1. Introduction

1.1 This data privacy policy applies to (among other products and services) the following apps:

(a) Maximon - legal drafting suite

(b) FD Mxmn - import business data

1.2 This data privacy policy consists of the following sections:

(a) "General": applicable to all data subjects.

(b) Jurisdiction-specific supplements: applicable where, by virtue of domestic data protection law in the relevant jurisdiction, and/or applicable international private law, the Company's processing of your data is subject to the laws of that jurisdiction.

(c) "Cookies": a supplement specifically addressing website cookies.

1.3 The provisions of the supplements described at (b) and (c) above are, insofar as applicable, in addition to, rather than instead of, the general section described at (a) above (of which this introduction forms part).

2. Purpose of this privacy policy

2.1 This privacy policy aims to give you information on how the Company collects and processes your personal data through:

(a) your use of the Company’s website;

(b) your use of the Company’s software-as-a-service (“SaaS”) product offerings (including those listed at 1.1 above);

(c) your registration of a user account; and

(d) your (or your business’s) entry into a subscription agreement with the Company.

2.2 This website is a business website: it is not intended for children and we do not knowingly collect data relating to children.

2.3 It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

2.4 The Company is part of a Group of legal entities. This privacy policy is issued on behalf of the Group, so references to the “Company” or "us" (or declensions of these terms) are meant to refer to the relevant company in the Group responsible for processing your data in any given case. Maximon Ltd. is responsible for data processing in connection with the website.

2.5 The board of the Company is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please submit a request by email to hello@maximon.ltd.

2.6 We keep our privacy policy under regular review. We may update this policy periodically in response to regulatory, policy, or internal changes. In case of change, we will publish the updated version on the Company website.

2.7 It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

2.8 This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

2.9 This privacy policy includes this “general” section and several jurisdiction-specific addenda. The addenda may apply to you by virtue of your location, or may apply generally e.g. by virtue of the data storage locations (as disclosed below) or other legal bases. Where a jurisdiction-specific addendum applies, it is to be read in conjunction with, not instead of, the general section; but in case of conflict, the addenda take precedence.

3. The data we collect about you

3.1 Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

3.2 We may collect, use, store and transfer different kinds of personal data about you which we have grouped as follows:

(a) Identity Data includes name, title, and business affiliation.

(b) Contact Data includes email address, and possibly other contact details such as address or phone number.

(c) Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.

(d) Technical Data includes internet protocol (IP) address, your login and license identification data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website. In respect of error reports, it may also include details of loaded dynamic link libraries, relevant registry information, and configured addins.

(e) Profile Data includes your username and password, and saved preferences.

3.3 We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data); nor do we collect any information about criminal convictions and offences.

3.4 Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

4. How is your personal data collected?

4.1 We use different methods to collect data from and about you including through:

(a) Direct interactions: You may give us your Identity, Contact and Transaction Data by filling in forms or by corresponding with us by email or otherwise. This includes personal data you provide when you:

(i) enquire about, or contract for, our products or services;

(ii) create an account on our website;

(iii) subscribe to our service or publications; or

(iv) give us feedback or contact us.

(b) Automated technologies or interactions: As you interact with our website and software, we may automatically collect Technical Data, for example through cookies, automatic error reporting, or server-side logging.

(c) Third parties or publicly available sources: We might receive personal data about you from various third parties and public sources, for example from official company registries or LinkedIn or similar profiles.

5. How we use your personal data

5.1 We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

(a) Where we need to perform the contract we are about to enter into or have entered into with you.

(b) Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

(c) Where we need to comply with a legal obligation.

5.2 Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending marketing communications to you via email or other means. You have the right to withdraw consent to marketing at any time by contacting us.

5.3 We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

5.4 Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

5.5 Change of purpose

(a) We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

(b) If we need to use your personal data for an unrelated purpose, we will notify you (directly or through an update to this privacy notice) and we will explain the legal basis which allows us to do so.

(c) Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

6. Disclosures of your personal data

6.1 We may share your personal data with the parties set out below for the purposes set out in the table above.

(a) Other Group companies

(b) External Third Parties as set out in the Glossary.

(c) Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

6.2 We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes.

7. International transfers

7.1 We may transfer your data internationally, most notably (but not exhaustively) between the following jurisdictions:

7.2 We ensure your personal data is protected:

(a) by requiring all our Group companies to follow the same “binding corporate rules” when processing your personal data; and

(b) by ensuring that destination countries have been deemed to provide an adequate level of protection for personal data, and/or that our service providers in those countries are contractually obligated to provide an equivalent level of protection.

8. Data security

8.1 We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered, or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

8.2 We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

9. Data retention

9.1 We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation with respect to our relationship with you.

9.2 To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

10. Glossary

11. History

11.1 Effective date: 29 March 2022

11.2 Last updated: 27 April 2022

1. Data protection notice

This Data Protection Notice (“Notice”) sets out the basis on which we may collect, use, disclose or otherwise process personal data of our customers in accordance with the Personal Data Protection Act (“PDPA”). This Notice applies to personal data in our possession or under our control, including personal data in the possession of organizations which we have engaged to collect, use, disclose or process personal data for our purposes.

