Kosy Connect / KOSY LIVING PTE. LTD. Privacy Policy and Terms of Service

Effective Date: 29 September, 2025

PART A: PRIVACY POLICY (PDPA COMPLIANT)

This Privacy Policy applies to Kosy Connect (the “App”) and its operator KOSY LIVING PTE. LTD. (“we” or “the Company”). We are committed to protecting the privacy and security of your Personal Data. This Policy complies with the requirements of Singapore’s Personal Data Protection Act 2012 (PDPA) and its amendments.

Please read this Policy carefully before using the App. By using the App, you consent to our collection, use, and disclosure of your Personal Data in accordance with this Policy.

1. Types of Personal Data We Collect

We only collect Personal Data that is reasonably necessary to provide the App services. The Personal Data we collect may include:

1.1 Data Directly Provided by You (Directly Provided Data)

• Identity Data: Such as your username, password, and profile picture.
• Contact Data: Such as your email address or mobile phone number.
• Transaction Data: Such as payment receipts for in-App services or subscriptions (we do not store complete payment card information).
• Referral Data: Information related to potential clients you refer, including (but not limited to) the client’s name, contact number, property address, and details about their renovation needs. (Crucial: You must have proper consent mechanisms when collecting third-party data)
• Communication Data: Feedback, customer support requests, or survey participation data you submit through the App.

1.2 Data Automatically Collected by the App (Automatically Collected Data)

• Device Data: Such as your device model, operating system version, unique device identifier (UDID), and IP address.
• Usage Data: Information on how you use the App, including access times, in-App feature usage, pages clicked, etc.
• Location Data (if applicable): If you grant permission, we may collect precise or approximate location information.
  • Purpose for Location Data: Used for matching agents/property locations to relevant KOSY LIVING PTE. LTD. service areas and for internal geographic analysis of referral volume.

2. Purposes for Collection, Use, and Disclosure of Personal Data (Purpose Limitation Obligation)

We collect your Personal Data only for one or more of the following purposes, which were disclosed to you at the time of your consent, or for purposes that a reasonable person would consider appropriate in the circumstances:

Purpose of Data Collection	Description and Explanation
Service Provision and Operation	Registering and managing your account; facilitating the referral and matching of clients to KOSY LIVING PTE. LTD. for renovation services; providing the features, services, or content you request; processing your commissions/incentives (e.g., in-App purchases).
User Support and Communication	Responding to your inquiries, requests, and feedback; sending you service-related notifications (such as updates or security alerts regarding referral status).
Security and Protection	Ensuring the network and information security of the App; detecting and preventing fraud, misuse, and illegal activities.
Improvement and Analysis	Analyzing App usage to improve and optimize the App’s performance, user experience, and referral process efficiency.
Marketing and Promotion	Sending you marketing materials about our products, services, or offers, provided we have your explicit consent.
Legal and Compliance	Complying with applicable laws, court orders, requirements from regulatory bodies (including the PDPC), or assisting with law enforcement investigations.

We will not use your Personal Data for purposes other than those listed above unless we have obtained your prior new consent or are permitted by law.

3. Consent and Withdrawal of Consent (Consent & Withdrawal)

3.1 Explicit Consent (Express Consent)

We will inform you of the purpose in a clear manner and obtain your explicit consent before collecting, using, or disclosing your Personal Data. Your consent is typically obtained through your action of checking a consent box during registration or taking a clear action when using a service that involves Personal Data processing.

3.2 Withdrawal of Consent (Withdrawal of Consent)

You have the right to withdraw your consent to our collection, use, or disclosure of your Personal Data at any time by written notice or through the mechanism provided within the App.

• Withdrawal Process: Please contact our Data Protection Officer (DPO) via the email address provided in Section 6.
• Consequences of Withdrawal: Upon receiving your withdrawal notice, we will cease collecting, using, or disclosing your Personal Data, unless required or permitted by law. Please note that withdrawing consent may result in our inability to continue providing some or all of the App’s features and services to you.

4. Your Rights (Access, Correction, Portability)

In accordance with the PDPA, you have the following rights:

4.1 Right of Access (Right of Access)

You have the right to request access to your Personal Data held by us, and information about how your Personal Data has been used or disclosed in the year preceding the request date.

• Response Time: We will respond to your request as soon as practicable (usually within 30 days) upon receiving it. We reserve the right to charge a reasonable administrative fee.

4.2 Right of Correction (Right of Correction)

You have the right to request us to correct or amend any Personal Data we hold that you believe is inaccurate or incomplete.

4.3 Right of Data Portability (Right of Data Portability)

You have the right to request us to transmit the Personal Data you have provided to us, in a common machine-readable format, to you or another organization designated by you.

• Exceptions: The exercise of this right is subject to the conditions and exceptions stipulated by the PDPA.

5. Data Security and Cross-Border Transfer (Protection & Transfer)

5.1 Protection Obligation (Protection Obligation)

We implement reasonable organizational, physical, and technical security measures (such as SSL/TLS encryption, access controls, and firewalls) to protect the Personal Data we hold, preventing unauthorized access, collection, use, disclosure, copying, modification, handling, or loss.

