PRIVACY POLICY

Effective Date：2025.12.09

We, 【CUBEE GROWTH PTE. LTD. 】 ("we," "us," or "our"), believe your privacy is very important.To fulfill our commitment to respecting and protecting your privacy, we will adhere to our basic principles as explained in detail below, and have crafted this Privacy Policy ("Policy") in accordance with these basic principles:

• We inform you of the personal information that will be collected, and seek your consent to collect, use, or disclose your personal information.
• We identify the purposes of use for collecting your personal information.
• We only collect personal information that is necessary to carry out the identified purposes of use.
• We use or disclose your personal information solely for the purposes for which it is collected, unless we obtain your additional consent or such use/disclosure is required or permitted by applicable law. We will retain your personal information only for the period necessary to fulfill those purposes.
• We endeavor to make sure that your personal information is accurate, complete, and up-to-date.
• We protect your personal information with appropriate security safeguards.
• We maintain maximum transparency in our personal information handling policies and practices.
• You may access and appropriately correct your personal information.
• We take accountability for our data processing activities. We welcome your feedback regarding our compliance with these principles, this Privacy Policy and applicable laws and regulations.

This Policy explains how we collect, use, store, protect, and share your personal information when you use our App and related services (collectively referred to as "Hami" or "Services"). It also sets out your rights in relation to your personal information as well as our data processing practices.

1. Acceptance & Age Restriction

1.1 Your Agreement

By accessing or using our Services (including account registration and in-app interactions), you confirm that you have read, fully understood, and agreed to be bound by all the provisions of this Privacy Policy. If you disagree with any part of this Policy, you must immediately cease accessing or using our Services. Your continued use of the Services after any updates to this Policy are posted will be deemed your acceptance of the revised terms.

1.2 Age Restriction

To comply with global data protection laws and regulations, we strictly prohibit individuals under the age of 18 (or the higher age of majority specified by the laws of your jurisdiction) from creating accounts or using our Services. We do not intentionally collect, use, or disclose personal information from minors. If we inadvertently collect personal information from an individual who does not meet the minimum age requirement, we will promptly delete such personal information in accordance with applicable data protection laws and regulations.

2. Personal Information We Collect

We collect only necessary personal information to provide, optimize, and secure our Services, adhering strictly to the principle of information minimization. The personal information we collect is obtained through the following channels:

2.1 Voluntarily Provided Information

• Account & Profile Information: Registered mobile number and optional profile details (avatar, nickname).
• Service-Related Information: This covers user-generated content (UGC) (e.g., audio clips) and its associated metadata, and customer support-related details (e.g., your account ID, description of the issue you report, and contact information provided for follow-up).

2.2 Automatically Collected Information

• Device & Technical Information: When you use our Services, we may automatically collect device and technical information, including unique device identifiers (e.g., IMEI, Android ID, IDFA), device model, operating system version, IP address, network type, App installation and update history, language settings, crash logs, and microphone permission data (only when you use audio-related features).
• Usage Behavior Information: Pages visited, time spent on features, actions taken (e.g., sending messages), and frequency of using specific services (e.g., voice chat matching).

2.3 Information from Third Parties

We may collect limited personal information from trusted third parties with your explicit consent or as permitted by applicable law. Such personal information includes anonymized aggregated usage information from analytics partners (e.g., Google Analytics) and personal information from regulatory or security partners for the purposes of compliance with laws and regulations or anti-fraud efforts.

3. How We Use Your Personal Information

We use your personal information solely for legitimate, necessary, and transparent purposes directly related to the provision and improvement of our Services. The key purposes of using your personal information include the following:

• Core Service Provision: Verify your identity for account login, ensure secure access to your account, maintain the stable operation of features, and provide technical support services to resolve issues you encounter while using our Services.
• Personalization & Optimization: Analyze your usage behavior, preferences, and interaction information to deliver personalized content and recommendations tailored to you. Additionally, this information is used to optimize the App's interface design, enhance service performance, and continuously improve our algorithms to provide a better user experience.
• Security & Compliance: Monitor and detect fraudulent activities, unauthorized account access, and violations of our platform rules to protect your account security and legitimate rights. We also use relevant personal information to respond to legal requests from competent authorities and comply with applicable laws, regulations, and regulatory requirements.
• Communication: Send you important service notifications (such as updates to this Privacy Policy, changes to service terms, and account-related reminders) and respond to your inquiries, feedback, and requests submitted to our customer support team.

