1. GENERAL PROVISIONS
   • This privacy policy (the “Policy”) sets out the basic rules for the processing of Personal Data by the Company when you use the Service provided by the Platform in accordance with the Terms. The purpose of this Policy is to inform you about how we process your Personal Data and protect the data of individuals who use the services provided by the Platform. The Platform and the Company acts as a Personal Data operator for any processing of Personal Data described in this Policy.
   • Relationships related to the collection, storage, distribution, and protection of the data of individuals who use the Services provided by the Platform are regulated by this Policy, other official documents drawn up by the Platform and applicable laws of Singapore.
   • The purpose of this Policy is to ensure that information about individuals, including their Personal Data are duly protected from unauthorized access and disclosure, as well as to inform about the methods used for Personal Data processing.
   • This Policy has been developed and is applied in accordance with the Terms of the Platform, among others, posted on the Platform. In case of inconsistencies between this Policy and other official documents drawn up by the Platform, this Policy shall prevail.
   • The capitalized terms used in this Policy shall have the meaning as set out in Clause 2 Definitions below, unless otherwise specified in the specific context.
   • This Policy is a public document and is available on the Platform.
   • The Company is entitled to make changes to this Policy. Any changes made to the Policy are announced by posting the Policy as amended on the Platform within 15 (calendar) days of the entry into force of the relevant changes.
   • By registering for and/or using the Platform, you agree with the terms of this Policy. If you do not want your Personal Data to be processed by the Company, you will not be able to use the Service provided by the Platform. If you do not agree with the terms of this Policy, you should stop using the Platform and its Services immediately.

2. DEFINITIONS
   • Company means the group of companies under Bongo Holdings PTE LTD, including, but not limited to its Bangladeshi subsidiary company Stellar Digital Limited. The Company is responsible for all Platform administration.
   • Content means the announcements, messages, and informational materials, including text, audio, video, and audio-visual materials provided by a Creator at the User’s Request. For example: a video birthday greeting recorded by the Creator after a User Request. Content is intended for personal use by individuals and is not intended for commercial use by organizations i.e. for advertising or other similar purposes.
   • Creator means any fully legally capable individual who is a well-known public figure (including, but not limited to, actors, musicians, athletes, influencers) who is registered as a Creator on the Platform and makes themselves available to provide Content at the request of Users.
   • Data Subjects under this Policy refer to the Users and Creators of the Platform.
   • Personal Data means any information relating directly or indirectly to a specific or identifiable individual or data subject.
   • Platform means the internet platform at www.josss.co (including any of its variations) operating as of the date of acceptance of these Terms by Users and those launched and put into operation during its entire validity term available to Users through the website, applications, and other resources. The Platform and its software constitute intellectual property that is owned by the Company.
   • Service means the hardware and software package as well as the databases posted on the Platform which allow Users to find out information about Creators regarding the commission Content, Request a Content commission, and enable the User to pay for Content ordered via the Platform.
   • Terms the Platform’s user terms and conditions, as available on the Platform on www.josss.co/pages/terms-of-service
   • User means any individual who visits the Platform, regardless of whether they place a Request or not.

3. WHY DOES THE PLATFORM USE YOUR PERSONAL DATA OR INFORMATION ABOUT YOU WHEN YOU REGISTER ON JOSS PLATFORM?

The Company processes (collects, records, classifies, accumulates, stores, clarifies (updates, changes), retrieves, uses, transfers (distributes, provides, accesses), depersonalizes, blocks, deletes, destroys) information about individuals who use the Services provided by the Platform, including their Personal Data, to provide the Platform Users with technical and other opportunities to place offers, request and provide short, personalized or non-personalized text, audio-visual messages from well-known actors, musicians, athletes, influencers, experts, public figures and other well-known personalities registered on this Platform.

