Atrae, Inc, (Company Registration No.6010401060842), a company incorporated under the laws of Japan with its registered address at 106-0045,1-10-10 Azabujuban, Minato-ku, Tokyo, Japan 8th floor, Joule A , its affiliates and subsidiaries (hereinafter referred to as the “Company”, “we”, “us” or “our”) has the highest regard for the privacy and personal data of each user (hereinafter referred to as “user”, “you” or “your”) of the Minglo Career App (defined below) and/or visitors to the Minglo Site (defined below) (the Minglo Career App and the Minglo Site are collectively, the “Minglo Platform”).
We are aware that the success of our services depends on the trust that you have in the way we handle your personal data. By entrusting us with your information, we would like to assure you of our commitment to keep such information private.
We have taken considerable steps to protect the confidentiality, security and integrity of the information shared with us. We encourage you to review the following information carefully before using the Minglo Career App. By using the Minglo Career App, you are deemed to have read, understood and accepted our practices governing the collection, use and disclosure of your personal data in this Privacy Policy.
We are not responsible for the privacy practices of any third-party websites that may be linked to the Minglo Career App. It is your responsibility to check this webpage periodically to see if any terms have been changed or modified. Your continued use of the Minglo Career App constitutes your acceptance of any updates to this Privacy Policy.
This Privacy Policy is drafted in accordance with the Personal Data Protection Act 2012 (“PDPA”) under Singapore law and is intended for use in Singapore and, where applicable, other countries or regions which provide the same level of protection for personal data that is comparable to the standards of the PDPA.
The PDPA recognizes the rights of individuals to protect their personal data (including rights of access and correction) and the requirement for organizations to collect, use or disclose personal data for legitimate and reasonable purposes. Accordingly, this Privacy Policy outlines the personal data that we collect, how it may be used, how it is stored and retained, whom it may be transmitted to as well as our and your responsibilities in relation to such uses and disclosures. We recommend that you read this Privacy Policy and our Terms and Conditions carefully before disclosing any personal data to us or using the Minglo Career App.
Please refer to the Terms and Conditions accessible at https://www.minglo.org/terms-and-conditions ("Terms”) when reading this Privacy Policy. Unless otherwise defined in this Privacy Policy, capitalized terms used herein shall have their meanings ascribed to them under each of the Terms and Conditions specific to each of the Minglo Career App.
This Privacy Policy applies specifically to the Minglo Career App during its limited test phase provisionally scheduled from 12 to 26 August 2025, though this period may be revised or deferred without prior notice (“test period”). During this period, the Platform offers only basic AI Career Buddy chat functionality and externally linked job listings. Features such as blockchain integration, Tokens (including DataNFTs or $MGL), identity verification, or DAO functionalities are not enabled or accessible during this phase.
1. INTERPRETATION
1.1. “Minglo Career App” is a mobile application that provides AI-driven career guidance through chat-based interactions and displays job listings that are externally linked.(Note: During the test period, only these limited functions are active.)
1.2. “Minglo Platform” shall mean the collective reference to the entire solution provided by the Minglo Career App and the Minglo Site;
1.3. “Minglo Site” means the website at https://www.minglo.org/, associated systems and subdomains thereof, including the mobile-optimised versions of such website;
1.4. “Service” or “Services” shall have the meaning ascribed to it under the Terms and Conditions specific to each Minglo Application. For the avoidance of doubt, non-capitalized reference to “service” or “services” shall have the ordinary meaning of service in this Privacy Policy;
1.5. “Terms and Conditions” refers to the terms and conditions of use of the Minglo Career App.
1.6. The headings used in this Privacy Policy are for convenience only and shall not affect the interpretation of these provisions.
2. APPLICATION
2.1. This Privacy Policy applies to users when browsing, visiting, accessing and/or using any part of the Minglo Platform.
2.2. This Privacy Policy sets out our commitments and explains the rights that you have with respect to your personal data. If you do not agree to the terms of this Privacy Policy, please do not use the Services or any part thereof.
2.3. You shall not be permitted to use the Services where you do not confirm your acceptance of this Privacy Policy.
2.4. This Privacy Policy is intended to govern data processing for the test release of the Minglo Career App from the test period only. During this phase, only the limited functionalities described in Clause 1.1 are active.
