caKao Privacy Policy

Effective Date: Aug 1, 2025
Last Updated: Aug 1, 2025

1. Introduction and Scope

caKao Inc., a corporation incorporated under the laws of Singapore ("caKao," "Company," "we," "us," or "our"), is committed to protecting and respecting your privacy rights by applicable data protection laws and regulations. This comprehensive Privacy Policy ("Policy") governs the collection, use, processing, storage, transfer, and disclosure of personal information obtained through your use of our AI-powered health and wellness platform, mobile application, and related services (collectively, the "Platform" or "Services").

This Policy applies to all users of our Platform, including visitors, registered users, and subscribers, regardless of their geographic location or method of access. By accessing, downloading, installing, or using our Platform in any capacity, you acknowledge that you have read, understood, and expressly consent to the data practices described in this Policy.

1.1 Legal Basis for Processing

Our processing of personal data is based on one or more of the following legal grounds:

  • Consent: Where you have provided explicit consent for specific processing activities

  • Contract Performance: Processing is necessary to perform our contractual obligations to you

  • Legitimate Interests: Processing necessary for our legitimate business interests, provided such interests do not override your fundamental rights and freedoms

  • Legal Compliance: Processing required to comply with applicable legal obligations

  • Vital Interests: Processing necessary to protect your vital interests or those of another person

1.2 Controller and Data Protection Officer

caKao Inc. acts as the data controller for personal information processed through our Platform. For data protection inquiries, you may contact our designated Data Protection Officer at: dpo@cakao.ai

2. Categories of Information We Collect

2.1 Account and Authentication Data

When you create an account through our integrated Single Sign-On (SSO) infrastructure utilizing Apple ID or Google authentication services, we collect and process:

Identity Information:

  • Unique user identifiers generated by authentication providers

  • Display names and profile information shared by your chosen authentication service

  • Account creation timestamps and authentication logs

Profile Data:

  • Age information is required for algorithmic personalization

  • Weight measurements for metabolic calculations

  • Height data for comprehensive health analytics

  • Gender information for tailored recommendations

  • Activity level assessments and fitness goals

  • Time zone and location preferences for scheduling

2.2 Health and Wellness Information

Our AI algorithms collect and analyze comprehensive health-related data to deliver personalized insights:

Nutritional Data:

  • Meal photographs and visual food content analysis

  • Caloric intake estimates and nutritional breakdowns

  • Macronutrient distribution (proteins, carbohydrates, fats, fiber)

  • Meal timing patterns and eating schedules

  • Food preferences and aversion profiles

Physical Activity Information:

  • Exercise types, duration, and intensity levels

  • Caloric expenditure calculations and metabolic data

  • Workout routines and fitness program adherence

  • Performance metrics and progress tracking

2.3 Technical and Usage Data

We automatically collect technical information to ensure Platform functionality and security:

Device Information:

  • Screen resolution and display characteristics

  • Hardware identifiers and device fingerprints

  • Network connectivity type and signal strength

Application Data:

  • Application version and build information

  • Feature usage patterns and interaction analytics

  • Session duration and frequency of use

  • Navigation paths and user flow analysis

  • Error logs and crash reports

  • Performance metrics and response times

  • Push notification preferences and delivery status

Network and Location Data:

  • IP addresses and geographic location indicators

  • Connection timestamps and session logs

  • Network performance and latency measurements

  • Time zone and locale settings

2.4 Visual and Media Content

All visual content processed through our Platform undergoes sophisticated handling:

Image Processing:

  • Original meal photographs captured through our camera interface

  • Processed image data for food recognition and analysis

  • Computer vision metadata and classification results

  • Image quality assessments and enhancement data

  • Cropping coordinates and region-of-interest selections

  • Color analysis and visual characteristics

  • Portion size estimations and scaling factors

Content Security:

  • Encrypted image storage with advanced cryptographic protocols

  • Access logs and viewing history for visual content

  • Sharing permissions and distribution controls

  • Retention timestamps and deletion schedules

3. Methods of Data Collection

3.1 Direct Collection

We collect information directly from you through:

  • Account registration and profile setup processes

  • Manual data entry through the Platform interfaces

  • File uploads and content submissions

  • Customer support interactions

  • Subscription and payment processes

3.2 Automatic Collection

Our Platform automatically collects certain information through:

  • Analytics tools and performance monitoring systems

  • Error logging and diagnostic reporting mechanisms

  • Usage analytics and behavioral tracking systems

  • Security monitoring and fraud detection systems

3.3 Third-Party Sources

We may receive information from external sources, including:

  • Authentication providers (Apple, Google)

  • Payment processors and billing services

  • Analytics and marketing service providers

  • Data enrichment and verification services

  • Public databases and regulatory sources

4. Purposes and Legal Basis for Processing

4.1 Primary Platform Functions

AI-Powered Personalization and Recommendations:

  • Processing health and wellness data to generate personalized caloric intake recommendations

  • Analyzing nutritional patterns to provide intelligent meal suggestions

  • Computing metabolic expenditure based on activity levels and biometric data

  • Delivering adaptive fitness guidance aligned with individual goals and capabilities

  • Creating customized wellness plans based on user preferences and health objectives

  • Generating predictive insights for health trend analysis and goal achievement

Food Recognition and Analysis:

  • Processing meal photographs through computer vision algorithms

  • Identifying food items, ingredients, and nutritional components

  • Estimating portion sizes and caloric content

  • Providing nutritional breakdowns and dietary insights

  • Tracking eating patterns and meal timing analysis

Platform Operations and Functionality:

  • Maintaining user accounts and authentication systems

  • Processing subscription management and billing operations

  • Providing customer support and technical assistance

  • Ensuring Platform security and preventing unauthorized access

  • Delivering push notifications 

  • Synchronizing data across multiple devices and platforms

4.2 Analytics and Improvement

Product Development and Enhancement:

  • Analyzing user behavior patterns to improve Platform functionality

  • Conducting A/B testing for feature optimization and user experience enhancement

  • Identifying usage trends and popular features for development prioritization

  • Measuring Platform performance and identifying areas for improvement

  • Developing new AI models and algorithmic capabilities

  • Enhancing user interface design and navigation flows

Research and Development:

  • Conducting anonymized research on health and wellness trends

  • Developing improved machine learning models for better predictions

  • Analyzing aggregated data for industry insights and benchmarking

  • Collaborating with research institutions on health-related studies

  • Publishing anonymized research findings for scientific advancement

4.3 Business Operations

Marketing and Communication:

  • Sending promotional materials and product updates (with consent)

  • Personalizing marketing content based on user preferences

  • Measuring marketing campaign effectiveness and engagement

  • Conducting market research and user satisfaction surveys

  • Managing affiliate and partnership programs

Legal and Regulatory Compliance:

  • Complying with applicable data protection and privacy laws

  • Responding to legal requests and regulatory inquiries

  • Maintaining records for audit and compliance purposes

  • Implementing security measures and breach notification procedures

  • Protecting intellectual property rights and preventing fraud

5. Data Sharing and Disclosure Practices

5.1 Service Providers and Vendors

We engage carefully vetted third-party service providers to support Platform operations:

Cloud Infrastructure Providers:

  • Data hosting and storage services with enterprise-grade security

  • Content delivery networks for optimal Platform performance

  • Backup and disaster recovery services

  • Database management and optimization services

Analytics and Performance Services:

  • User behavior analytics and Platform usage measurement

  • Performance monitoring and error tracking services

  • A/B testing platforms for feature optimization

  • Marketing analytics and campaign measurement tools

Payment and Billing Services:

  • Subscription management and recurring billing systems

  • Payment processing through Apple's secure infrastructure

  • Fraud detection and prevention services

  • Tax calculation and compliance services

Communication Services:

  • Push notification delivery systems

  • Survey and feedback collection tools

All service providers are bound by contractual obligations to maintain the confidentiality and security of your personal information and are prohibited from using your data for their purposes.

5.2 Business Transfers and Corporate Transactions

In the event of a merger, acquisition, reorganization, bankruptcy, or sale of assets, your personal information may be transferred as part of the business transaction. We will provide notice of any such transfer and any choices you may have regarding your personal information.