5.2 Transfer Limitation Obligation (Transfer Limitation Obligation)

Your Personal Data may be transferred to and stored and processed in countries outside Singapore (e.g., using cloud servers located in the United States or Ireland).

We will ensure that the overseas recipient of your Personal Data provides a standard of protection comparable to the PDPA, for example, by entering into a contract that incorporates data protection terms stipulated by the PDPA.

6. Data Protection Officer and Contact Information (Data Protection Officer – DPO)

Data Protection Officer (DPO)

We have appointed a Data Protection Officer responsible for overseeing the Company’s compliance with the PDPA.

• DPO Name/Department: Compliance and Legal Department
• DPO Email: contact@kosyliving.com
• DPO Address: 6 Raffles Boulevard 03-208, Marina Square Singapore 039594

If you have any questions or complaints regarding this Privacy Policy or how we handle your Personal Data, please contact our DPO.

7. Updates to the Policy (Updates to the Policy)

We may revise this Policy from time to time. Any material changes will be communicated to you in advance through an App notification or email, allowing you time to review the changes. Your continued use of the App after the revised policy becomes effective constitutes your acceptance of the revised policy.

PART B: TERMS OF SERVICE (GOVERNED BY SINGAPORE LAW)

Welcome to Kosy Connect (the “App”). These Terms of Service (“Terms”) constitute a legally binding agreement between you and KOSY LIVING PTE. LTD. (“we” or “the Company”).

Please read these Terms carefully. By accessing or using the App, you agree to be bound by these Terms and the Privacy Policy contained in Part A.

1. Acceptance of Terms

You must be at least 16 years old to use this App. If you are under the legal age, you require the consent of your parent or legal guardian.

2. Intellectual Property

2.1 Our Content

All content, features, and functionality in the App (including, but not limited to, all information, software, text, displays, images, video, and audio, and the design, selection, and arrangement thereof) are owned by KOSY LIVING PTE. LTD. or its licensors and are protected by copyright, trademark, patent, trade secret, and other intellectual property or proprietary rights laws.

2.2 User Content

You retain all rights in and to any content you post, upload, link to, or otherwise make available on the App (“User Content”). However, you grant us a perpetual, non-exclusive, transferable, royalty-free, worldwide license to use, reproduce, modify, publicly display, and distribute your User Content to operate and improve this App.

3. User Behavior Rules

You agree that you will not engage in the following conduct while using the App:

1. Posting any content that is unlawful, harmful, threatening, defamatory, obscene, harassing, hateful, or racially/ethnically/otherwise objectionable.
2. Infringing any third party’s copyright, trademark, patent, trade secret, or other intellectual property or proprietary rights.
3. Uploading or transmitting programs containing viruses, malware, or any other element designed to damage the App’s operation.
4. Attempting unauthorized access to any part of the App, servers, or connected systems.
5. Engaging in any activity that violates the laws of Singapore or any other jurisdiction.

Note on Referral Function: You acknowledge and agree that you are responsible for obtaining all necessary consents and adhering to all applicable privacy laws (including the PDPA) before submitting any third party’s personal data (e.g., client names, contact details) to the App for referral purposes.

4. Termination of Service

We reserve the right to suspend or terminate your access to the App at any time for any reason (including but not limited to breach of these Terms), without prior notice or liability. Upon termination, your right to use the App will immediately cease.

5. Disclaimer and Limitation of Liability

5.1 App Status

The App is provided on an “AS-IS” and “AS-AVAILABLE” basis without any warranties of any kind, either express or implied. KOSY LIVING PTE. LTD. does not warrant that the App will operate uninterrupted, securely, or error-free.

5.2 Limitation of Liability

To the maximum extent permitted by applicable law, KOSY LIVING PTE. LTD. and its directors, employees, partners, or agents shall not be liable for any indirect, incidental, special, consequential, or punitive damages (including but not limited to loss of profits, loss of data, or loss of goodwill), even if we have been advised of the possibility of such damages.

6. Governing Law and Dispute Resolution

6.1 Governing Law

These Terms shall be governed by and construed in accordance with the laws of the Republic of Singapore, without regard to its conflict of law principles.

6.2 Dispute Resolution

For any dispute, controversy, or claim arising out of or relating to the App or these Terms, both parties agree to first attempt resolution through good faith negotiations. If unresolved, both parties agree to the exclusive jurisdiction of the Courts of Singapore.

7. Miscellaneous Terms

7.1 Third-Party Links

The App may contain links to third-party websites or services that are not owned or controlled by us. We assume no responsibility for the content, privacy policies, or practices of any third-party websites.

7.2 Entire Agreement

These Terms and the Privacy Policy constitute the entire agreement between you and KOSY LIVING PTE. LTD. regarding the use of the App and supersede all prior or contemporaneous oral or written agreements.

8. Contact Us

If you have any questions about these Terms of Service or the Privacy Policy, please contact us at:

• Company Name: KOSY LIVING PTE. LTD.
• Email: contact@kosyliving.com
• Address: 6 Raffles Boulevard 03-208, Marina Square Singapore 039594

KOSY LIVING PTE. LTD.