We will not use your personal information for unstated purposes without your explicit consent. You may withdraw consent for non-essential uses (e.g., personalization) at any time, though this may affect certain features.

4. How We Share Your Personal Information

We only share your personal information in the following limited circumstances, and we implement strict technical and contractual safeguards to ensure the confidentiality, integrity, and security of your personal information throughout the sharing process:

• Authorized Service Providers: We may share limited, necessary personal information with trusted third-party service providers that act on our behalf to support the operation and improvement of our Services (e.g., cloud storage providers for information hosting, content moderation services for compliance, and analytics providers for service optimization).
• Legal Obligations & Protection of Rights: We may disclose your personal information if we reasonably believe that such disclosure is necessary to: (i) comply with applicable laws, regulations, judicial orders, or mandatory government/regulatory requests; (ii) protect or defend our legitimate rights, property, or safety, as well as the rights, property, or safety of our users or the public (e.g., in response to fraud, cybersecurity threats, or potential harm to individuals); (iii) enforce our TERMS OF USE, this Policy, or other agreements with you; or (iv) participate in legal proceedings (e.g., responding to subpoenas or court orders). We will limit such disclosure to the minimum amount of personal information necessary to fulfill the legal obligation.
• Business Transfers or Restructurings: In the event of a merger, acquisition, consolidation, sale of all or substantially all of our assets, bankruptcy, liquidation, or other corporate restructuring (collectively, "Business Transfer"), your personal information may be transferred to the successor entity or acquiring party as part of the business assets. We will notify you of such a Business Transfer via prominent means at least 30 days in advance, unless applicable law prohibits such notification. The successor entity or acquiring party will be required by contract to comply with the terms of this Privacy Policy with respect to your personal information; if it intends to use your personal information in a manner materially different from that stated in this Policy, it will obtain your explicit consent before doing so.
• Your Explicit Consent: We will only share your personal information with third parties other than those described above if we have obtained your clear, explicit, and voluntary consent (e.g., when you choose to link your account with a third-party application, share content to a third-party platform, or authorize a third party to access your information through our Services).

Except for the circumstances outlined above, we will not share your personal information with any third party without your prior authorization.

5. Children

You must be at least 18 years of age to access or use our Services. If you are located in a jurisdiction (including any state, country, or region) that mandates a higher minimum age for consenting to the collection, use, or processing of personal information (hereinafter "Applicable Age Threshold"), you may only use our Services if you meet or exceed such higher threshold.

If we become aware that a user is under the Applicable Age Threshold (whether through self-disclosure, parental/guardian notification, or other verification), we will promptly: (a) terminate the user's account; (b) cease all further collection and use of the user's personal information; (c) delete or anonymize the user's personal information in accordance with applicable data protection laws and our information retention policies; and (d) notify the parent or legal guardian of such action upon request (provided the requester can verify their parental/guardian status and relationship to the minor).

Parents or legal guardians who believe their child (under the Applicable Age Threshold) has inadvertently provided personal information through our Services may contact at 【support@cubeegrowthpte.com】 to request account termination and information deletion. To process such requests, we may require reasonable proof of parental/guardian status (e.g., government-issued identification) and confirmation of the child's association with the account. We will respond to valid requests within the timeframe required by applicable law.

6. Your Rights

6.1 Basic Rights

Under applicable data protection laws and relevant local data protection legislation), you have the following rights in relation to your personal information processed by use our Services. To exercise these rights, please contact us via 【support@cubeegrowthpte.com】:

• Access Your Personal Information: Obtain confirmation of whether we are processing your personal information and, if so, access a copy of such information along with relevant details;
• Correct Inaccurate or Incomplete Personal Information: Request correction of any incorrect personal information we hold about you, or completion of incomplete information;
• Erase Your Personal Information: Request deletion of your personal information where applicable (e.g., when the information is no longer necessary for the purposes for which it was collected, or you withdraw consent and no other legal basis for processing exists). Notwithstanding the above, we may retain certain information to the extent required by law (e.g., for anti-fraud, or compliance purposes) or to protect our legitimate business interests (e.g., resolving disputes);
• Restrict Processing of Your Personal Information: Request that we limit the processing of your information (e.g., when you contest the accuracy of the information, or the processing is unlawful but you oppose deletion);
• Object to Processing: Object to the processing of your personal information based on legitimate interests, direct marketing, or processing for statistical purposes (we will cease processing unless we demonstrate compelling legitimate grounds for the processing that override your interests, rights, and freedoms);
• Withdraw Consent: Withdraw your consent to information processing at any time (where processing is based on consent). Such withdrawal shall not affect the lawfulness of processing conducted prior to the withdrawal;
• Data Portability: Request the transfer of your personal information to yourself or a third-party controller in a structured, commonly used, and machine-readable format (where applicable and required by law). We will facilitate such transfer where technically feasible and consistent with data security requirements;
• Lodge Complaint: Lodge a complaint with a relevant information protection authority if you believe our processing of your personal information violates applicable data protection laws.

6.2 Identity Verification

To safeguard your privacy and prevent unauthorized access to or disclosure of your personal information, we may require you to provide reasonable, verifiable evidence to confirm your identity prior to processing your request. If you fail to provide sufficient, verifiable information to confirm your identity, we may decline your request to mitigate the risk of data breaches or misuse.

We further reserve the right to decline requests that are: (i) unfounded or malicious; (ii) excessive request,even if the USD 10 fee is offered; or (iii) excessively burdensome to process (e.g., requests that require disproportionate time, resources, or would interfere with our legitimate business operations, compliance obligations, or the rights of other users). Where required by applicable law, we will provide you with a written explanation of the grounds for declining your request.

7. Personal Information Storage, Transfer & Retention

• Storage: Your personal information is securely stored on state-of-the-art servers located in Singapore. These servers are equipped with multi-layered security measures, including 24/7 monitoring, encryption at rest, firewalls, and regular security audits to safeguard against unauthorized access, information breaches, and other potential threats.
• Transfer: Cross-border information transfers are strictly conducted only when necessary to comply with valid legal requests, such as court orders or regulatory requirements, and are never performed for commercial purposes without explicit user consent where required. All such transfers are subject to rigorous assessment to ensure they meet international information protection standards, including adequacy decisions or appropriate safeguards like standard contractual clauses, to guarantee that your personal information receives an equivalent level of protection as it would within Singapore.
• Retention: We retain your personal personal information only for the minimum period necessary to fulfill the specific purpose for which it was collected. Once this purpose is achieved, or if retention is no longer required by applicable laws, regulations, or legal obligations, your personal information is either permanently deleted from our systems - ensuring it cannot be recovered - or anonymized through a process that removes all personally identifiable personal information, rendering it non-identifiable.

8. Personal Information Security

We implement multi-layered security measures to protect your personal information from unauthorized access, disclosure, or destruction. However, no security system is 100% foolproof. Despite these robust protections, evolving cyber threats and human error can sometimes create gaps. You are responsible for protecting your account credentials and not sharing them with others, even if approached by individuals claiming to be from our organization. By taking these steps, we collectively enhance the security of your personal information and minimize risks.

9. Cookies & Similar Technologies

We use cookies, and other similar tracking technologies (collectively referred to as "Cookies") when you access or use our Services. These technologies help us deliver, optimize, and protect our Services, and we only use them in compliance with applicable data protection laws.You have the right to manage your Cookie preferences, subject to the limitations of essential Cookies (as they are necessary for Service functionality). If you previously consented to non-essential Cookies, you can withdraw your consent at any time. Withdrawal of consent will not affect the lawfulness of Cookie usage prior to the withdrawal, but this may affect some features.

10. Modifications

We may revise this Policy to adapt to legal changes, Service updates, or emerging risks. The "Effective Date" date will be updated to reflect the effective date of changes. Your continued use of the Services after the effective date constitutes acceptance of the revised Policy.

11. Contact Us

For questions, concerns, or requests related to this Policy or your personal information, please contact us at 【support@cubeegrowthpte.com】.