5.3 Legal Requirements and Protection

We may disclose your personal information when required or permitted by law:

Legal Process:

  • Compliance with court orders, subpoenas, and legal proceedings

  • Response to lawful requests from government agencies and regulatory bodies

  • Cooperation with law enforcement investigations

  • Compliance with tax reporting and regulatory requirements

Safety and Security:

  • Protection of our rights, property, and legitimate business interests

  • Prevention of fraud, abuse, and unauthorized access

  • Investigation of potential violations of our Terms of Service

  • Protection of the safety and security of users and third parties

5.4 Anonymized and Aggregated Data

We may share anonymized, aggregated, or de-identified information that cannot reasonably be used to identify you:

Research and Analytics:

  • Industry reports and trend analysis

  • Academic research collaborations

  • Public health studies and initiatives

  • Technology development and innovation projects

Business Intelligence:

  • Market research and competitive analysis

  • Product development and feature planning

  • Partnership and collaboration opportunities

  • Investment and funding activities

6. Data Security and Protection Measures

6.1 Technical Safeguards

We implement comprehensive security measures to protect your personal information:

Encryption and Cryptographic Protection:

  • Military-grade AES-256 encryption for data at rest

  • TLS 1.3 encryption for all data transmissions

  • End-to-end encryption for sensitive communications

  • Advanced key management and rotation protocols

  • Cryptographic hashing for password protection

Access Controls and Authentication:

  • Multi-factor authentication for administrative access

  • Role-based access controls with the principle of least privilege

  • Regular access reviews and permission audits

  • Secure API authentication and authorization mechanisms

  • Session management and timeout controls

Infrastructure Security:

  • Secure cloud hosting with enterprise-grade providers

  • Network firewalls and intrusion detection systems

  • Regular security scanning and vulnerability assessments

  • Automated threat detection and response systems

  • Secure backup and disaster recovery procedures

6.2 Organizational Safeguards

Compliance and Auditing:

  • Regular security audits and penetration testing

  • Compliance assessments and certification maintenance

  • Third-party security evaluations and validations

  • Continuous monitoring and improvement programs

  • Documentation and record-keeping procedures

Incident Response:

  • 24/7 security monitoring and alerting systems

  • Rapid incident detection and containment procedures

  • Forensic analysis and root cause investigation capabilities

  • User notification and regulatory reporting protocols

  • Post-incident review and improvement processes

6.3 Data Retention and Deletion

Retention Principles: We retain personal information only for as long as necessary to fulfill the purposes outlined in this Policy, comply with legal obligations, resolve disputes, and enforce our agreements.

Retention Periods:

  • Account information: Retained while your account is active and for up to 7 years after deletion for legal compliance

  • Health and wellness data: Retained for up to 5 years after last Platform use for AI model improvement

  • Technical logs: Retained for up to 2 years for security and performance analysis

  • Support communications: Retained for up to 3 years for quality assurance and training

Secure Deletion: When retention periods expire or upon valid deletion requests, we employ secure deletion methods including cryptographic erasure, overwriting, and physical destruction of storage media.

7. Your Privacy Rights and Controls

7.1 Access and Transparency Rights

Right to Access: You have the right to request information about:

  • Categories of personal information we collect and process

  • Specific pieces of personal information we maintain about you

  • Sources from which we collected your personal information

  • Business purposes for collecting and sharing your information

  • Third parties with whom we share your personal information

Right to Data Portability: You may request a copy of your personal information in a structured, machine-readable format for transfer to another service provider, subject to technical feasibility and legal restrictions.

7.2 Correction and Update Rights

Right to Rectification: You have the right to request correction of inaccurate or incomplete personal information. You can update most information directly through your Platform account settings, or contact us for assistance with corrections.

Profile Management: Our Platform provides comprehensive tools for managing your personal information:

  • Account settings for updating profile information

  • Privacy controls for managing data sharing preferences

  • Communication preferences for marketing and notifications

  • Data download tools for accessing your information

7.3 Deletion and Restriction Rights

Right to Erasure (Right to be Forgotten): You may request deletion of your personal information under certain circumstances:

  • The information is no longer necessary for the original purposes

  • You withdraw consent, and no other legal basis exists

  • Your information has been unlawfully processed

  • Deletion is required for compliance with legal obligations

Right to Restrict Processing: You may request that we limit our processing of your personal information in certain situations:

  • You contest the accuracy of the information

  • Processing is unlawful, but you prefer restriction over deletion

  • We no longer need the information, but you require it for legal claims

  • You object to processing pending verification of legitimate grounds

Account Deletion: You may delete your account at any time through our advanced settings management interface. Upon deletion:

  • Your account will be immediately deactivated

  • Personal information will be deleted by our retention policies

  • Some information may be retained for legal compliance and legitimate business purposes

  • Anonymized data may be retained for research and development purposes

7.4 Objection and Opt-Out Rights

Right to Object: You have the right to object to the processing of your personal information based on legitimate interests, including:

  • Direct marketing and promotional communications

  • Profiling for marketing purposes

  • Processing for research and development activities

  • Automated decision-making processes

Marketing Opt-Out: You can opt out of marketing communications through:

  • Unsubscribe links in email communications

  • Direct contact with our support team

  • Third-party marketing preference centers

7.5 Exercising Your Rights

To exercise any of your privacy rights, please contact us using the information provided in the Contact section. We will respond to your request within the timeframes required by applicable law, typically within 30 days.

