Privacy Policy

Qepon Pte. Ltd, (“Qepon” or “we” or “us” or “our” or other similar pronouns) takes your privacy matters very seriously. Please read the following to learn more about our Privacy Policy (“Policy”). This Policy details how we receive, collect and use information in connection with our website located at www.qepon.com (the “Site”), the Qepon software (“Qepon App”), and other products and services provided on the Qepon (all of the foregoing, collectively, the “Service”).

By visiting this Site or using the Service, you are accepting the policies and practices described in this Policy, as such Policy may be amended from time to time. Each time you visit the Site or use the Service, you agree and expressly consent to our collection, use and disclosure of the information that you provide as described in this Policy.

To be clear about the terminology we are using, when we use the phrase “Personal Information” in this Policy, we mean information about you that is personally identifiable, like your name, address, e-mail address, billing information, or phone number, as well as other non-public information that is associated with this personal information. When we use the phrase “Anonymous Information” in this Policy, we mean information that is not personally identifiable, or linked to your Personal Information such as aggregated information, general demographic information and IP addresses. Anonymous Information does not necessarily enable identification

IF YOU ARE A USER ACCESSING THE SITE OR SERVICE FROM THE EUROPEAN UNION, ASIA, OR ANY OTHER REGION WITH LAWS OR REGULATIONS GOVERNING PERSONAL DATA COLLECTION, USE, AND DISCLOSURE THAT DIFFER FROM SINGAPORE LAWS, PLEASE BE ADVISED THAT THROUGH YOUR CONTINUED USE OF THE SITE AND SERVICE, WHICH ARE GOVERNED BY SINGAPORE LAW, THIS PRIVACY POLICY, AND OUR END USER LICENSE AGREEMENT, YOU MAY BE TRANSMITTING YOUR PERSONAL INFORMATION TO COUNTRIES (INCLUDING THE UNITED STATES) WHERE LAWS REGARDING PROCESSING PERSONAL INFORMATION MAY BE LESS STRINGENT THAN THE PROCESSING OF PERSONAL INFORMATION IN YOUR COUNTRY AND YOU HEREBY CONSENT TO SUCH TRANSMISSION OF PERSONAL INFORMATION.

1. Collection and Use of Information

Account Information

You will receive a unique QePon ID when you create a QePon account. We use these IDs to provide our services to you and other QePon users. You may optionally add your phone number to your account to help you connect more easily with your friends. If you choose to link your phone number, we store it as a one-way encrypted hash value on our servers.

We take your privacy seriously. All information you share with us, including the one-way encrypted hash values of your phone number, is protected by transport encryption when sent to our servers. This helps prevent unauthorized access to your data.

If you decide to link and verify your phone number, we briefly use the actual number during the verification process. We’ll send you a confirmation code via text message (SMS) to complete this step. For sending these SMS messages, we use a service called Twilio. Twilio is a trusted company that follows strict security standards to protect your information. You can find more details about Twilio’s data protection practices on their website: https://www.twilio.com/en-us/legal/privacy.

Messages

QePon cannot decrypt the content of your messages and calls. QePon queues end-to-end encrypted messages on its servers for delivery to devices that are temporarily offline and automatically deletes them after delivered. Your message history is stored only on your own devices.

Additional technical information is stored on our servers, including randomly generated authentication tokens, keys, push tokens, and other material that is necessary to establish calls and transmit messages.

Contact Discovery

QePon offers an optional Contact Discovery System that helps connect users with their contacts on the platform. This involves hashing and thereafter sending encrypted phone number data from the user’s device to QePon’s servers to match it with registered QePon users.

When this feature is enabled, the system sends encrypted hash values of a user’s contact list to the servers for matching with other users on the platform. This occurs either when the user clicks the contact button in the navigation menu or manually refreshes the contact menu by pulling down the screen. If there’s a match, the contact information is automatically updated.

QePon processes the following data through this system:

  • (a) The user’s phone number, encrypted
  • (b) Contact information from the user’s contact list, also encrypted
  • (c) Hash values, only temporarily stored and never in plain text

This service is necessary for QePon’s functioning as per the contract agreement with the user. Personal data is stored only as necessary for the system to run, and data is typically deleted immediately after the hash values are transmitted. Any permanent storage of contact list data is never stored longer than necessary.

This contact discovery system uses an allowed legal basis as the core functionality of the platform under contract performance requirements, justifying the data collection processes.