3. GROUNDS FOR DATA COLLECTION
3.1. By browsing, visiting, accessing and/or using the Minglo Platform and/or when you provide personal data to us, you consent to the collection, storage, use, disclosure and other uses and processing of your personal data by us in accordance with this Privacy Policy, and such consent shall remain effective unless you otherwise notify us in writing of the withdrawal of your consent and the reason thereto. You shall not use our Services if you do not consent to this Privacy Policy, and you shall immediately cease using our Services if you withdraw your consent for us to process your personal data. For the avoidance of doubt, during the test period, we are only collecting data necessary to support AI chat functionality and job listing display. Features such as identity verification and blockchain integration processing are not enabled during this phase.
3.2. “Personal data” and other terms defined under the PDPA where used in this Privacy Policy shall have the same meaning defined under the PDPA.
3.3. Processing of your personal data is necessary for the performance of our contractual obligations towards you under the Terms, permitting access to the Minglo Platform, and providing you with the Services, to protect our legitimate interests, and to ensure compliance with legal and financial regulatory obligations. Failure to provide the relevant data to us or the limitation placed on us in the processing of your personal data may affect our ability to allow your access to the Minglo Platform, provide the Services and/or your ability to enjoy the full benefits of the Minglo Career App.
4. HOW DO WE RECEIVE INFORMATION ABOUT YOU?
4.1. During the test period, you may voluntarily provide us with personal data when using the AI Career Buddy chat feature, accessing job listings, or submitting feedback via the Platform.
4.2. It is your voluntary decision whether to provide us with any personal data. However, certain limited information may be required to enable your participation in the test and ensure proper operation of the Platform.
4.3. To enable us to provide the Services effectively, the information you provide must be accurate and kept up to date. If you discover that the information is inaccurate or outdated, please notify us promptly.
4.4. If you choose to sign up via your social media accounts or other authentication providers during the testing period, we may access limited basic profile information that you explicitly agree to share for instance, name and email address solely to enable access to the Platform during testing. We do not collect or use any additional profile information such as contact lists, profile photos, or personal descriptions during this phase.
5. WHAT TYPES OF INFORMATION WE COLLECT?
5.1. We collect the following personal data about you:
(a) Profile and Registration information – you will be required to provide basic registration information such as your name and email address, which may be required to access certain test features;
(b) AI chat inputs - the content of any queries or messages you submit to the AI Career Buddy;
(c) Voluntary information – when you communicate with us (for example when you send us an email, use a “contact us” form or participating in surveys during the test period) we collect the personal data you provided us with; and
(d) Technical information – we collect certain technical information that is automatically recorded when you use our Services, such as your IP address, device approximate location.
5.2. We may also collect limited data about your usage of the Minglo Platform to help us understand user interactions and improve the platform. This may include the type of device and browser used, operating system language, and general activity on the app.
6. TRACKING TECHNOLOGIES – COOKIES
6.1. The Minglo Career App does not use browser-based cookies or web tracking technologies, as it is only accessible via a mobile application.
6.2. We may collect certain information automatically when you use the Minglo Career App, including device identifiers, app activity logs, crash data, and general usage statistics. These are collected through in-app tracking technologies integrated into the mobile application. This data helps us understand user engagement, improve functionality, and troubleshoot issues during the test period.
6.3. We may also use third party analytics tools such as Google Analytics for Firebase ( https://firebase.google.com/support/privacy ) to better understand usage patterns and app performance. These tools may collect information such as the frequency of app usage, screen navigation, device type, and operating system. The data collected is anonymised and used solely to improve the user experience and functionality of the App. We do not combine the information collected through the use of Google Analytics with personal data. We use the information we get from Google Analytics only to improve the Services.
6.4. Google’s ability to use and share information collected by Google Analytics about your use of the Services is restricted by the Google Firebase Terms of Service and the Google Privacy Policy.
7. HOW DO WE USE THE INFORMATION WE COLLECT?
7.1. We collect the following personal data about you:
(a) Provision of Services – to provide you with access to the AI Career Buddy chat functionality and display job listings that are externally linked. This includes using your inputs to generate AI responses and enabling you to view job-related information.