2. Personal data

2.1 As used in this Notice:

(a) “customer” means an individual who (i) has contacted us through any means to find out more about any goods or services we provide, or (ii) may, or has, entered into a contract with us for the supply of any goods or services by us; and

(b) “personal data” means data, whether true or not, about a customer who can be identified: (i) from that data; or (ii) from that data and other information to which we have or are likely to have access.

2.2 Depending on the nature of your interaction with us, some examples of personal data which we may collect from you include name, email address and telephone number.

2.3 Other terms used in this Notice shall have the meanings given to them in the PDPA (where the context so permits).

3. Collection, use, and disclosure of personal information

3.1 We generally do not collect your personal data unless (a) it is provided to us voluntarily by you directly or via a third party who has been duly authorized by you to disclose your personal data to us (your “authorized representative”) after (i) you (or your authorized representative) have been notified of the purposes for which the data is collected, and (ii) you (or your authorized representative) have provided written consent to the collection and usage of your personal data for those purposes, or (b) collection and use of personal data without consent is permitted or required by the PDPA or other laws. We shall seek your consent before collecting any additional personal data and before using your personal data for a purpose which has not been notified to you (except where permitted or authorized by law).

3.2 We may collect and use your personal data for any or all of the following purposes:

(a) performing obligations in the course of or in connection with our provision of the goods and/or services requested by you;

(b) responding to, handling, and processing queries, requests, applications, complaints, and feedback from you;

(c) managing your relationship with us;

(d) processing payment or credit transactions; and

(e) any other incidental business purposes related to or in connection with the above.

3.3 We may disclose your personal data where such disclosure is required for performing obligations in the course of or in connection with our provision of the goods and services requested by you.

4. Withdrawing your consent

4.1 Where the collection, use and disclosure of your personal data is based on consent, the consent that you provide will remain valid until such time as it is withdrawn by you in writing. You may withdraw consent and request us to stop collecting, using and/or disclosing your personal data for any or all of the purposes listed above by submitting your request via email at the contact details provided below.

4.2 Upon receipt of your written request to withdraw your consent, we may 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 of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us. In general, we shall seek to process your request within 1 month of receiving it.

4.3 Whilst we respect your decision to withdraw your consent, please note that depending on the nature and scope of your request, we may not be in a position to continue providing our goods or services to you and we shall, in such circumstances, notify you before completing the processing of your request. Should you decide to cancel your withdrawal of consent, please inform us in writing in the manner described in clause 4.1 above.

4.4 Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclosure without consent is permitted or required under applicable laws.

5. Access to and correction of personal data

5.1 If you wish to make (a) an access request for access to a copy of the personal data which we hold about you or information about the ways in which we use or disclose your personal data, or (b) a correction request to correct or update any of your personal data which we hold about you, you may submit your request via email at the contact details provided below.

5.2 Please note that a reasonable fee may be charged for an access request. If so, we will inform you of the fee before processing your request.

5.3 We will respond to your request as soon as reasonably possible. In general, our response will be within 1 month. Should we not be able to respond to your request within 30 days after receiving your request, we will inform you in writing within 30 days of the time by which we will be able to respond to your request. If we are unable to provide you with any personal data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the PDPA).

6. Protection of personal data

6.1 To safeguard your personal data from unauthorized access, collection, use, disclosure, copying, modification, disposal or similar risks, we have introduced appropriate administrative, physical and technical measures such as minimized collection of personal data, authentication and access controls (such as good password practices, need-to-basis for data disclosure, etc.), encryption of data, up-to-date antivirus protection, regular patching of operating system and other software, securely erase storage media in devices before disposal, web security measures against risks, and usage of multi-factor authentication (MFA) to secure access.

6.2 You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.

7. Accuracy of personal data

We generally rely on personal data provided by you (or your authorized representative). In order to ensure that your personal data is current, complete and accurate, please update us if there are changes to your personal data by informing us via email at the contact details provided below.

8. Retention of personal data

8.1 We may retain your personal data for as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws.

8.2 We will cease to retain your personal data, or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purpose for which the personal data was collected, and is no longer necessary for legal or business purposes.

9. Transfers of personal data outside of Singapore

Our IT system is international in nature and we may transfer your personal data to other countries outside of Singapore, in particular the Focal Territories defined in the General section of our global Data Privacy Notice. We will take steps to ensure that your personal data continues to receive a standard of protection that is at least comparable to that provided under the PDPA. By using our services, you are required to consent to this transfer.

10. Contact

You may contact our Data Protection Officer if you have any enquiries or feedback on our personal data protection policies and procedures, or if you wish to make any request, at the following address: hello@maximon.ltd.

11. Effect of notice and changes to notice

11.1 This Notice applies in conjunction with any other notices, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your personal data by us.

11.2 We may revise this Notice from time to time without any prior notice. You may determine if any such revision has taken place by referring to the date on which this Notice was last updated. Your continued use of our services constitutes your acknowledgement and acceptance of such changes.

