FD AI

1.1 Definitions.

In this Privacy Policy (the "Policy"), unless the subject or context otherwise requires, the following words and expressions shall have the following meanings:

• (a) "AI" refers to artificial intelligence systems, including large language models, machine learning algorithms, and automated processing tools that generate, review, analyse, or assist with content delivery as part of the Services;
• (b) "Children" refers to individuals under the age of 18, and the term "Child" shall be construed accordingly;
• (c) "Founders Doc", "we", "our", or "us" refers to Founders Doc Pte. Ltd., a private limited company incorporated in Singapore, together with its subsidiaries and affiliates as established from time to time, which operates and manages Founders Doc AI (otherwise known as FD AI);
• (d) "Legal Document(s)" refers to any legal template, agreement, or contract provided by Founders Doc AI (otherwise known as FD AI) through its Platforms;
• (e) "Personal Data" refers to data, whether true or not, about an individual who can be identified (i) from that data; or (ii) from that data and other information to which we have or are likely to have access. This includes any data that is subject to protection under the Personal Data Protection Act 2012 of Singapore;
• (f) "Platforms" refers to Founders Doc AI (otherwise known as FD AI)'s digital services, including this website, web-based applications, and any other related online services;
• (g) "process", "processing" or any variation thereof means carrying out any operation or set of operations on Personal Data including, but not limited to, collecting, obtaining, organising, consulting, using, disclosing, and destroying;
• (h) "Services" refers to the provision of AI-enabled legal document generation, document review tools, and other automated legal solutions made available through our Platforms, including any associated features such as user uploads, integrations, or APIs; and
• (i) "user" or "you" refers to any individual, person, company, or entity accessing or using our Platforms and Services, including individuals acting in a professional or business capacity.

1.2 Scope of Application.

This Policy applies to:

• (a) individuals and entities that interact with Founders Doc (trading as "Founders Doc AI" or "FD AI"), including users based in Singapore and users outside Singapore who voluntarily access our Platforms and/or use our Services;
• (b) individuals who interact with Founders Doc (trading as "Founders Doc AI" or "FD AI") for business or other purposes, whether on their own account or on behalf of third parties or organisations;
• (c) individuals who visit or browse our Platforms without using our Services;
• (d) individuals associated with suppliers, vendors, customers, consumers, or professional advisors of Founders Doc (trading as "Founders Doc AI" or "FD AI");
• (e) individuals involved in any transactions or potential transactions conducted or evaluated by Founders Doc (trading as "Founders Doc AI" or "FD AI"); and
• (f) individuals who have opted to receive communications from Founders Doc (trading as "Founders Doc AI" or "FD AI").

Founders Doc AI (otherwise known as FD AI) is a digital legal document platform operated by Founders Doc Pte. Ltd. It is not a separate legal entity, and all legal obligations under this Policy are undertaken by Founders Doc.

1.3 Acknowledgement and Consent.

By using our Services, you acknowledge and agree that you have read and understood this Policy and consent to our collection, use, disclosure, and/or processing of your Personal Data as described herein. You also represent that you have the authority to provide any Personal Data you submit on behalf of third parties. Where required by law, we will obtain your explicit consent before processing sensitive data.

1.4 No Legal Advice Disclaimer.

Our Platforms and/or Services facilitate the generation of Legal Document(s) based on user inputs. We do not provide legal advice, and use of our Services does not establish an attorney-client relationship. You are solely responsible for reviewing and assessing the suitability of any generated Legal Document(s) for your intended use. For more details, please refer to our Terms of Use.

1.5 Amendments.

We may amend this Policy from time to time by posting the updated version on our website. The updated version will take effect as of the date of posting. Your continued use of our Services after the effective date of any amendments constitutes your acceptance of the revised Policy.

If you do not consent to the collection and processing of your Personal Data as described in this Policy, please do not use our Platform and/or Services.

2.1 User Responsibility for Data Accuracy.

When using our Platforms and/or Services to generate legal templates, you are solely responsible for ensuring that the information you provide is complete, accurate, and up to date. We do not verify user-submitted data, and any errors in the final document due to inaccurate inputs are your responsibility.

2.2 Data Protection Principles.

We will process Personal Data in compliance with applicable data protection laws. We will secure and retain your Personal Data only for as long as necessary to fulfil the purposes for which it was collected, or as required by law.

2.3 Modes of Data Collection.

Your Personal Data may be collected from you or your authorised representative during your course of dealing with us. The main ways through which we collect your Personal Data may be categorised into the following:

• (a) Information that you provide to us directly: when you access our Platform and/or Services, we may ask you to provide Personal Data to us. This may include, but is not limited to data in relation to identity information, contact information, financial information, transaction information, and any relevant marketing and communication. For example, we may ask you for information relating to your start-up via our Platforms, or for contact information when you submit a questionnaire or respond to an email offer. If you choose not to provide us with Personal Data, you may be unable to use and/or access some parts of our Services;
• (b) Information that we collect automatically: we may automatically collect certain information when you visit and navigate through our Platforms, such as your IP address and device type. We may also use analytics tools, such as Google Analytics, and other third-party services to collect data on user interactions. These services may use cookies, tracking pixels, or similar technologies to analyse trends and serve relevant content, including advertisements. You can manage your cookie preferences through your browser settings; and
• (c) Information from third parties: we may collect Personal Data from external sources such as publicly available materials or trusted third parties. This information supplements the Personal Data that we already hold in order to personalise our Services.

2.4 AI-Driven Tools.

We may use AI-driven tools, including those provided by third-party service providers, to assist with generating legal templates. These tools may include services provided by third-party vendors such as OpenAI and Anthropic, and your Personal Data may be shared with such vendors strictly for the purpose of providing our Services. These tools operate based on user-provided data and pre-set instructions. All outputs are automatically generated and are not verified by a human unless otherwise specified.