Verification Requirements: To protect your privacy and security, we may need to verify your identity before processing certain requests. This may include:

  • Confirming your account credentials

  • Requesting additional identification documents

  • Using multi-factor authentication

  • Confirming details about your Platform usage

8. International Data Transfers and Cross-Border Processing

8.1 Global Operations

As a technology company with global infrastructure and user base, your personal information may be transferred to, processed, and stored in countries outside your country of residence, including Singapore, the United States, and other jurisdictions where our service providers operate.

8.2 Transfer Safeguards

We ensure appropriate safeguards are in place for international data transfers:

Adequacy Decisions: We transfer data to countries that have been deemed to provide adequate protection by relevant data protection authorities.

Standard Contractual Clauses: For transfers to countries without adequacy decisions, we use Standard Contractual Clauses (SCCs) approved by the European Commission or other relevant authorities.

Additional Safeguards: We implement supplementary technical and organizational measures to ensure the security of international data transfers:

  • Enhanced encryption for cross-border data transmission

  • Strict data localization controls where required

  • Regular assessments of transfer risks and safeguards

  • Contractual commitments from international service providers

8.3 Data Localization Compliance

Where applicable law requires data localization or imposes restrictions on international transfers, we maintain compliance through:

  • Local data processing and storage infrastructure

  • Regional service provider arrangements

  • Jurisdiction-specific privacy controls

  • Compliance monitoring and reporting systems

9. Children's Privacy Protection

9.1 Age Restrictions

Our Platform is not intended for use by children under the age of 13. We do not knowingly collect, use, or disclose personal information from children under 13 without verifiable parental consent.

9.2 Parental Consent Requirements

For users between the ages of 13 and 18 (or the age of majority in their jurisdiction), we require:

  • Explicit parental consent before account creation

  • Parental notification of our privacy practices

  • Ongoing parental rights to access and control their child's information

  • Special protections for sensitive health information

9.3 Discovery and Deletion

If we discover that we have collected personal information from a child under 13 without proper consent:

  • We will immediately cease processing the information

  • The account and associated data will be promptly deleted

  • Parents will be notified of the collection and deletion

  • We will implement additional safeguards to prevent future occurrences

10. California Privacy Rights (CCPA/CPRA)

10.1 California Consumer Rights

California residents have additional privacy rights under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA):

Right to Know:

  • Categories and specific pieces of personal information collected

  • Categories of sources from which information is collected

  • Business purposes for collecting and selling personal information

  • Categories of third parties with whom information is shared

Right to Delete: Request deletion of personal information, subject to certain exceptions for legal compliance, security, and legitimate business purposes.

Right to Opt-Out: Opt out of the sale or sharing of personal information for targeted advertising purposes.

Right to Correct: Request correction of inaccurate personal information maintained by the business.

Right to Limit Use of Sensitive Personal Information: Request limitation of use and disclosure of sensitive personal information to necessary business purposes.

10.2 Non-Discrimination

We do not discriminate against California consumers who exercise their privacy rights by:

  • Denying goods or services

  • Charging different prices or rates

  • Providing different levels or quality of services

  • Suggesting different prices or service levels

10.3 Authorized Agents

California residents may designate an authorized agent to submit privacy requests on their behalf. We may require:

  • Proof of the agent's authorization

  • Verification of the consumer's identity

  • Direct confirmation from the consumer of the agent's authority

11. European Privacy Rights (GDPR)

11.1 Legal Basis for Processing

For users in the European Economic Area (EEA), the United Kingdom, and Switzerland, we process personal data based on:

Consent: Explicit consent for specific processing activities, marketing communications, and optional features.

Contract Performance: Processing is necessary to provide Platform services and fulfill our contractual obligations.

Legitimate Interests: Processing for business operations, security, fraud prevention, and service improvement, where our interests do not override your fundamental rights.

Legal Compliance: Processing required to comply with applicable laws and regulations.

11.2 Additional Rights

European users have additional rights under the General Data Protection Regulation (GDPR):

Right to Withdraw Consent: Where processing is based on consent, you may withdraw consent at any time without affecting the lawfulness of processing before withdrawal.