1. Children Under the Age of 16

1.1 Our Website is not intended for children under 16 years of age. No one under the age of 16 may provide any information to or on the Website. We do not knowingly collect personal information from children under 16. If you are under 16, do not use or provide any information on this Website or through any of its features, register on the Website, make any purchases through the Website, use any of the interactive or public comment features of this Website, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at hello@maximon.ltd.

1.2 California residents under 16 years of age may have additional rights regarding the collection and sale of their personal information. Please see section 2 below for more information.

2. California

2.1 General

(a) If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. To learn more about your California privacy rights, see below.

(b) California's "Shine the Light" law (Civil Code Section § 1798.83) may permit users of our products that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to hello@maximon.ltd.

2.2 Privacy notice for California residents

This privacy notice for California residents supplements the information contained in the Privacy Statement of the Company and its Group (collectively, “us” or declensions thereof) and applies solely to visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws. Any terms defined in the CCPA have the same meaning when used in this notice.

2.3 Information we collect

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:

Personal information does not include:

(a) Publicly available information from government records.

(b) De-identified or aggregated consumer information.

(c) Information excluded from the CCPA’s scope, like:

(i) health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;

(ii) personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

We obtain the categories of personal information listed above from the sources described in section 3 of the General section of the global Data Privacy Notice.

2.4 Use of Personal Information

(a) We may use or disclose the personal information we collect for one or more of the business purposes described in section 4 of the General section of the global Data Privacy Notice.

(b) We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

2.5 Sharing Personal Information

(a) We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

(b) In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:

(i) Category A: Identifiers.

(ii) Category B: California Customer Records personal information categories.

(iii) Category F: Internet or other similar network activity.

(c) We disclose your personal information for a business purpose to the following categories of third parties:

(i) Our affiliates.

(d) In the preceding twelve (12) months, we have not sold any personal information.

2.6 Your Rights and Choices

(a) The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

(b) Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

(i) The categories of personal information we collected about you.

(ii) The categories of sources for the personal information we collected about you.

(iii) Our business or commercial purpose for collecting or selling that personal information.

(iv) The categories of third parties with whom we share that personal information.

(v) The specific pieces of personal information we collected about you (also called a data portability request).

(vi) If we sold or disclosed your personal information for a business purpose, two separate lists disclosing: sales, identifying the personal information categories that each category of recipient purchased; and disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

(c) Deletion Request Rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service providers to:

(i) Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.

(ii) Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.

(iii) Debug products to identify and repair errors that impair existing intended functionality.

(iv) Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.

(v) Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).

(vi) Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.

(vii) Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.

(viii) Comply with a legal obligation.

(ix) Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

(d) Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by email at hello@maximon.ltd.

Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

(i) Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.

(ii) Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

(e) Response Timing and Format

We endeavor to respond to a verifiable consumer request within 1 month of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

2.7 Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

(a) Deny you goods or services.

(b) Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.

(c) Provide you with a different level or quality of goods or services.

(d) Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

2.8 Changes to Our Privacy Notice

We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will notify you by email or through a notice on our website homepage.

2.9 Contact Information

If you have any questions or comments about this notice, our Privacy Statement, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us by email at hello@maximon.ltd.

3. Nevada

Nevada residents who wish to exercise their sale opt-out rights under Nevada Revised Statutes Chapter 603A may submit a request to this designated address: hello@maximon.ltd. However, please know we do not currently sell data triggering that statute's opt-out requirements.

1. General

1.1 This cookie notice sets out how the Company uses and protects any information that you give it when you use its website.

1.2 A cookie is a small text file that is stored on your computer or mobile device when you visit a website – we use these to make a user's experience more efficient. The law states that we can store cookies on your device if they are strictly necessary for the operation of the site. For all other types of cookies we need your permission.

1.3 On this website we use persistent cookies (necessary for the functioning of the site) and optional cookies (useful to make a user’s experience more efficient).

1.4 Details of the cookies used on our website are provided below.

1.5 Your consent to the use of cookies applies to www.maximon.ltd.

1.6 You can view and change your cookie settings at any time.

1.7 We sometimes embed content, in particular video content, from third-party websites such as YouTube. Pages with this embedded content may present cookies from these websites. Similarly, when you use one of the share buttons on this website, a cookie may be set by the service you have chosen to share content through. We do not control the dissemination of these cookies and we will not block cookies from those websites. You should check the relevant third party website for more information about these.

2. Persistent or necessary cookies

3. Optional cookies

N/A

4. Browser settings

4.1 You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

4.2 Do Not Track (DNT) and Global Privacy Control (GPC) are features offered by some browsers which, when enabled, can send a signal to websites to request that your browsing is not tracked, such as by third-party advertising networks, social networks and analytics companies.

4.3 This website does not currently action DNT or GPC requests; however, you may opt out of tracking on this website, including analytics, by following the instructions to opt out of cookies above.

5. Changes to this Cookie notice

5.1 We reserve the right to amend this notice at any time and will post any revisions on this page.

5.2 Effective date: 29 March 2022

5.3 Last updated: 27 April 2022