Thank you for using our AdTrans Pro platform, visiting our website at https://adtranslate.pro and/or communicating with us via email or text or our social media accounts, if any (collectively, the "Services").

For the purposes of data protection and privacy laws, Tiya Pte Ltd and TopMuse Pte Ltd ("we" or "us") are joint controllers in the processing of your personal information. We are committed to protecting your privacy through our data practices described in this Privacy Policy.

This Privacy Policy describes:

The ways we collect personal information about you and why we do so;
How we or our Authorised Partners use your personal information;
The choices you have about your personal information; and
How we protect your personal information.

For the purposes of this Privacy Policy, the terms "personal information" and "personal data" are used synonymously. This Privacy Policy does not apply to our data collection activities offline or otherwise outside of the Services (unless otherwise stated below or at the time of collection).

Residents of certain U.S. states have privacy rights detailed in our Privacy Notice to US Residents. To the extent that there is a conflict between this Privacy Policy and the Privacy Notice to US Residents, the latter will control.

BY USING THE SERVICES, YOU CONSENT TO THE COLLECTION, USE AND TRANSFER OF YOUR PERSONAL DATA FOR PROCESSING AS DESCRIBED IN THIS PRIVACY POLICY. We reserve the right to change and may periodically update this Privacy Policy by posting the updated version on our website. Where required, we endeavour to notify you of material changes to this Privacy Policy by posting a notice on AdTrans Pro. Your continued use of our Services following the posting of changes to the Privacy Policy or any notification to you shall mean you accept those changes. To the extent any provision of this Privacy Policy is found by a competent tribunal to be invalid or unenforceable, such provision shall be severed to the extent necessary for the remainder to be valid and enforceable.

1. Contact Us

The designated joint controller representative is TopMuse Pte Ltd, which is entitled to act on behalf of Tiya Pte Ltd and is responsible for processing and responding to data requests made by you or any government authority.

If you have questions about how we collect, use, process or protect your personal information, or if you have any requests for access, correction, deletion, or suspension of use in respect of your personal information, please contact us at the address below:

Name of the joint controller representative: TopMuse Pte Ltd
Address: 6 Shenton Way, #37-03, OUE Downtown, Singapore 068811
Attn: Data Protection Officer
Email: support@adtranspro.com

We will respond to your requests in accordance with applicable laws and may take additional steps to verify your identity before fulfilling your request. These steps may include verifying your account details. You may also designate an authorized agent to act on your behalf but we reserve the right to verify the agent's identity and authority, and may deny any requests in appropriate circumstances.

We endeavour to respond to all requests in a timely manner. For more complex requests, we may charge a fee for processing your request. We will inform you of such fees before proceeding with your request. If you have any unresolved concerns about your privacy rights or personal data protection that we could not address adequately, you may contact your local privacy and personal data protection authority for further assistance.

2. Collection of Personal Information

(I) Information You Provide

(II) Information We Get When You Use Our Services

When you use our Services, we may automatically collect information about you and how you use our Services. We only use pseudonymized or anonymised data that have gone through a privacy-enhancement process to protect and improve the functionalities of the Services.

(III) Information We Collect from Third Parties

Categories of Third Parties	Description	Data Categories
Technical Service Partners	We work with technical service partners that give us certain data. This includes mapping IP addresses to non-precise location data (e.g. country or region, city, state). This makes it possible for AdTrans Pro to provide certain Services, Contents, and Features. We also collaborate with security service providers, including external fraud-prevention APIs, that help protect user accounts.	User Data Usage Data
Marketing Partners	If you access the Services through a channel of one of our marketing partners, we may receive information from the relevant partner regarding that channel (e.g., the advertising source, referring URL).	Usage Data
Law Enforcement Agencies	We may receive information from law enforcement about potential violations of our Terms of Use. Such information may be used, as necessary, for investigations or to support legal actions.	User Data User Content

3. How Do We Use Your Information

DO NOT SELL. We do not sell your personal information. We also do not transfer, disclose or share your personal information with third parties, except where the information is necessarily transferred, disclosed and shared with our authorised third-party partners who must use and process your information solely to provide you with the Services on our behalf.