(b) Improving User Experience – to analyse how users interact with the AI chat and job listing features in order to assess functionality, identify bugs, and improve the platform’s design and usability.
(c) General communication – to send you administrative communications related to your test participation, such as service notices, updates, or feedback requests.
(d) Research and Development – we may analyse usage patterns and aggregate feedback to improve our algorithms and future offerings. Any such research will be conducted using anonymized or aggregated data where possible.
(e) Marketing purposes – we will not use your personal data for marketing or promotional purposes during the limited test period.
(f) Anonymised data – we may analyse and evaluate your personal data in connection with the Services, anonymise and aggregate our analysis and evaluation, and commercialise such anonymised and aggregated analysis and evaluation in any manner as we think fit.
(g) Protecting our interests – we may use your personal data when we believe it is necessary in order to take precautions against liabilities, investigate and defend ourselves against any third-party claims or allegations, investigate and protect ourselves from fraud, protect the security or integrity of the Minglo Platform and/or the Services and protect the rights and property of the Company, its users and/or partners.
(h) Enforcing of policies – we may use your personal data in order to enforce our policies, including the Terms.
(i) Compliance with legal and regulatory requirements – we may also use your personal data as required by or for the purpose of compliance with law, regulation or other governmental authority, or to comply with a subpoena or similar legal process.
(j) Record-keeping – we will collect and retain your personal data in the ordinary course of our business and for so long as necessary for the fulfilment of the purposes set out in this Privacy Policy or as is required by any legal, regulatory and/or accounting requirements.
(k) Ancillary purpose – we may use your personal data for any purposes in connection with, relating or ancillary to any of the above, provided that they are necessary for the delivery of the Services.
7.2. The Platform does not use blockchain, smart contracts or identity verification features during the test period. Any references to these technologies in our broader documentation are not applicable during this phase.
8. WITH WHOM YOUR PERSONAL DATA MAY BE SHARED?
8.1. During the test period, we may share your personal data only with the following categories of recipients, and only to the extent necessary to support the operation, testing, and improvement of the Platform:
(a) Service providers – we might share your personal data, as is reasonably necessary, with our contractors or consultants, including vendors and suppliers that provide us with development services, technology, services, or content for the operation, development and maintenance of the Minglo Platform and/or our Services or data and analysis on the use of the Minglo Platform and/or our Services. The Company shall impose on such service providers obligations of confidentiality and only share personal data to the extent necessary with such contractors or consultants.
(b) Law authorities – we may share your personal data with law enforcement authorities, courts and tribunals, including with legal advisors and consultants, in case we need to respond to law enforcement requests or other legal requests or pursuant to a requirement imposed by law, order, judgment or decree, or courts in order to protect and defend our rights and property or those of Services users.
(c) Merger, acquisition or sale – we may transfer your personal data to another organisation in the event of a merger, acquisition or sale of all or a portion of our assets.
(d) Auditor, legal and professional advisor – we may share your personal data with our auditor if requested for the purpose of audit on our business. We may also share your personal data with our legal and other professional advisors for the purpose of enforcing our rights or defending any claims against us, or for any other purpose in connection with the Services.
(e) Data intermediary – we may appoint an organisation to process and/or store personal data on our behalf in connection with the Minglo Platform and/or the Services. In this respect, we will share your personal data to the appointed organisation, who will be required to process your personal data in accordance with this Privacy Policy.
(f) Group companies – we may share personal data with our affiliated companies for internal reporting and test-related evaluation, subject to appropriate safeguards.
8.2. We and/or providers of Third Party Services may, through the Minglo Platform and/or the Services, offer you, from time to time and at our sole discretion, participation in customized programs, based on specified criteria, which could include testing trials (“Programs”). Participation in Programs may require sharing of your personal data with additional third parties. If you choose to participate, we will provide you with additional information and seek your consent for such sharing. While we take great care to keep your personal data confidential and secure, if you choose to share your personal data (such as through optional feedback forms, public forums, or social media), you do so at your own risk. We are not responsible for any disclosures made by you in such external or public contexts.
