Personal Information You think is incorrect.

3. To the extent that an Owner (the data controller) is using the Platform to process Your Personal Information, You may contact the Owner to object, restrict, access, correct or delete Your Personal Information. If You need help finding contact information for Your Owner’s privacy officer, please contact us at dpo@communa.app.

4. If You have a registered account in the Platform, You may object, restrict, access, correct, or request deletion or a copy of some or all of Your Personal Information or other information by logging in to Your account.

5. If You do not have a registered account in the Platform and You would like to object, restrict, access, correct, delete, or request a copy of some or all of Your personal information, please email, write, or call us at the following address: dpo@communa.app. Tvasan Technologies Pte Ltd., 192 Waterloo Street, #05-03, Skyline, Singapore 187966. We shall make all reasonable and practicable efforts to respond to Your request within a reasonable period of time. 

6. Please note, we will keep Your Personal Information for as long as necessary for us to provide the Platform to You. We will also keep and use Your Personal Information to comply with laws including tax laws and other applicable laws. We will also keep Your Personal Information and other information as necessary for backup, archiving, audit, preventing fraud, resolving disputes and troubleshooting problems.

11. YOUR CHOICES AND RIGHTS

1. JOIN COMMUNA AND OWNERS YOU TRUST: You decide the Community You want to join. You also decide whether You trust Your Owner with the information sharing described in this Policy.

2. PUBLIC OR PRIVATE COMMUNITY SETTINGS: It is up to the discretion of an Owner to manage and change the settings of a Community as Private or Public. 

3. NOTIFICATION SETTINGS: In Your account settings, You can control the frequency, type, and mode of notifications You receive through the Platform. You can choose to be notified by email or mobile alerts, both, or neither. You can choose to turn on or off Your notifications by type, such as cheers on Your posts and direct chat messages. 

4. OPT OUT OF EMAIL: We would like to send You information about our services that You may be interested in. If You have agreed to receive marketing messages from us, You may opt-out at any time. We provide an opt-out link at the bottom of each email message. Since we plan our communications in advance, it may take a few weeks for Your opt-out request to take effect. If You continue to receive marketing messages from us or an Owner after Your opt-out, please let us know so that we can investigate the situation.

5. MOBILE ADVERTISING ID CONTROLS: All iOS and Android operating systems provide options to limit tracking and/or reset the advertising IDs.

12. ACCOUNT TERMINATION

1. You can leave one or more of Your Communities or delete any of Your Community accounts. As soon as You leave, we stop collecting Your Personal Information for that Community. 

13. EXCLUSIONS

1. This Privacy Policy does not apply to any Personal Information collected by TSG outside the Platform, such as a telephone call. This Privacy Policy does not apply to any unsolicited information You provide to TSG through the Platform or through any other means, such as information posted to any public areas of the Platform, any ideas for new products or modifications to existing products, and other unsolicited submissions (collectively, “Unsolicited Information”). 

2. All Unsolicited Information shall be deemed to be non-confidential, and TSG shall be free to reproduce and use such Unsolicited Information without limitation or attribution. We respect Your copyrights in Your content, as outlined in our Terms of Use.

14. DISPUTES WITH OWNERS OR OTHER MEMBERS

1. Communa cannot control the actions of Owners or other Members; if You have a privacy-related dispute with an Owner or another Member, You should contact that person directly. You should alert us dpo@communa.app if You believe that an Owner or another Member has violated this Privacy Policy or our Terms of Use.

15. CHILDREN

1. Communa does not knowingly collect Personal Information from children under the age of 18. If You are under the age of 18, please do not use the Platform or submit any Personal Information through the Platform. If You have reason to believe that a child under the age of 13 has provided Personal Information to Communa through the Platform, please contact us at dpo@communa.app and we will look to delete that information from our databases.

16. LINKS TO OTHER WEB APPLICATIONS

1. This Privacy Policy applies only to the Platform/Website/App. The Platform may contain links to other websites not operated or controlled by TSG (the “Third Party Sites”). The Policies and procedures we described here do not apply to the Third-Party Sites. The links from the Platform do not imply that TSG endorses or has reviewed the Third-Party Sites. We suggest contacting those sites directly for information about their Privacy Policies and practices. For example, please be aware that when You click through to a YouTube channel from a Community, YouTube is collecting Personal Information according to the YouTube privacy policy.

17. SECURITY OF YOUR PERSONAL INFORMATION

1. We use appropriate technical and organizational measures including encryption, aggregation, and pseudonymization to protect Your Personal Information provided via the Platform from loss, misuse, and unauthorized access or use, disclosure, alteration, or destruction. However, no Internet, email, or other electronic transmission is ever 100% secure or error free, so we cannot guarantee that Your Personal Information will never be accessed, used, or disclosed, so You should take special care in deciding what information You share on the Platform.

2. “Phishing” is an online cyber scam that is designed to steal Personal Information. If You receive a suspicious email from any unidentified email address or an email address claiming to be affiliated with Communa, asking You for information about You, please contact us at dpo@communa.app

18. YOUR STATE PRIVACY RIGHTS AND ADDITIONAL DETAILS 

1. If You are a resident of a jurisdiction other than Singapore, and the Platform is offered for usage by us within that jurisdiction, TSG will take all relevant steps to ensure that it is compliant with the local privacy laws of such jurisdiction. We also encourage You to be familiar with the privacy laws and regulations of Your jurisdiction. 

19. ACCESS TO INFORMATION AND CONTACT US

1. To keep Your Personal Information accurate, current, and complete, please update Your account settings or contact us at the email address below. We will take reasonable steps to update or correct Personal Information in our possession that You have previously submitted via the Platform.

2. Kindly feel free to contact us if You have any questions about Communa’ Privacy Policy or the information practices of the Platform. Our email address for privacy issues is dpo@communa.app. Our postal address is Tvasan Technologies Pte Ltd., 192 Waterloo Street, #05-03, Skyline, Singapore 187966.

20. CHANGES TO COMMUNA’S PRIVACY POLICY

1. We endeavour to keep this Privacy Policy under regular review, and we will notify You when we make material changes in the future. Please review this policy periodically, and especially before You provide any Personal Information to us. We will also place any updates on our Website and App suitably. This Privacy Policy was last updated on the date indicated at the top of this document.

21. CONFLICTING PROVISIONS IN OWNERS’ PRIVACY POLICY 

1. We have no liability or responsibility for upholding or managing or in any other manner effectuating the privacy policies or practices of our Owners that may be enabled within the Platform. In the event that the terms contained in the Owner’s Privacy Policy are in direct conflict with the terms contained in Communa’s Privacy Policy, the terms contained in Communa’s Privacy Policy shall prevail.