We use your personal information for the following purposes only when it is necessary to do so for valid reasons (such as with your consent, to comply the law, to provide you with the Services, to protect your rights and interest or to fulfil our legitimate business interests) and in accordance with applicable laws:

Purpose	Legal basis	Personal Information
To allow you to use the Services and generally manage your account.	They are necessary to provide you with the Services.	Account Information
To deliver and facilitate the delivery of the Services and to allow you to use certain AdTrans Pro features.	They are necessary to provide you with the Services. You have provided your consent when you take steps to provide us with certain information or continue to use the features. With your explicit consent.	User Content Consent Data
To provide certain optional features that form part of the Service. Your explicit consent will be obtained separately before you use these features.	With your explicit consent.
To better understand how AdTrans Pro users use and interact with the Services. To identify and work on areas for improvement. To optimize the user experience.	We have legitimate interests in developing and improving our products and features for our users.	Activity Information: Activity log, timestamps, and country / region information Page access logs (e.g., pages visited, interaction history, timestamps)
Training AI Models & improve our AI services.	We have legitimate interests in developing and improving our products and features for our users. Synthetic Data being artificially generated and not linked to personally identifiable information (PII), does not contain any identifiable or sensitive personal information.
To detect and prevent fraudulent activities, software and tools within the Services and/or employed by end users. To identify a banned account or a device.	It is in our legitimate interests to ensure the security of the environment of our Services and safety of our users.	Fraud-detection information: Basic browser and device information (e.g., browser type, version, language settings, OS type) Network-related information (e.g., IP address, connection status, time zone) Cookie and session information (e.g., user preferences, authentication data) User Data Usage Data User Content Device Address Book Survey and User Research Data
To comply with our legal obligations, respond to legal requests, respond to requests from law enforcement authorities as well as exercise, establish or defend our legal rights. To take appropriate action in respect of intellectual property infringement claims or reports of inappropriate content or activity.	Compliance with legal obligations Legitimate interest to protect our legal rights They are necessary to provide you the Services.	User Data Usage Data User Content
To diagnose, troubleshoot and fix issues with the service. To discover error frequency and trends to ensure a high level of functionality for the Services.	They are necessary to provide you the Services.	Crash Reporting Information: Crash/Error information collected from your usage with the AdTrans Pro
To provide you with customer and technical support when you have enquiries, provide feedback, when you need troubleshooting, to fix bugs and to assist with any issues you might experience using the Services.	With your consent to resolve your questions.	Customer Support Information Email, details of the request
When AdTrans Pro users respond to a survey or take part in user research, we collect and use the personal information as described in the survey or user research.	You provide consent for processing personal information.	Survey and User Research
To conduct business planning, reporting, and forecasting. To evaluate and develop new features or technologies.	Legitimate Interest Our legitimate interests here include researching and planning so that we can keep running our business successfully. Legitimate interest in improving our products, improving user experience and developing new products for our users.	Aggregated usage data Synthetic User Content

4. Who Else Can Use Your Information

We may share your information with other entities in the following situations:

A) Our Related Entities: We might share your personal information within our corporate group to assist us in technical processing operations (such as data hosting, analytics or maintenance), finance, legal, HR or accounting assistance, enhancing security against spam, abuse, fraud, infringement or other wrongdoings, and improve the Services; for corporate audit, analysis, strategic planning, corporate transactions (for example merger and acquisition, sale of company assets, financing etc); or compliance with applicable law. Each entity within the group may only use your personal information in accordance with this Privacy Policy.

B) Our Authorised Partners: We work with third party vendors to provide the AdTrans Pro service ("Authorised Partners" or "Vendors"). We seek to update our list of Authorised Partners below as soon as practicable. These Authorised Partners process your information only at and according to our instructions. They perform tasks such as hosting, user support, analytics and fraud detection and prevention. For more information, please read the privacy policies of our Vendors.

Vendor	Purpose
Firebase	Crash analytics
Shumei	Fraud detection and prevention, Risk control
GoogleSignIn	SSO login & content sharing
Microsoft Azure	Audio-to-Speech
OpenAI	Content Translation
Meta Pixel	Collecting behavioral analytics to improve website functionality and ad effectiveness

C) Government Agencies: In order to combat fraud and illegal activity, we may process and disclose information to other organizations or provide information to government agencies in response to any lawful request. If required by any government authority or courts for any purposes such as the enforcement of any laws or to prevent their contravention, we may release your personal information as is legally required or permitted.

5. Data Storage and Cross Border Data Transfers

By default, your personal data is stored in the United States.