9. USE OF AGGREGATED DATA
9.1. We make every effort to ensure that aggregated data does not include any personally identifiable information. The AI technologies powering the Platform and/or enabling the delivery of the Services may analyze and/or combine all information we receive (as set out under this Privacy Policy), with information from other users to create aggregated data that may be disclosed to and utilized by us, our affiliates and by third parties without restriction, on commercial terms that we can determine in our sole discretion, for purposes such as: content marketing, research purposes, in order to understand behavior patterns, marketing strategies and for entering into commercial contracts in order to provide our users with the Services (including the Third Party Services) as well as to periodically enhance the Platform and/or the Services.
10. ACCESS AND CORRECTION
10.1. You may request access to and correction of, your personal data and limit the processing of your personal data or make any enquiries or complaints in respect of the processing of your personal data, by contacting us at the contact details set out in “How to Contact Us” section below. You are responsible for informing us when your personal data or preferences have changed and require updating. We shall, within a reasonable time frame, attend to your request for access to and correction of your personal data or updating of your preferences.
10.2. You may at any time, in your sole discretion or at the direction of our data protection team, delete content containing personal data which you have posted on the Minglo Platform.
11. INTERNATIONAL TRANSFERS
11.1. Off Chain Storage: We store information and data on public and/or private cloud, where your data can be stored and/or backed up in any of the jurisdictions where the cloud service providers provide their cloud service. You hereby consent that we may store your personal data on our cloud server, which may be located outside Singapore or the jurisdiction in which the Services was obtained or is used.
11.2. The Company utilizes a network of storage and server resources that is designed to provide the required security and accessibility for the Minglo Platform. The Company shall, in all engagements with data storage solution providers, use service providers who have evidenced the capability to manage the volumes, nature and technology necessary to store the data provided by users of the Minglo Platform and/or the Services.
12. RETENTION
12.1. We will retain your personal data for as long as necessary to provide our services or as required by any legal, regulatory, accounting requirements and for the duration of the test period unless extended use is required by law, or you provide express opt-in consent for participation in future phases of the Minglo Platform. After the test period, we will delete or anonymize your personal data unless you have provided affirmative consent for continued data retention or usage.
13. LINKS TO OTHER WEBSITES OR APPS
13.1. Our Services may link to or refer to websites or mobile device services that we do not control. Any personal data you provide on the linked pages is provided directly to this third party and is subject to this third party’s provider’s privacy policy. This Privacy Policy does not apply to such other websites or mobile device services, and we are not responsible for the privacy practices or content of any website or mobile device service not controlled by us. For example, job listings displayed in the app redirect to external job platforms. We are not responsible for the content or availability of those listings. If you have any concerns, we urge you to review the terms of those other websites or mobile device services for more information about their applicable policies.
14. HOW WE PROTECT YOUR INFORMATION
14.1. We have implemented administrative, technical, and physical safeguards to help prevent unauthorized access, use, or disclosure of your personal data. Your information is stored on secure servers and isn’t publicly available. We limit access of your information only to those employees or partners that need to know the information in order to enable the carrying out of the agreement between us.
14.2. You need to help us prevent unauthorized access to your account by protecting your password appropriately and limiting access to your account (for example, by signing off after you have finished accessing your account). You will be solely responsible for keeping your password confidential and for all use of your password and your account, including any unauthorized use.
14.3. While we seek to protect your information to ensure that it is kept confidential, we cannot absolutely guarantee its security. You should be aware that there is always some risk involved in transmitting information over the internet. While we strive to protect your personal data, we cannot ensure or warrant the security and privacy of your personal data or other content you transmit using the Services, and you do so at your own risk. All user data during the test period is stored using secure, off-chain cloud infrastructure. Blockchain-based storage mechanisms are not enabled or used during this phase.
