Privacy Policy

Effective Date: 8 Jun 2026
Last Updated: 8 Jun 2026

1. Introduction

BetterPay ("we", "our", "us") is a product operated by HUMANMAX AI PTE. LTD., a company incorporated in Singapore. We are committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our career intelligence platform ("Service").

Geographic Availability: Our services are primarily designed for and available to users in Singapore and the Asia-Pacific region. We do not provide services to users located in the European Union (EU) or European Economic Area (EEA). Users from other jurisdictions may access our services but without specific legal protections or guarantees.

By using our Service, you confirm that you are not located in the EU/EEA and consent to the data practices described in this policy.

2. Information We Collect

2.1 Personal Information

We collect the following personal information:

Account Information:

• Full name (first and last name)
• Email address
• Password (encrypted)
• Profile picture (if provided)

Professional Information:

• Current job title/role
• Years of experience
• Industry/sector
• Current salary information
• Location/geographic data
• Résumé/CV — processed in memory only to extract structured findings; the original file is never stored (see Section 9 and our CV Processing Notice & AUP)
• Structured findings extracted from your CV (skills, roles, seniority, education, employment history)
• Career history
• Skills and qualifications

Google OAuth Information: When you sign in with Google, we collect:

• Google account ID
• Name (first and last)
• Email address
• Profile picture
• Basic profile information

2.2 Automatically Collected Information

Usage Data:

• IP address
• Browser type and version
• Device information
• Operating system
• Pages visited and time spent
• Click patterns and navigation paths
• Search queries within our platform
• Feature usage statistics

Technical Data:

• Session information
• Cookies and similar technologies
• Log files
• Error reports and diagnostics

2.3 Location Information

• Country and city (from IP address)
• Location data you provide in your profile
• Geographic salary benchmarking data

3. How We Use Your Information

3.1 Primary Uses

We use your information to:

• Create and manage your account
• Provide personalized career insights
• Analyse your CV and match you with relevant job openings
• Generate salary benchmarking reports
• Deliver job market analytics
• Process authentication and security
• Respond to your inquiries and support requests

3.2 Analytics and Improvements

• Analyze platform usage patterns
• Improve our services and user experience
• Develop new features and functionality
• Conduct research on career trends
• Generate aggregate market insights

3.3 Communications

• Send service-related notifications
• Provide account updates and security alerts
• Share relevant career opportunities (with consent)
• Deliver newsletters and platform updates (with consent)
• Respond to customer service requests

4. Legal Basis for Processing

4.1 Service Availability Notice

Important: Our services are primarily designed for users in Singapore and the Asia-Pacific region. We do not provide services to users located in the European Union or European Economic Area. Users from other jurisdictions may access our services at their own discretion without specific legal protections.

4.2 PDPA (Singapore Users)

Under Singapore's Personal Data Protection Act (PDPA), we collect and use personal data for the following purposes:

• Primary Purpose: Providing career intelligence and salary benchmarking services
• Secondary Purposes: Platform improvement, customer support, and service communications
• Consent-Based Processing: Marketing communications and optional analytics (with explicit consent)
• Legitimate Business Interests: Fraud prevention, security, and legal compliance

4.3 Asia-Pacific Region Users

For users in the Asia-Pacific region outside Singapore, we process personal data based on:

• Contractual Necessity: To provide our services as agreed
• Legitimate Business Interests: Platform operation, security, and improvement
• Consent: Where required by local law or for optional features
• Legal Compliance: To meet applicable regulatory requirements

4.4 Other Jurisdictions (No Legal Guarantees)

Users from jurisdictions outside Singapore and Asia-Pacific may access our services, but we:

• Do not guarantee compliance with local privacy laws
• Provide no specific legal protections beyond basic service delivery
• Process data based on legitimate business interests and contractual necessity only
• Recommend users review their local privacy laws before using our services

5. Data Sharing and Disclosure

5.1 We Do NOT Sell Your Data

We do not sell, rent, or trade your personal information to third parties.