Right to Lodge a Complaint: You have the right to complain with a supervisory authority in your country of residence, place of work, or where an alleged infringement occurred.

Automated Decision-Making: You have the right not to be subject to automated decision-making, including profiling, that produces legal effects or significantly affects you.

11.3 Data Protection Impact Assessments

We conduct Data Protection Impact Assessments (DPIAs) for high-risk processing activities and implement appropriate measures to mitigate identified risks.

12. Other Jurisdictional Privacy Rights

12.1 Brazil (LGPD)

For users in Brazil, we comply with the Lei Geral de Proteção de Dados (LGPD) and provide rights including:

  • Confirmation of processing and access to data

  • Correction of incomplete or inaccurate data

  • Anonymization, blocking, or deletion of data

  • Portability of data to another service provider

  • Information about public and private entities with whom data is shared

12.2 Canada (PIPEDA)

For Canadian users, we comply with the Personal Information Protection and Electronic Documents Act (PIPEDA) and provide:

  • Access to personal information and correction rights

  • Withdrawal of consent for certain processing activities

  • Complaint procedures through the Privacy Commissioner of Canada

12.3 Australia (Privacy Act)

For Australian users, we comply with the Privacy Act 1988 and Australian Privacy Principles (APPs), providing:

  • Access to personal information and correction rights

  • Notification of data breaches affecting user privacy

  • Complaint procedures through the Office of the Australian Information Commissioner

13. Data Breach Notification and Response

13.1 Breach Detection and Assessment

We maintain comprehensive systems for detecting and assessing potential data breaches:

  • Continuous monitoring and threat detection systems

  • Automated alerting for suspicious activities

  • Regular security assessments and penetration testing

  • Employee training on breach identification and reporting

13.2 Incident Response Procedures

Upon detection of a potential breach, we implement our incident response plan:

Immediate Response (0-24 hours):

  • Containment and mitigation of the breach

  • Assessment of scope and potential impact

  • Preservation of evidence for investigation

  • Initial stakeholder notification

Investigation Phase (24-72 hours):

  • Forensic analysis and root cause determination

  • Impact assessment and affected user identification

  • Documentation and evidence collection

  • Coordination with law enforcement, if necessary

Notification and Remediation (72 hours+):

  • Regulatory notification as required by applicable law

  • User notification for high-risk breaches

  • Implementation of additional security measures

  • Ongoing monitoring and support for affected users

13.3 User Notification

We will notify affected users of data breaches that pose a high risk to their rights and freedoms:

  • Direct notification via email or in-app messaging

  • Clear description of the nature and scope of the breach

  • Information about potential consequences and recommended actions

  • Details of measures taken to address the breach

  • Contact information for additional questions or support

14. Third-Party Integrations and Links

14.1 Authentication Services

Our Platform integrates with third-party authentication providers:

Apple ID Integration:

  • Governed by Apple's Privacy Policy and Terms of Service

  • Limited data sharing based on user-selected preferences

  • Secure OAuth 2.0 authentication protocols

  • Option to hide email address from caKao

Google Account Integration:

  • Governed by Google's Privacy Policy and Terms of Service

  • Scope-limited access to basic profile information

  • Secure authentication with minimal data collection

  • User control over shared information

14.2 Payment Processing

Subscription and payment processing are handled by Apple's App Store:

  • All payment information is processed by Apple

  • caKao does not have access to payment card details

  • Billing inquiries should be directed to Apple Support

  • Refund policies are governed by Apple's terms

14.3 External Links and Services

Our Platform may contain links to external websites and services:

  • Third-party privacy policies govern data collection on external sites

  • We are not responsible for external privacy practices

  • Users should review privacy policies before sharing information

  • Links do not constitute endorsement of external services

15. Marketing and Communications

15.1 Types of Communications

We may send various types of communications based on your preferences:

Transactional Communications:

  • Account notifications and security alerts

  • Subscription and billing confirmations

  • Platform updates and maintenance notices

  • Customer support responses

Marketing Communications:

  • Product updates and new feature announcements

  • Promotional offers and special discounts

  • Health and wellness tips and content

  • Survey requests and feedback opportunities

15.2 Consent and Opt-Out

Email Marketing:

  • Explicit opt-in consent is required for promotional emails

  • Clear unsubscribe options in all marketing communications

  • Immediate processing of opt-out requests

  • Preference management for different types of content

Push Notifications:

  • Device-level permission controls

  • In-app notification preferences and settings

  • Granular control over notification types

  • Immediate effect of preference changes

15.3 Personalization

We may personalize marketing communications based on:

  • Platform usage patterns and preferences

  • Health and wellness goals and interests

  • Subscription status and feature usage

  • Geographic location and time zone

All personalization respects your privacy settings and communication preferences.