14.4. We shall, in the event of a compromise of personal data:
(a) Assess the extent to which personal data collected by us has been compromised and put in place appropriate measures to contain the breach of personal data and minimize any harm to you arising from the breach of personal data;
(b) Analyze and determine the cause of the data breach;
(c) Ascertain if the data breach are notifiable data breaches under any data protection and privacy laws applicable to the Company;
(d) Report the data breach to any relevant governmental data protection body or agency, including the Singapore Personal Data Protection Commission if the data breach is a notifiable data breach;
(e) Ascertain if you are required to be informed of the data breach having regard to relevant rules, regulations, advisories, orders wheresover applicable, including but not limited to the Personal Data Protection (Notification of Data Breaches) Regulations 2021 and the Advisory Guidelines on Key Concepts in the PDPA;
(f) Inform you if you are required to be notified of the data breach; and
(g) Take continuing action to prevent further harm to you arising from the breach of personal data, including but not limited to reviewing measures taken to contain breaches of personal data and protect personal data.
14.5. We shall, in managing data breaches, have regard to the Guide on Managing and Notifying Data Breaches under the PDPA (“Guide”). Subject to our compliance with the Guide in the event of a breach of personal data, by continuing to use the Platform following such an event of breach, you confirm that you accept the adequacy of measures taken by us following an event of breach of personal data.
14.6. We shall be entitled to all rights of indemnity against you as a user of the Minglo Platform in the case where you posted content containing personal data and acted in breach of the Terms of the Minglo Platform.
14.7. You acknowledge that notwithstanding the Company’s security measures, malicious actors, scripts, viruses, codes, software and other damaging factors including the evolution of hacking technologies, may result in the compromise of the personal data which you have provided to the Company.
14.8. To the fullest extent permitted, you waive any claim against the Company for any, loss, liability, damage and/or cost incurred (“Damage”), howsoever such Damages arise and whether such losses are direct or indirect losses, where such data breaches do not arise out of the negligence, fraud or wilful default of the Company.
15. CHILDREN
15.1. Our Services are intended for use by persons 18 years of age and older or where you are under 18 years of age, you have the consent of your legal guardian. Under no circumstances should the Services be used by children under 18 years of age or without consent, and we will not knowingly collect personal data from any person we know to be under 18 years of age, or who does not have consent. If any person discovers that his/her child has been using the Services without his/her consent, or that someone has been using the Services for or on behalf of his/her child without his/her consent, please contact us using the information below under “How to Contact Us” and we will take reasonable steps to delete the child’s information from our active databases. We reserve the right to check our user base from time to time and remove users whom we have grounds to believe they are in fact minors, including without limitation, restricting those user accounts, or deleting them, as we may deem appropriate.
16. COMPANIES OR LEGAL ENTITIES
16.1. Our Services are intended for use by corporations or legal entities duly organised, validly existing and in good standing in the jurisdiction which they are incorporated, or established in. We have no control over the personal data protection policies adopted within these organizations or entities and by agreeing to the Privacy Policy, you accept that the personal data which you, as an individual using the Minglo Platform, provided to such corporations or legal entities at your own risk and that we have no control over, and accept no liability thereto, for the personal data which you provide at your own discretion.
17. EUROPEAN UNION USERS
17.1. Our Services are not available to individuals in the European Union. We do not knowingly collect or process personal data of EU residents and have geo-blocking measures in place to prevent access. If you believe we may have inadvertently collected your data, please contact us immediately.
18. MODIFICATIONS OF THIS PRIVACY POLICY
18.1. We reserve the right to update or modify this Privacy Policy at any time and from time to time. By continuing to use the Services after any such changes, you agree to follow and be bound by this Privacy Policy as changed. For these reasons, we encourage you to periodically review this Privacy Policy for the latest version.
18.2. We may, from time to time, modify or update this Privacy Policy where required under or by any data protection laws applicable to the Minglo Platform and/or the Services.
18.3. Any material changes relevant to the test period will be communicated through the Platform or associated communication channels.
19. HOW TO CONTACT US
18.1. If you have any questions, comments, requests, or concerns related to this Privacy Policy or the privacy practices for our service, please contact us at:
ATRAE, INC 106-00451-10-10 Azabujuban, Minato-ku, Tokyo, Japan8th floor, Joule A Attention: Chief Data Protection Officer
Email: privacy@atrae.co.jp
You may also contact our Data Protection team: Security Project Team
20. ENGLISH VERSION AND OTHER LANGUAGES
19.1. If there is a conflict between this English version of the Privacy Policy and the corresponding versions in other languages, the terms in this English version shall prevail.
Effective date: August 14, 2023 Last revised: August 1, 2025
