Naise Privacy Policy

1. Personal Data We Collect

We collect personal data that you provide directly, that we generate through your use of our services, and that we receive from third parties.

Information you provide

• Account details: name, email address, phone number, company name, billing address.
• Payment information: processed via our payment partner Airwallex; we do not store full card numbers on our servers.
• Campaign content: briefs, creator messages, contracts, deliverables, and any other content you upload or generate on the platform.
• Identity verification: where required for onboarding or payouts (e.g., NRIC last digits, business registration documents).
• Communications: support tickets, email exchanges, and feedback you submit.

Information generated through your use

• Usage data: pages visited, features used, click and scroll behaviour, campaign actions, login times.
• Device and connection data: IP address, browser type, operating system, device identifiers, referring URLs.
• Cookies and similar technologies: see Section 6 below for details.

Information from third parties

• Public creator profiles indexed from Instagram, TikTok, YouTube, and X.
• Authentication providers if you sign in with Google, Meta, or another OAuth partner.
• Analytics and marketing partners (e.g., Google Analytics, Google Ads) who may share aggregated insights with us.

2. How We Use Personal Data

We use personal data for the following purposes:

• To provide, operate, and maintain the Naise platform.
• To match brands with relevant creators using our AI matching engine.
• To process payments, hold funds in escrow, and release payouts.
• To send transactional communications (campaign updates, contract notifications, payout receipts).
• To send marketing emails, where you have opted in. You can unsubscribe at any time.
• To analyse and improve our services, including model performance and feature development.
• To detect, investigate, and prevent fraud, abuse, or violations of our Terms of Service.
• To comply with legal obligations, court orders, and regulatory requirements.

3. Google Account Data (Gmail)

If you connect your Google account to Naise, we request only the access required to power email outreach to journalists and reporters. You can review or revoke this access at any time from your Google Account’s third-party access settings, or in Naise under Settings → Integrations.

Scopes we request and why

• Sending email (gmail.send). We send outreach emails from your connected Gmail account, only when you explicitly choose to send. We never send email automatically or in the background.
• Reading replies (gmail.readonly). When you manually refresh a conversation, we read only the message threads you started so we can display the reporter’s replies inside Naise. We do not read the rest of your mailbox.

How we handle Google data

• Reply content is fetched on demand and is not stored on Naise’s servers — Google remains the source of record.
• Your Google authorization tokens are stored encrypted and used solely to perform the actions above.
• Disconnecting your Google account in Settings → Integrations immediately revokes Naise’s access and deletes the stored tokens.
• We do not sell or transfer your Google user data, use it for advertising, permit humans to read it (except where you request support, or where required for security or to comply with the law), or use it to develop, improve, or train generalized artificial intelligence or machine-learning models.

Limited Use

Naise’s use and transfer of information received from Google APIs to any other app will adhere to the Google API Services User Data Policy, including the Limited Use requirements.

4. Legal Bases for Processing

We rely on the following legal bases under PDPA and GDPR:

• Contract. Processing necessary to deliver the services you have signed up for.
• Consent. For marketing communications, optional analytics cookies, and certain integrations.
• Legitimate interests. For platform security, fraud prevention, product analytics, and improving service quality.
• Legal obligation. Where required by law (e.g., financial record-keeping, anti-money-laundering checks).

5. How We Share Personal Data

We do not sell your personal data. We may share it with:

• Service providers. Hosting (AWS), payment processing (Airwallex), email delivery (Loops), analytics (Google), customer support tooling, and other vendors who process data on our behalf under contractual safeguards.
• Counterparties on the platform. When you engage a creator or accept a brief, the relevant counterparty receives the information needed to fulfil the engagement (e.g., name, payout details, deliverable specs).
• Legal and safety. Law enforcement, regulators, and legal advisors where disclosure is required by law or necessary to protect rights, property, or safety.
• Corporate transactions. In connection with a merger, acquisition, or asset sale, subject to confidentiality protections.

We never use your private campaign content or creator messages to train third-party AI models.

6. International Data Transfers

Naise is headquartered in Singapore and primarily processes data within ASEAN. Where data is transferred outside Singapore, we rely on appropriate safeguards including standard contractual clauses, and we ensure recipients provide a comparable standard of protection as required by the PDPA.

7. Cookies and Similar Technologies

We use the following categories of cookies:

• Strictly necessary. Required for authentication, security, and core platform functionality. Cannot be disabled.
• Analytics. Help us understand how the platform is used (e.g., Google Analytics 4). You can opt out via your browser settings or our cookie banner.
• Marketing. Used for measuring ad effectiveness (e.g., Google Ads conversion tracking). Optional and opt-in.

8. Data Retention

We retain personal data only as long as necessary for the purposes set out in this policy, or as required by applicable law. Account data is typically retained for the lifetime of your account plus 7 years for financial record-keeping. You may request earlier deletion subject to legal obligations we cannot waive.

9. Your Rights

Subject to applicable law, you have the right to:

• Access the personal data we hold about you.
• Request correction of inaccurate or incomplete data.
• Request deletion of your data, subject to legal obligations.
• Withdraw consent for processing where consent is the legal basis.
• Object to processing based on our legitimate interests.
• Request data portability (a copy of your data in a machine-readable format).
• Lodge a complaint with the Personal Data Protection Commission of Singapore or, if you are in the EU/UK, your local supervisory authority.

To exercise any of these rights, email support@naise.ai with the subject line “Data Subject Request”.

10. Security

We implement industry-standard technical and organisational measures to protect personal data, including encryption in transit and at rest, role-based access control, audit logging, and regular security reviews. No system is perfectly secure, but we work continuously to reduce risk.

11. Children's Privacy

Naise is not intended for individuals under the age of 18. We do not knowingly collect personal data from children. If you believe a child has provided us with personal data, please contact us and we will take steps to delete it.

12. Changes to This Policy

We may update this Privacy Policy from time to time. Material changes will be notified via email or through a notice on the platform. Continued use of the services after such changes constitutes your acceptance of the updated policy.

13. Contact

Questions about this policy or our data practices? Contact our Data Protection Officer at support@naise.ai.

EMERGE ESPORTS PTE. LTD.
Registered in Singapore.