Cookies, Clear GIFs and Other Automatically Collected Data

If you have permitted your computer to accept cookies, we may use cookies on the Site. Cookies are pieces of information that a website transfers to an individual’s hard drive for record-keeping purposes. Cookies make web-surfing easier by saving preferences and browsing patterns while you are at the Site. Cookies may be used to analyze the Site usage, improve content, customize the Site’s content and layout and for other customer service purposes. A cookie may enable us to relate your use of our Site to other information about you, including your Personal Information. All of these purposes serve to improve and personalize your experience on our Site. Most Web browsers can be set to inform you when a cookie has been sent to you and provide you with the opportunity to refuse that cookie. Additionally, if you have a Flash player installed on your computer, your Flash player can be set to reject or delete Flash cookies. However, refusing a cookie may, in some cases, preclude you from using, or negatively impact the display or function of, the Site or certain areas or features of the Site.

We may use “clear GIFs” (aka “Web beacons” or “pixel tags”) or similar technologies, in the Site and/or in our communications with you to enable us to evaluate Site usage information about visitors to the Site, target campaigns, upgrade visitor information, and know whether you have visited a Web page or received a message. A clear GIF is typically a one-pixel, transparent image (although it can be a visible image as well), located on a Web page or in an e-mail or other type of message, which is retrieved from a remote site on the Internet enabling the verification of an individual’s viewing or receipt of a Web page or message. A clear gif may enable us to relate your viewing or receipt of a Web page or message to other information about you, including your Personal Information.

Our servers may automatically collect data about your Internet address when you visit the Site. This information, known as an Internet Protocol address, or IP Address, is a number that is automatically assigned to your computer by your Internet service provider whenever you are on the Internet. When you request pages from our Site, our servers may log your IP Address and, if applicable, your domain name. Your IP Address is used to help identify you and to gather demographic information about our members and users as a whole, but does not include personally identifiable information. Our server may also record the referring page that linked you to us (e.g., another web site or a search engine); the pages you visit on this Site; the web site you visit after this Site; the ads you see and/or click on; other information about the type of Web browser, computer, platform, related software and settings you are using; any search terms you have entered on this Site or a referral site; and other Web usage activity and data logged by our servers. We use this information for internal system administration, to help diagnose problems with our servers, and to administer our Service. Such information may also be used to gather demographic information, such as country of origin and Internet Service Provider.

We will not link any Personal Information, including e-mail addresses, with aggregate data of our users.

Any or all of these activities with regard to Site usage information may be performed on our behalf by our service providers, including, for example, our analytics vendor(s) and our e-mail management partner(s).

2. Sharing and Disclosure of Information

We do not rent, sell, or share any information about our users with any third-parties, except as specifically described herein. We may disclose your Personal Information if we believe such action is necessary to:

  • (a) comply with the law, or legal process served on us;
  • (b) protect and defend our rights or property (including the enforcement of our agreements); or
  • (c) act in urgent circumstances to protect the personal safety of users of our Service or members of the public.

In order to provide you with Qepon products you have requested, Qepon may sometimes, if necessary, share your Personal Information (excluding your address book and related information) and traffic data with trusted partner service providers and/or agents, for example: banking organizations or other providers of payment and analytical services, customer support, or hosting services. We will always require these third parties to take appropriate organizational and technical measures to protect your personal data and traffic data and to observe the relevant legislation. Qepon will never share your address book information with any third party, except as may be required by law (see below).

The following is a description of how we may share your Personal Information with trusted third party partners. Should we add additional partners, we will immediately update this description:

    1. We use third-party companies to send you an SMS for authentication purpose. Once it is authenticated, it will be linked to a QePon ID assigned to your account. This process can be found in the register section or in the setting of the application. In order to send you the SMS, we need to send your phone number and the authentication message to one of the third-party companies. These third parties are contractually obligated to use your phone number only for the transmission of the authentication SMS.
    1. If we fail to send you an SMS (this happens in certain cases) you may ask us to call you and read you the authentication code on the phone. This is done using a third party automated phone system. In order to call you, we provide this third party partner with your phone number and send the “audio content” of the call to them. The third party partner in turn will typically use another phone provider who may use another phone provider and so on until the call reaches you. This is an industry standard mechanism for the transmission of phone calls. The third party partner is contractually obligated to only use your phone number for the completion of the authentication phone call.
    1. We may use Push Notification Services to notify you about various events related to the app. If we do, the phone number or the name of the person calling you or sending you a message may be part of the notification. This message is sent to the push notification service provider, for delivery to your device.
    1. We use third parties to process the payment and/or billing information that you submit on our Site or through the Qepon App to facilitate payment transactions. We require that these third parties take the appropriate organizational and technical measures to protect your personal data and traffic data and to comply with relevant laws, but we are not liable or responsible for these third party transactions. Therefore, you should review such third party terms and conditions before providing your payment or billing information.