In order to provide you with the full range of Services efficiently, we are working with authorised third party partners as well as related entities within our corporate group around the world. Accordingly, your personal information may be accessed by our authorised personnel around the world and/or your personal information may be lawfully transferred at our instructions for limited access, use or processing by our authorised personnel around the world.

Because the data protection and privacy laws in other countries may be different from those of your home country, we will take steps to ensure that adequate safeguards are in place to protect your personal information as explained in this Privacy Policy. Adequate safeguards that we may use include relying on approved standard contractual clauses and implementing other lawful safeguards.

We are entitled to do the above in order to perform our contractual obligations to you. By using our Services and providing information to us, you also consent to the storage, transfer and processing of the information to jurisdictions outside your home country and, unless otherwise stated in this Privacy Policy, we use this consent as one of the legal grounds for that data transfer.

6. Your Rights and Choices

A) Device Settings

To enable the features of AdTrans Pro, we may request access permissions for the clipboard, microphone, camera, and other device functions. You may opt out of (disable) these permissions at any time.

B) Access the personal information we hold about you

Upon your written request and successful verification of your identity, we will provide you with a copy of your personal information in an electronic format.

C) Personal information rights

You may, at any time, withdraw your consent for us to collect, use, disclose or transfer your personal information to third parties. You also have the right to rectify or delete your personal information, or limit the processing of your personal information. Upon receipt of your written request, we require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences regarding the same. In general, we shall seek to process your request within thirty (30) calendar days of receiving it. Depending on the nature and scope of your request, you may not be able to access some or all features on AdTrans Pro, and we may have to terminate the End-User License Agreement we have with you. We will notify you before completing the processing of your request. Should you decide to cancel your request, please inform us immediately.

Please note that:

If you choose not to provide us with all the personal information as required to (i) register a user account, (ii) use the Services, (iii) process your personal information requests or (iv) assist you on other feedback, queries or requests, we may (x) be unable to, or refuse to, process your personal information for any of the purposes stated herein, (y) be unable to (or continue to) perform our contractual obligations owed to you (if any), and/or (z) have to terminate the End User Licensing Agreement, without any liability on our part.
You may withdraw your consent to using or disclosing your personal information at any time by adjusting the relevant settings on the Website or by contacting us, but withdrawing does not affect the lawfulness of the processing before the withdrawal nor our rights to collect such information where (i) such use or disclosure is required by law, (ii) the personal data in question was collected from publicly available sources or (iii) such use or disclosure is necessary in an emergency where the life or health of a person is at risk.
You may, by providing us with a notice in writing, limit the processing of your personal information (including to request us to cease or not begin processing your personal information for purposes of direct marketing). If you limit the processing of your personal information, we may not be in a position to continue to administer any arrangement or contractual relationship in place, which in turn may result in: (i) us being unable to (or continue to) process your personal information for any of the purposes stipulated in this Privacy Policy; (ii) unable to (or continue to) perform our contractual obligations owed to you (if any); and/or (iii) the termination of any arrangements/agreements/contracts you have with us, without any liability on our part.
Even if you delete your AdTrans Pro account or ask us to delete your personal information, we may still retain some of your data to the extent necessary to serve our legitimate business interests, such as to comply with our legal obligations, resolve disputes, and enforce our agreements. Where required under applicable laws, we will explain to you in greater detail about why we cannot delete your personal data when we receive such requests.

Under applicable laws, you may have the right to obtain a transferable version of your personal information to transfer to another provider.

To exercise your personal information rights, please contact us according to Section 1 "Contact Us" above. You will not be subject to discriminatory treatment for exercising your rights.

7. How Do We Protect Your Personal Information

A) Security

In order to help ensure a secure environment for the Services and safe experience for our users, we are continuously developing and implementing reasonable administrative, technical and physical security measures to protect your personal information from unauthorized use or access and against loss, misuse or alteration.

While we try our best, we cannot warrant the security of any information transmitted to us through or in connection with the Services, that we store on our or our authorised partners' systems.

Any improper collection or misuse of personal information is a violation of this Privacy Policy and our Terms of Use and should be reported to support@adtranspro.com.

B) Pseudonymisation, anonymisation and aggregation techniques

These privacy-enhancing techniques involve modifying or removing certain identifying information from your personal data and information to make it more difficult to link the data or information to you. We only use information that has gone through this privacy-enhancement process if we are using them to improve functionalities of the Services.

C) Personal information retention

Generally, we will store your personal information only for the time period necessary:

to fulfil the purposes for which such personal information was collected;
for as long as you have an active subscription or as needed to provide you the Services; or
as required or permitted by applicable laws (such as tax, accounting, or other legal requirements).