16. Business-to-Business Services

16.1 Enterprise and Research Partnerships

We may offer specialized services to healthcare providers, research institutions, and corporate wellness programs:

Aggregated Analytics:

  • De-identified population health insights

  • Wellness trend analysis and reporting

  • Benchmarking and comparative analytics

  • Custom research and data analysis services

API and Integration Services:

  • Secure data integration with healthcare systems

  • Custom reporting and dashboard solutions

  • Compliance-focused data sharing arrangements

  • White-label and co-branded platform options

16.2 Data Protection for B2B Services

All business-to-business services maintain strict data protection standards:

  • Separate data processing agreements and contracts

  • Enhanced security measures for sensitive health data

  • Regular compliance audits and assessments

  • Strict access controls and monitoring

17. Artificial Intelligence and Automated Processing

17.1 AI Systems and Decision-Making

Our Platform employs sophisticated AI systems for various purposes:

Computer Vision and Image Recognition:

  • Automated food identification and nutritional analysis

  • Portion size estimation and caloric calculation

  • Ingredient recognition and allergen detection

  • Meal quality assessment and recommendations

Predictive Analytics:

  • Personalized health and wellness recommendations

  • Goal achievement probability and timeline estimation

  • Risk assessment for health-related outcomes

  • Behavioral pattern analysis and intervention suggestions

Machine Learning Optimization:

  • Continuous improvement of recommendation accuracy

  • Personalization algorithm enhancement

  • User experience optimization and customization

  • Platform performance and efficiency improvements

17.2 Human Oversight and Intervention

While our AI systems operate with high accuracy, we maintain human oversight:

  • Regular algorithm auditing and bias testing

  • Human review of high-impact decisions

  • User feedback integration and correction mechanisms

  • Manual override capabilities for automated processes

17.3 Transparency and Explainability

We strive to provide transparency about our AI systems:

  • General explanations of how our algorithms work

  • Information about the data used for training and improvement

  • User controls for automated processing preferences

  • Feedback mechanisms for algorithm improvement

18. Data Innovation and Research

18.1 Research and Development

We research to advance health and wellness technology:

Internal Research:

  • Algorithm improvement and optimization studies

  • User behavior and engagement analysis

  • Platform effectiveness and outcome measurement

  • Technology innovation and development projects

External Collaborations:

  • Academic research partnerships and studies

  • Healthcare industry collaborations

  • Public health research initiatives

  • Technology advancement consortia

18.2 Research Data Protection

All research activities maintain strict privacy protections:

  • De-identification and anonymization of research data

  • Institutional Review Board (IRB) approval for human subjects research

  • Informed consent for research participation

  • Secure data sharing agreements with research partners

18.3 Innovation Benefits

Our research activities benefit users through:

  • Improved algorithm accuracy and personalization

  • Enhanced platform features and capabilities

  • Better health outcomes and user experiences

  • Advancement of digital health technology

19. Compliance and Certifications

19.1 Industry Standards and Certifications

We maintain compliance with relevant industry standards:

Information Security:

  • ISO 27001 Information Security Management

  • SOC 2 Type II Security and Availability

  • NIST Cybersecurity Framework alignment

  • Regular third-party security assessments

Healthcare Standards:

  • HIPAA-level security controls (where applicable)

  • FDA guidance for digital health tools

  • Healthcare data interoperability standards

  • Clinical research good practices

Privacy and Data Protection:

  • Privacy by Design and Default principles

  • Data minimization and purpose limitation

  • Consent management and user control systems

  • Cross-border data transfer safeguards

19.2 Regular Audits and Assessments

We conduct regular compliance evaluations:

  • Annual privacy impact assessments

  • Quarterly security audits and penetration testing

  • Ongoing vendor and partner compliance reviews

  • Regular legal and regulatory compliance updates

19.3 Continuous Improvement

Our compliance program includes:

  • Regular policy and procedure updates

  • Employee training and awareness programs

  • Industry best practice adoption

  • Stakeholder feedback integration

20. Contact Information and Data Protection Contacts

20.1 General Privacy Inquiries

For general privacy questions, concerns, or requests, please contact us:

Email: team@cakao.ai
Subject Line: Privacy Inquiry - [Your Request Type]

Response Time: We respond to privacy inquiries within 5 business days and provide substantive responses within 30 days as required by applicable law.

