Toki-Privacy Policy

Toki refers to the Toki service owned and operated by Orion Arm Pte. Ltd. or our affiliated companies (referred to as 'we' hereafter). We respect your privacy and are committed to safeguarding the security of any information we obtain from you or about you. This Privacy Policy outlines our practices regarding the collection of personal information about you when you use our website, applications, and services (collectively referred to as the "Services") in accordance with the Singapore Personal Data Protection Act (“PDPA”) and the European Union General Data Protection Regulation (“GDPR”). Each of GDPR and PDPA has been deemed to have extra-territorial scope, so GDPR also applies to non-EU/ EEA data controllers which offer their services to data subjects within the EU or the EEA, and PDPA to non-Singaporean data controllers offering services within Singapore.

01. Personal information we collect

We collect personal information relating to you (“Personal Information”) as follows:

Personal Information You Provide: We collect Personal Information if you create an account to use our Services or communicate with us as follows:

  • Account Information: When you create an account with us, we will collect information associated with your account, may including your name, contact information, account credentials (collectively, “Account Information”).

  • User Content: When you use our Services, we collect Personal Information that is included in the input, file uploads, or feedback that you provide to our Services (“Content”).

  • Communication Information: If you communicate with us, we collect your name, contact information, and the contents of any messages you send (“Communication Information”).

Personal Information We Receive Automatically From Your Use of the Services: When you visit, use, or interact with the Services, we receive the following information about your visit, use, or interactions (“Technical Information”):

  • Log Data: Information that your browser automatically sends when you use our Services. Log data includes your Internet Protocol address, browser type and settings, the date and time of your request, and how you interact with our website.

  • Usage Data: We may automatically collect information about your use of the Services, such as the types of content that you view or engage with, the features you use and the actions you take, as well as your time zone, country, the dates and times of access, user agent and version, type of computer or mobile device, and your computer connection.

  • Device Information: Includes the name of the device, operating system, device identifiers, language and timezone settings, and browser you are using. Information collected may depend on the type of device you use and its settings.

  • Cookies: We use cookies to operate and administer our Services, and improve your experience. A “cookie” is a piece of information sent to your browser by a website you visit. You can set your browser to accept all cookies, to reject all cookies, or to notify you whenever a cookie is offered so that you can decide each time whether to accept it. However, refusing a cookie may in some cases preclude you from using, or negatively affect the display or function of, a website or certain areas or features of a website.

  • Analytics: We may use a variety of online analytics products that use cookies to help us analyze how users use our Services and enhance your experience when you use the Services.

  • Location Information: With your explicit permission, we may collect and process your approximate or precise location data (such as GPS data or device-based location). This information is used to enable location-based features, such as localized reminders, time adjustments, weather updates, and context-aware suggestions.

  • Health and Wellness Information: If you choose to provide it and give your explicit consent, we may collect limited health- or wellness-related information (such as activity patterns, habits, or wellbeing inputs) to support personalized features within the Services. This information is not required to use the core functionality of the Services, and you may withdraw your consent at any time.

Personal Information We Receive From Third Parties: When you use a third party account to register or log in to our Services (Google, Apple, etc.), we may have access to certain information (“Third Parties Information”) as follows:

  • Profile Information: We will receive profile information from your third-party provider, may including your name, email address, profile picture as well as other information you choose to make public on third parties.

  • Usage Data: We may automatically collect information about your use of the Services in connection with your third-party account.

02. How we use personal information

We may use Personal Information for the following purposes:

  • To provide, administer, maintain and/or analyze the Services;

  • To improve our Services and conduct research;

  • To communicate with you;

  • To develop new programs and services;

  • To prevent fraud, criminal activity, or misuses of our Services, and to protect the security of our IT systems, architecture, and networks;

  • To carry out business transfers;

  • To comply with legal obligations and legal process (including regulatory bodies) and to protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or other third parties.

  • To enable optional, personalized and context-aware features based on your location or health-related inputs, where you have provided explicit consent.

Aggregated or De-Identified Information: We may aggregate or de-identify Personal Information so that it may no longer be used to identify you and use such information to analyse the effectiveness of our Services, to improve and add features to our Services, to conduct research and for other similar purposes.

03. Disclosure of personal information

In certain circumstances we may provide your Personal Information to third parties without further notice to you, unless required by the law:

  • Vendors and Other Third-Party Service Providers: We may share your data with third-party vendors, service providers, contractors or agents who perform services for us or on our behalf and require access to such information to do that work.

  • Business Transfers: If we are involved in strategic transactions, reorganization, bankruptcy, receivership, or transition of service to another provider (collectively, a “Transaction”), your Personal Information and other information may be disclosed in the diligence process.

  • Legal Requirements: We may share your Personal Information, including information about your interaction with our Services, with government authorities, industry peers, or other third parties if required to do so by law.

  • Affiliates: We may disclose Personal Information to our affiliates, meaning an entity that controls, is controlled by, or is under common control with Toki.

04. Reliance on the Legitimate Interests Exception

Toki reserves the right to gather, utilise, or reveal your personal information in specific cases without explicit consent, based on the legitimate interests of either Toki or another party.

  • Identifying and mitigating fraudulent activities
  • Detection and prevention of service misuse
  • Meeting legal requirements, such as anti-money laundering and anti-terrorism measures
  • Understanding and enhancing customer experiences

05. Your rights

Depending on location, individuals in the EEA, the UK, Singapore and across the globe may have certain statutory rights in relation to their Personal Information.

  • Access and rectify your Personal Information
  • Delete your Personal Information from our records
  • Transfer your Personal Information to a third party (right to data portability).
  • Restrict how we process your Personal Information.
  • Withdraw your consent.
  • Lodge a complaint with your local data protection authority.

06. Protection of Personal Data

We employ various measures to protect your personal data from unauthorised access or misuse.

07. International transfers of data

Your personal data is stored and processed on servers located in the United States.

08. Children

The Services are intended for a general user. If a minor is to use our Services and provides Personal Information, the minor must do so with the consent of his/her guardian.

09. Links to other websites

The Service may contain links to other websites not operated or controlled by Toki.

10. Security and Retention

We implement commercially reasonable technical, administrative, and organizational measures to protect Personal Information both online and offline.

11. Changes to privacy policy

We may update this Policy from time to time. When we do, we will post an updated version on this page.

12. Contact Us

If you have any questions or suggestions about our Privacy Policy, do not hesitate to contact us at dpo@orionarm.ai.

13. Acknowledgement and consent

By visiting our website, you acknowledge that you have read and understood this Privacy Policy and you accept the practices and terms as set out in this Privacy Policy.