4. WHAT PERSONAL DATA DO WE PROCESS?
   • the Company processes the following Personal Data of Users:
     • Data necessary for the User to request Content on the Platform: (а) name; (b) email address and/or (c) mobile phone number; (d) payment details; (e) description and instructions as requested by the User; (f) social media accounts that the User chooses to share (optional).
     • the Company is entitled to request from Users a copy of an identification document or other document with their name, surname, and photo, as well as other additional information which at the Company’s discretion is necessary and sufficient to identify a particular User and allows excluding any abuse and violation of third parties’ rights.
   • the Company processes the following Personal Data of Creators:
     • Data necessary to fulfil the obligations to Creators: (а) name; (b) email address; (c) mobile phone number; (d) details of company (legal entity) to make payments; (d) city of residence; (f) country; (g) personal description; (h) Creator category; (i) agent (representative) number (if applicable); (j) agent (representative) email address (if applicable); (k) social media account details (link).
     • the Company is also entitled to request a copy of an identification document or other document with the name, surname, and photo of the Creator or agent (representative) (if applicable), as well as other additional information which at the Company’s discretion is necessary and sufficient to identify a particular Creator allows excluding any abuse and violation of third parties’ rights.
   • Other information about Data Subjects processed by the Company
     • Data received when accessing the Platform, including data on technical means (devices), technological interaction with the Platform (including host IP address, type of user’s operating system, type of browser, geographic location, internet service provider);
     • Information automatically obtained when accessing the Platform using bookmarks (cookies).

5. BASED ON WHAT PRINCIPLES DOES JOSS PROCESS PERSONAL DATA?
   • Validity of the purposes and methods for Personal Data processing;
   • Good faith;
   • Compliance of Personal Data processing purposes with the purposes determined and declared when collecting Personal Data as well as with the powers and authority of the Platform;
   • Compliance of the scope and nature of processed Personal Data, Personal Data processing methods with Personal Data processing purposes;
   • Combining Personal Data databases created for purposes that are not compatible with each other is not permitted.

6. CONDITIONS AND PURPOSES FOR PERSONAL DATA PROCESSING

The Platform processes Personal Data for the purposes as specified in this Policy. Requesting access to the Platform Services (as well as creating an account on the Platform), performing other actions aimed at using the Services means consenting to the processing of Personal Data.

7. COLLECTION OF PERSONAL DATA
   • Personal Data are collected on the Platform upon request of Content or access to the Service as well as later, when Data Subjects make changes and/or provide additional information about themselves.
   • User’s Personal Data namely, name, email address and/or mobile phone number, payment details, description and instruction as requested by the User, social media accounts that the User chooses to share are the minimum required to use the Services offered by the Company.
   • Creator’s Personal Data (namely, name, email address and/or mobile phone number, details of company (legal entity) to make payments, city of residence, country, personal description, Creator category, number of agent (representative) (if applicable), email address of agent (representative) (if applicable), social media account details (link) are the minimum required to register on the Platform and use the Services offered by the Platform.
   • Data Subjects are entitled at their own discretion to provide the Company with additional Personal Data which are not necessary using the tools on the Platform.

8. STORAGE AND USE OF PERSONAL DATA

Personal Data are stored exclusively on electronic media and processed using automated systems, except in cases where Personal Data are to be processed manually as prescribed by law.