20.2 Data Protection Officer

Our designated Data Protection Officer handles complex privacy matters:

Email: team@cakao.ai
Responsibilities:

  • Privacy impact assessments and compliance oversight

  • Data breach response coordination

  • Cross-border transfer compliance

  • Regulatory relationship management

20.3 User Rights Requests

To exercise your privacy rights, please use our dedicated portal:

Email: team@cakao.ai
Required Information:

  • Full name and account email address

  • Specific right you wish to exercise

  • Relevant details about your request

  • Identity verification information (as needed)

20.4 Security Incident Reporting

To report security concerns or potential data breaches:

Email: team@cakao.ai
Phone: [Emergency Security Hotline - Available 24/7]

20.5 Customer Support

For general Platform support and account assistance:

Email: team@cakao.ai
In-App Support: Available through Platform settings 

20.6 Corporate Information

caKao Inc.
Corporate Headquarters:
One-North district
Singapore

20.7 Regulatory Contacts

For users in specific jurisdictions, you may also contact relevant data protection authorities:

 European Union: Your local Data Protection Authority
United Kingdom: Information Commissioner's Office (ICO)
California: California Attorney General's Office
Canada: Office of the Privacy Commissioner of Canada
Australia: Office of the Australian Information Commissioner

21. Policy Updates and Change Management

21.1 Policy Review and Updates

We regularly review and update this Privacy Policy to ensure:

  • Compliance with evolving legal requirements

  • Reflection of new Platform features and capabilities

  • Incorporation of user feedback and industry best practices

  • Alignment with organizational changes and business developments

21.2 Material Changes

Material changes to this Policy include:

  • Changes to the types of personal information collected

  • New purposes for processing personal information

  • Changes to data sharing or disclosure practices

  • Modifications to user rights or procedures

  • Changes to data retention periods or deletion practices

21.3 Notification Procedures

We will notify users of material changes through:

Direct Notification:

  • Email notifications to registered users

  • In-app notifications and alerts

  • Account dashboard notifications

  • Push notifications (where enabled)

Public Notice:

  • Updates to our website at www.cakao.ai/privacy

  • Social media announcements

  • Platform release notes and change logs

  • Public blog posts and communications

21.4 Effective Date and Transition

New Policy Effective Date: Material changes take effect 30 days after notification, allowing users sufficient time to review changes and exercise their rights.

Transition Period:

  • Users may opt out or delete their accounts before changes take effect

  • Existing data processing continues under the previous terms during the transition

  • New features or processing activities require explicit consent

  • Legacy users maintain grandfathered rights where applicable

Version Control: We maintain historical versions of our Privacy Policy for reference:

  • Previous versions available at www.cakao.ai/privacy/archive

  • Change logs documenting specific modifications

  • Effective dates and transition timelines

  • User communication records and notifications

22. Emergency Procedures and Crisis Management

22.1 Platform Discontinuation

In the unlikely event of Platform discontinuation, we will:

User Notification (90 days minimum):

  • Email notifications to all registered users

  • In-app notifications and dashboard alerts

  • Website announcements and public communications

  • Social media notifications and press releases

Data Export and Transfer:

  • Comprehensive data export tools and procedures

  • Assistance with data transfer to alternative platforms

  • Extended data retention period for user access

  • Secure data destruction timelines and procedures

Service Wind-Down:

  • Gradual feature deprecation with advance notice

  • Continued customer support during the transition period

  • Account closure assistance and final billing reconciliation

  • Legacy access for data retrieval and export

22.2 Emergency Data Access

In emergencies affecting user safety or public health:

Limited Emergency Processing:

  • Processing may occur without typical consent requirements

  • Strict limitation to emergency purposes only

  • Immediate cessation once emergency conditions end

  • Documentation and audit trail of emergency processing

Legal and Regulatory Coordination:

  • Cooperation with public health authorities

  • Compliance with emergency legal requirements

  • Transparent reporting of emergency processing activities

  • Post-emergency review and improvement procedures

22.3 Business Continuity

Our business continuity planning includes:

  • Redundant data processing and storage systems

  • Alternative service delivery mechanisms

  • Emergency communication procedures

  • Vendor and partner contingency arrangements

23. Specific Regional Compliance

23.1 Asia-Pacific Region

Singapore Personal Data Protection Act (PDPA):

  • Consent management for collection, use, and disclosure

  • Purpose limitation and notification requirements

  • Data breach notification to authorities and individuals

  • Do Not Call Registry compliance for marketing

Australian Privacy Principles (APPs):

  • Open and transparent privacy policy requirements

  • Data quality and security safeguards

  • Individual access and correction rights

  • Notifiable data breach obligations

Japan Personal Information Protection Act (PIPA):

  • Lawful basis for processing personal information

  • Cross-border transfer restrictions and safeguards

  • Individual rights and complaint procedures

  • Consent requirements for sensitive information

23.2 European Union and United Kingdom

GDPR Article 30 Records: We maintain comprehensive records of processing activities, including:

  • Purposes of processing and legal basis

  • Categories of data subjects and personal data

  • Recipients and international transfers

  • Retention periods and security measures

UK Data Protection Act 2018:

  • Compliance with UK GDPR requirements

  • Information Commissioner's Office (ICO) guidance

  • Lawful basis assessment and documentation

  • Special category data protection measures

Brexit Transition Compliance:

  • Separate UK adequacy assessment compliance

  • UK-specific data transfer mechanisms

  • Dual compliance with EU and UK requirements

  • Regular monitoring of regulatory changes

23.3 Americas Region

Canadian Personal Information Protection and Electronic Documents Act (PIPEDA):

  • Meaningful consent requirements

  • Individual access and correction rights

  • Breach notification to the Privacy Commissioner

  • Cross-border transfer accountability

Mexican Federal Law on Protection of Personal Data (LFPDPPP):

  • Privacy notice requirements and consent management

  • Individual rights (ARCO rights) procedures

  • Data transfer impact assessments

  • National Institute transparency obligations

Brazilian Lei Geral de Proteção de Dados (LGPD):

  • Lawful basis for processing activities

  • Data subject rights and response procedures

  • Data Protection Impact Assessment requirements

  • National Data Protection Authority (ANPD) compliance

24. Conclusion and Commitment

24.1 Our Privacy Commitment

At caKao, privacy is not just a legal requirement; it is a fundamental principle that guides every aspect of our Platform development and operations. We are committed to:

Continuous Improvement:

  • Regular assessment and enhancement of privacy practices

  • Integration of emerging privacy technologies and best practices

  • Responsive adaptation to user feedback and concerns

  • Proactive compliance with evolving regulatory requirements

  • Transparent communication about our privacy practices and changes

User Empowerment:

  • Meaningful control over personal information and privacy settings

  • Clear, accessible information about our data practices

  • Responsive customer support for privacy-related inquiries

  • Regular education and awareness about privacy rights and options

  • Advocacy for user privacy rights in industry and policy discussions

Innovation with Privacy:

  • Privacy-by-design approach to all Platform development

  • Investment in privacy-enhancing technologies and solutions

  • Collaboration with privacy experts and advocacy organizations

  • Research and development of privacy-preserving AI and analytics

  • Leadership in responsible data stewardship and digital ethics

24.2 Long-Term Vision

We envision a future where:

  • Users have complete transparency and control over their personal information

  • AI technology enhances human health and wellness while protecting privacy

  • Digital platforms serve users' best interests with trust and accountability

  • Privacy protection enables rather than hinders technological innovation

  • Global privacy standards create consistent protection for all users

24.3 Ongoing Dialogue

We welcome feedback, questions, and suggestions about our privacy practices:

  • Regular user surveys and feedback collection

  • Privacy advisory group and community engagement

  • Academic and industry collaboration on privacy research

  • Public consultation on significant privacy policy changes

  • Transparent reporting on privacy metrics and improvements

Legal Disclaimer: This Privacy Policy is governed by the laws of Singapore and forms part of our comprehensive legal framework for Platform operations. In the event of any conflict between this Policy and applicable law, the requirements of applicable law shall prevail. This Policy does not create any contractual rights or legal obligations beyond those required by applicable privacy and data protection laws.

Language and Translation: This Privacy Policy was originally drafted in English. Translations into other languages are provided for convenience only. In case of any discrepancy between the English version and any translation, the English version shall prevail.

Contact for Legal and Compliance Matters: For legal, compliance, or regulatory inquiries related to this Privacy Policy, please contact our Legal Department at team@cakao.ai.