5.2 Aggregate Data Sharing

We may share anonymized, aggregate data that cannot identify you:

• Industry salary trends and benchmarks
• Career progression patterns
• Job market analytics
• Research publications

5.3 Third-Party Service Providers

We share limited data with trusted service providers:

Google OAuth: For authentication services Cloud Storage: AWS/Google Cloud for data hosting AI Service Provider: To analyse your CV and generate structured career insights. Before any text is sent, we redact direct identifiers (name, email, phone, address), and the original file is never stored. This provider may process data outside Singapore under contractual safeguards (see Section 10). Analytics: For platform improvement (anonymized data) Email Services: For transactional communications Payment Processor: A secure third-party payment provider, for subscription billing (if applicable)

5.4 Legal Disclosure

We may disclose your information when required by:

• Valid legal process or court orders
• Government investigations
• Protection of our rights or property
• Prevention of fraud or illegal activities
• Emergency situations involving personal safety

6. Data Security

6.1 Security Measures

We implement industry-standard security practices:

• Encryption in transit and at rest
• Secure authentication protocols
• Regular security audits and updates
• Access controls and monitoring
• Employee training on data protection

6.2 Data Breach Response

In case of a data breach:

• We will assess and contain the breach without delay
• Where the breach is notifiable under the PDPA, we will notify the Personal Data Protection Commission (PDPC) within the timeframe required by law (within 3 calendar days of assessing it as notifiable)
• We will notify affected individuals as soon as practicable where the breach is likely to result in significant harm
• We will provide guidance on protective measures

7. Your Privacy Rights

7.1 Access and Control

You have the right to:

• Access your personal data
• Update or correct inaccurate information
• Delete your account and associated data
• Export your data in a portable format
• Withdraw consent for optional data processing

7.2 PDPA Rights (Singapore Users)

Under Singapore's PDPA, you have the right to:

• Access: Request information about personal data we hold about you
• Correction: Request correction of inaccurate personal data
• Withdrawal of Consent: Withdraw consent for processing (where consent is the legal basis)
• Data Portability: Receive your personal data in a structured format
• Complaints: Lodge complaints with the Personal Data Protection Commission (PDPC)

7.3 Users from Other Jurisdictions

Users from jurisdictions outside Singapore and Asia-Pacific:

• Limited Rights: May have basic access and deletion rights only
• No Guaranteed Protections: We do not guarantee compliance with local privacy laws
• Self-Assessment Required: Users should assess their local privacy law requirements
• Contact Support: For data requests, contact security@humanmax.ai

7.4 Exercising Your Rights

To exercise your rights:

• Email: security@humanmax.ai
• Account settings: Update through your profile
• Data deletion: Request through support or account settings

8. Cookies and Tracking Technologies

8.1 Types of Cookies We Use

Essential Cookies: Required for platform functionality Analytics Cookies: Help us understand usage patterns Preference Cookies: Remember your settings and preferences Security Cookies: Protect against fraud and unauthorized access

8.2 Cookie Management

You can control cookies through:

• Browser settings
• Our cookie preference center
• Opt-out tools for analytics services

8.3 Third-Party Tracking

We use Google Analytics for usage insights (anonymized data only)

9. Data Retention

9.1 Retention Periods

• Active accounts: Data retained while account is active
• CV analysis (structured findings): The original CV file is never stored. The structured findings are retained until you delete the analysis or your account — there is no automatic time-based expiry. You can delete any analysis at any time from your dashboard.
• Inactive accounts: Data deleted after 3 years of inactivity
• Deleted accounts: Most data deleted within 30 days
• Legal requirements: Some data retained longer if required by law

9.2 Backup Data

Backup systems may retain data for up to 90 days after deletion

10. International Data Transfers

10.1 Data Location

Your data may be processed in:

• Singapore (primary data center)
• Asia-Pacific region (regional data centers)
• Third-party cloud providers (global infrastructure as needed)

10.2 Transfer Safeguards

We ensure appropriate safeguards for international transfers:

• PDPA: Contractual safeguards and adequacy assessments for overseas transfers
• General: Certification schemes and binding corporate rules
• Industry Standards: Compliance with recognized data protection frameworks