9. TRANSFER OF PERSONAL DATA
   • Personal Data are not transferred to any other third parties except in cases specified in this Policy. Personal Data may be transferred to third parties/counterparties of the Platform only at the request of Data Subjects or with their consent. When Personal Data are transferred to the Company counterparties, they are to assume and fulfil the obligations to keep the data received confidential. Personal Data and other information are in any case transferred with the consent of Data Subjects, expressed implicitly through actions such as, for example, pressing a specific button as well as by using the Platform (Services).
   • By accepting the terms for Personal Data processing, the User agrees to the transfer of the following Personal Data and for the following purposes in any cases:
     • The Username is transferred to the Creator to inform of the User’s request for Content from the Creator;
     • Payment details are transferred to Bongo as defined in the Terms to fulfil Content request and/or pay for delivered Content;
     • The name, email address, mobile phone number are transferred to service providers that contact the Users by email or phone to liaise with them on their Content requests/services.
   • The Data subject also agrees to the transfer of information (including as it is defined in section “Other Information about Personal Data Subjects Processed by the Company”) for the Platform’s marketing purposes.
   • Personal Data are to be provided at the request of state authorities (local authorities) in the manner prescribed by law. To provide Data Subjects with access to services on the Platform, the Platform develops, improves, and optimizes the products on the Platform. For these purposes, Data Subjects agree to the Platform’s mailing (including surveys) in compliance with applicable laws to get some feedback through the Platform Administration services and/or third parties’ services: electronic messages, SMS and other types of mailings, as well as collection, storage, accumulation, classification, retrieval, comparison, use, data filling (clarification), as well as receipt and transfer of the results of the automated processing of such data to affiliates and partners using various information assessment models in the form of integer and/or text values and identifiers consistent with the evaluation criteria in the requests for data processing by the Platform Administration and/or the entities specified in this paragraph.

10. DESTRUCTION OF PERSONAL DATA
    • Personal Data are destroyed upon deletion by Data Subjects, upon deletion of account (if applicable) by Data Subjects, upon deletion by the Platform of information that is posted in violation of the Terms.
    • the Company will store on its electronic media Personal and other necessary data for the necessary period as set out by law of Singapore.
    • By posting information, using an account, including their Personal Data, Creators acknowledge and agree that this information may be available to other Internet users given the particularities of the Platform architecture and functions.

11. RIGHTS AND OBLIGATIONS OF DATA SUBJECTS
    • Data Subjects are entitled to:
      • Easy and free access to information about themselves by uploading their data on the Platform (if it is applicable);
      • Change and correct the information about themselves provided such changes and corrections are relevant and accurate;
      • Delete information about themselves;
      • Request the Company to update, block, or destroy their Personal Data if such data is incomplete, outdated, inaccurate, illegally obtained, or not necessary for the stated purpose for data processing, and if these actions may not be performed by Data Subjects;
      • Upon request obtain from the Company information about the processing of their Personal Data.
    • Data Subjects must:
      • Provide up-to-date and accurate data about themselves. If the data provided is irrelevant and/or inaccurate, the Platform shall not be liable for the inability to use the Services offered on the Platform.

12. WHAT MEASURES DO WE TAKE TO PROTECT USER DATA?
    • the Platform takes technical, organizational, and legal measures to ensure the protection of Personal Data from unauthorized or accidental access, destruction, modification, blocking, copying, distribution, as well as from other wrongful acts.
    • Data Subjects are responsible for keeping information safe that allows Data Subjects to use the Site (Services). Data Subjects are not entitled to pass on their data related to the use of the Platform (Services) to third parties and must take measures to ensure that they remain confidential.

13. RESTRICTIONS

This Policy does not apply to the actions and internet resources of third parties.

14. REQUESTS FROM DATA SUBJECTS
    • Data Subjects are entitled to send their requests to the Platform Administration, including requests regarding the use of their Personal Data. Requests must be sent to the following email address as a document signed with a qualified electronic signature to support@josss.co
    • The following information must be specified in any request sent by Data Subjects:
      • Number of main identity document for the user or his/her representative;
      • Date of issuance of this document and name of issuing authority;
      • Information confirming the Data subject’s participation in the relationship with the operator;
      • Signature of the user or his/her representative.
    • The Platform Administration undertakes to consider and send a response to any user’s request within 30 days of the request receipt date.
    • All correspondence received by the Platform Administration from users (requests in electronic form via email) constitutes information with restricted access and is not disclosed without the user’s written consent. Personal Data and other information about Data Subjects who have sent a request cannot be used without the Data Subject’s special consent for anything other than to respond to the topic of the request or in cases expressly provided by law.