We may disclose information about you if we determine that for national security, law enforcement, or other issues of public importance that disclosure of information is necessary. We may from time to time ask you to provide information about your experiences, which will be used to measure and improve quality. You are at no time under any obligation to provide any of such data. Any and all information which is voluntarily submitted in feedback forms on the Site or any survey that you accept to take part in is used for the purposes of reviewing this feedback and improving the Qepon software, products and websites.

We may contact you to send you messages about faults and service issues. Furthermore, we reserve the right to use email, the Qepon software or SMS to notify you of any eventual claims related to your use of our software, websites and/or products, including without limitation claims of violation of third party rights.

We may send you alerts via the Qepon software to notify you when someone has tried to contact you. We may also use the Qepon software to keep you up to date with news about our software and products that you have purchased and/or to inform you about other Qepon products and related information.

3. Children’s Privacy

Qepon websites and software clients are not intended for or designed to attract anyone under the age of 13 and we do not intentionally or knowingly collect Personal Information on our sites from anyone under the age of 13 (or older in some jurisdictions). We encourage parents to be involved in the online activities of their children to ensure that no information is collected from a child without parental permission.

4. Security

We take reasonable precaution to protect Personal Information from misuse, loss and unauthorized access. Although we cannot guarantee that Personal Information will not be subject to unauthorized access, we have physical, electronic, and procedural safeguards in place to protect Personal Information. Personal Information is stored on our servers and protected by secured networks to which access is limited to a few authorized employees and personnel. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure.

5. Business Transitions

In the event that we go through a business transition, such as a merger, acquisition by another company, or sale of all or a portion of our assets, Personal Information will likely be among the assets transferred. As part of such a transaction the new entity will be required to commit to the same level of protection of your Personal Information as described in this Privacy Policy. If we cannot obtain such a commitment, we will not perform the business transition. We will post a notice on this Site of any such change in ownership or control of the Personal Information we may have prior to such transfer.

6. Changes to Policy

From time to time, we may revise this Policy. We reserve the right to update or modify this Policy, or any other of our policies or practices, at any time with or without notice. However, we will not use your Personal Information in a way that is materially different than the uses described in this Policy without giving you an opportunity to opt-out of such differing uses. We will post the revised Policy on the Site, so that users can always be aware of what information we collect, how the information is used and under what circumstances such information may be disclosed. You agree to review the Policy periodically so that you are aware of any modifications. Your continued use of the Site indicates your assent to any changes and signifies your agreement to the terms of our Policy. If you do not agree with these terms, you should not use the Site, the Qepon App, or any other Service.

7. Change or Removal of Information

If you provided your e-mail address to us and wish to update it, you may do so by sending an e-mail to [email protected] If you no longer wish to receive e-mail communication from us, such as offers, updates and newsletters, you may opt-out of receiving such communications by following the instructions included in each newsletter or communication. In addition, you can remove your e-mail address at any time by sending an e-mail with the subject line of UNSUBSCRIBE to [email protected] Due to technological reasons, we do not know when and if you delete the application.

Therefore, if we detect no activity from your device for 6 months, we will assume that you deleted the application and discontinued the use of our services. However, since we are not certain that you deleted the application (you may just be on vacation, etc.) we will not deactivate your Qepon account (which is your phone number and device ID). We do not want to force you to register again in the event of non-use.

If you wish to delete your account completely, you can go to the “Application Settings” tab in the Qepon App, and tap the “Deactivate Account” option in the Account menu. Please note that this will remove your data from Qepon, and deactivate Qepon on your device. If you have additional concerns and/or requests, you can contact QePon at [email protected]

8. Contact Information

Please direct all questions in connection with this Policy via e-mail to [email protected] or by writing to Qepon Pte, Ltd.., 11, North Bridge Road #08-19 Peninsula Plaza Singapore (179098)