10.3 PDPA Overseas Transfer Requirements

For Singapore users, when transferring personal data overseas, we ensure:

• Adequate level of protection in the receiving country/organization
• Contractual obligations requiring recipient to provide comparable protection
• Your consent where required by law
• Compliance with PDPC guidelines on overseas data transfers

11. Children's Privacy

11.1 Age Restrictions

• Our Service is intended only for users aged 18 and over
• We do not knowingly collect personal data from anyone under 18
• If we discover that we have collected data from a minor, we will delete it
• A parent or guardian may contact us to request removal of a minor's data

12. Updates to Privacy Policy

12.1 Policy Changes

• We may update this policy periodically
• Material changes will be notified via email or platform notice
• Continued use after changes constitutes acceptance
• Previous versions are archived and available upon request

12.2 Notification Methods

• Email notification to registered users
• Prominent notice on our platform
• 30-day advance notice for material changes

13. Contact Information

13.1 Privacy Questions

For privacy-related inquiries:

• Email: security@humanmax.ai
• Subject Line: "Privacy Policy Inquiry"
• Response Time: Within 7 business days

13.2 Data Protection Officer

For data protection matters:

• Email: security@humanmax.ai
• Response Time: Within 30 days

13.3 Legal Entity & Business Address

• Legal Entity: HUMANMAX AI PTE. LTD.
• Jurisdiction: Singapore
• Registered Address: 808 French Road, #05-155 Kitchener Complex, Singapore 200808

13.4 PDPA Contact (Singapore Users)

For PDPA-related matters:

• Email: security@humanmax.ai
• Subject Line: "PDPA Privacy Inquiry"
• Response Time: Within 30 days
• PDPC Complaints: You may also file complaints directly with the Personal Data Protection Commission at https://www.pdpc.gov.sg

14. Specific Consent Agreements

14.1 Google OAuth Consent

By using Google Sign-In, you consent to:

• Sharing your Google profile information with us
• Our access to your basic profile data
• Storage of your Google account ID for authentication
• Use of your Google email for account communications

14.2 Salary Data Consent

By providing salary information, you consent to:

• Use of your salary data for benchmarking (anonymized)
• Inclusion in aggregate market reports
• Comparison with similar roles and locations
• Career progression analysis

14.3 Location Data Consent

By providing location information, you consent to:

• Geographic salary comparisons
• Local job market insights
• Location-based feature recommendations
• Regional career trend analysis

14.4 Marketing Communications Consent

You may opt-in to receive:

• Career opportunity notifications
• Industry insights and reports
• Platform feature updates
• Newsletter and educational content

You can withdraw consent at any time through your account settings or by contacting us.

15. PDPA Compliance (Singapore Users)

15.1 Notification Obligations

We comply with PDPA notification requirements by:

• Providing clear notice of data collection purposes at the point of collection
• Informing you of your rights under the PDPA
• Notifying you of any material changes to our data practices

15.2 Consent Management

• Express Consent: Required for marketing communications and non-essential processing
• Deemed Consent: Applied where permitted by law for legitimate business purposes
• Withdrawal Rights: You may withdraw consent at any time with reasonable notice

15.3 Data Breach Notification

In case of a data breach affecting Singapore users:

• We will assess and contain the breach immediately
• Notify the PDPC within 72 hours if required by law
• Notify affected individuals without undue delay if there is significant risk of harm
• Provide clear guidance on protective measures

15.4 Access and Correction Procedures

Singapore users may request access to or correction of personal data by:

1. Online: Through your account settings
2. Email: security@humanmax.ai with "PDPA Access Request" or "PDPA Correction Request"
3. Response Time: Within 30 days of receipt
4. Fees: Reasonable administrative fees may apply for access requests

15.5 Data Protection Officer (Singapore)

We have appointed a Data Protection Officer for Singapore operations:

• Email: security@humanmax.ai
• Responsibilities: PDPA compliance oversight, breach response, user rights management

16. Data Processing Activities Summary

---

By using BetterPay, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and use of your information as described herein.

Last Review Date: 8 Jun 2026
Next Scheduled Review: 8 Jun 2027