Once we determine that the retention of your personal information is no longer necessary for the intended purposes, or that retention is no longer necessary for any legal or business purpose, we will cease to retain your personal information, or anonymise the personal information so that it can no longer be used to identify any particular individual.

Logs are pseudonymized and retained for a year, after which we may delete or anonymize it.

8. Protecting Children's Privacy

We take our responsibilities to the AdTrans Pro community very seriously. We also believe in protecting children's privacy online. AdTrans Pro is not meant for use by persons under the age of 18 years old. If you are under the age of 18, please do not use our AdTrans Pro Services in any manner. If you are a minor, you may only access and use AdTrans Pro with the consent and under supervision of your parent or legal guardian. Please note that you must be of legal age according to the laws of your home country to make any purchases on AdTrans Pro.

We do not knowingly collect personal information and data from anyone under the age of 18 and the AdTrans Pro is not directed at children under the age of 18. Any person who provides their personal information to us through our Services explicitly represents that they are 18 years of age or older. If we become aware that someone under 18 years of age provided us with their personal information, we will close the account of that person and promptly delete their information or remove their information to the extent required by law, save when we are under a legal obligation to keep certain information.

If you are a parent or legal guardian of a minor, and wish to review any personal data that may have been collected by us from your child or ward for security reasons, or request that their AdTrans Pro account or personal information be modified or deleted for security or accuracy reasons, you may contact us at support@adtranspro.com. We will respond to your requests after verifying the identities of the relevant users and their parents or legal guardians, and obtaining consent (if required under the laws) from the relevant users.

You are responsible for any and all account activity conducted by a minor on your AdTrans Pro account.

9. Cookies and Tracking Technologies

We use third-party services such as Google Firebase and Meta Pixel to help us understand how AdTrans Pro is used and to improve performance and user experience. These services may collect and analyze certain device and usage data, including device identifiers, service usage statistics, and crash reports.

These technologies may function similarly to cookies and may involve the collection of personally referable information under applicable laws. This data may be shared with or accessed by the respective service providers to perform analytics, attribution, or to optimize AdTrans Pro's performance.

We will ask for your prior consent before enabling such tracking technologies, except where they are strictly necessary for the operation or security of AdTrans Pro. You may withdraw your consent any time by adjusting your device settings.

10. Notice to US Residents

11. Notice to EU or UK Residents

Pursuant to the General Data Protection Regulation (GDPR) and the UK Data Protection Act, we now explain the valid legal bases we rely on in order to process your personal information.

Consent. We may process your information if you have given us permission to use your personal information for a specific purpose. You can withdraw your consent at any time.
Performance of a contract. It is necessary for us to process your information in order to allow you to register an AdTrans Pro account and grant you a license to access, use or navigate our Services (or continue to do so at your choice).
Compliance with Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.
Legitimate Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.

12. Notice to Canadian Residents

We may process your information if you have given us specific permission to use your personal information for a specific purpose, or in situations where your permission can be inferred. You can withdraw your consent at any time.

In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:

If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way.
For investigations and fraud detection and prevention.
For business transactions provided certain conditions are met.
If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim.
For identifying injured, ill, or deceased persons and communicating with next of kin.
If we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse.
If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province.
If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records.
If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced.
If the collection is solely for journalistic, artistic, or literary purposes.
If the information is publicly available and is specified by the regulations.

13. Notice to Malaysian Residents

This section applies to you if you reside in Malaysia. In this section, the term "processing" shall have the same meaning as prescribed in the Malaysian Personal Data Protection Act 2010 ("MY PDPA").

Personal Information of Minors – In respect of personal information relating to a minor (i.e. individuals under the age of 18), you confirm that you are the parent or legal guardian or person who has the parental responsibility for the said minor to consent on his/her behalf to the processing of his/her personal information in accordance with this Privacy Policy.

Obligatory Personal Information – It is obligatory that you supply us your details for fields marked as compulsory (where applicable) when you register an account or use our Services (collectively, "Compulsory Personal Information"). If you fail to supply us with any of the Compulsory Personal Information, we may refuse to, or may be unable to, process your personal information for any of the purposes specified in this Privacy Policy.

Language – In the event of any inconsistency between the English version and the Bahasa Malaysia version of this Privacy Policy, the English version shall prevail over the Bahasa Malaysia version.

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