2.5 AI Processing.

We use automated processes, including AI-driven tools, to facilitate the provision of our Services on our Platforms. These automated processes assist with document generation and legal drafting, but they do not replace professional legal judgment or verification.

2.6 Types of Personal Data Collected.

While accessing our Platforms and/or using our Services, we may collect Personal Data (including sensitive personal data) that relates to you, including data that can be used to identify or contact you. Personal Data may include, but is not limited to:

• (a) Contact Details: such as your name, email address, phone number, professional details and mailing address;
• (b) User Content: including any images, documents, or files you upload, generate, or share through the Platforms and/or Services, such as saved drafts of legal templates or responses entered into questionnaires;
• (c) Social Media Information: including information you voluntarily provide via our social media pages (e.g. LinkedIn, Instagram, TikTok), such as your username or contact information, as well as engagement data (e.g. comments, likes, shares). We may also receive aggregate or analytics data about our social media activity from the relevant third-party platforms;
• (d) Payment Information: such as billing details and transaction data if you make purchases through our Platforms and/or Services. Payment card information is processed by third-party payment providers and is not stored by us;
• (e) Questionnaire Responses: including information you submit via forms, questionnaires, or other interactive components of our Platforms, such as legal questions, business details, and other information relevant to your use of our Services;
• (f) Sensitive Personal Information: we do not actively request sensitive Personal Data (such as religious beliefs, sexual orientation, or political opinions). If you choose to provide such information, we will only process it where necessary for the provision of our Services and with your explicit consent where required by law;
• (g) Feedback and Support Requests: including any information you provide when contacting our customer support team, or when submitting comments, feedback, or reviews;
• (h) Survey Responses: including any data you submit in connection with optional user research, service feedback, or other surveys conducted by us; and/or
• (i) Others: any other Personal Data or personally identifiable information reasonably related to your interactions with our Platforms and/or Services and collected for a legitimate business purpose.

2.7 Third-Party Links.

We may include links to third-party websites, plug-ins, and applications. Clicking on those links may allow third parties to collect or share your data. We do not control these third-party websites and are not responsible for their privacy policies. Your use of third-party websites, plug-ins, and applications is at your own risk, and we encourage you to review their privacy policies before providing any Personal Data.

2.8 Social Media.

We may collect Personal Data from your interactions with our social media pages on platforms such as LinkedIn, Instagram, and TikTok. This may include publicly available information such as your username, profile details, comments, likes, shares, and other engagement data. We may also use analytics tools provided by social media platforms to understand audience demographics and engagement trends. If we introduce the ability to sign up using social media accounts in the future, we will update this Policy accordingly.

3.1 How We Use Your Personal Data.

We collect, use, and process Personal Data to operate and improve our Platforms and Services, support your use of our Services, manage our business operations, and comply with legal and regulatory requirements, as well as such other legitimate business interests. This includes the following purposes:

• (a) to perform a contract with you, including providing access to our Platforms and Services, generating legal templates based on your input, managing your account, processing your transactions, responding to your requests, and supporting your ongoing use of our Services;
• (b) to operate, maintain, and improve our Platforms and Services, including monitoring usage, diagnosing issues, optimising performance, and developing new features;
• (c) to send service-related communications, respond to enquiries, and provide information about our Services, including updates, offers, or other content where permitted by law;
• (d) to conduct due diligence and compliance checks, including for anti-money laundering and counter-terrorism purposes, whether required by law or our internal policies;
• (e) to detect, investigate, and prevent fraud, abuse, security incidents, or other unlawful activities;
• (f) to enforce our Terms of Use and any other applicable terms, and to protect our rights, property, and interests, or those of our users and third parties;
• (g) to produce aggregated or anonymised data sets, reports, or usage analytics for internal or external use. We do not attempt to re-identify anonymised data;
• (h) to comply with applicable laws, regulations, legal processes, or governmental requests;
• (i) to support any other operational or business purpose reasonably related to your use of our Platforms and Services;
• (j) to evaluate or facilitate a potential business transaction, including mergers, acquisitions, fundraising, financing, restructuring, or sale of assets, and to support related due diligence and disclosure processes;
• (k) to manage relationships with service providers, partners, and vendors who support our business, including account administration, technical support, and integration services;
• (l) to improve, test, and develop our proprietary models or internal systems, using de-identified or aggregated data only;
• (m) to cooperate with regulators, auditors, legal counsel, or third parties in connection with audits, investigations, legal claims, or dispute resolution;
• (n) to respond to user requests relating to access, correction, or withdrawal of Personal Data, where required by applicable law;
• (o) to maintain and enhance the security, stability, and resilience of our infrastructure, systems, and data;
• (p) to maintain a directory of contacts and visitors; and/or
• (q) to carry out any legitimate business purposes or fulfil legal obligations where applicable, in relation to the use of our Platforms and Services.

You acknowledge and agree that the purposes listed above are not exhaustive and that we may use your Personal Data for additional purposes related to the operation of our Platforms or the delivery of our Services. Where required by law, we may notify you or obtain your consent before using your Personal Data for such purposes. You also agree to keep your Personal Data accurate and up to date throughout your relationship with us.

3.2 Lawful Basis.

Where the collection, use, or disclosure of Personal Data requires a legal basis under applicable law, we will rely on the purposes set out in this Policy as the basis for such processing. Consent will be obtained where required by law.

5.1 Provision of Personal Data of Other Individuals.

If you provide Personal Data about other individuals, including family members, dependents, directors, shareholders, employees, representatives, or agents, you confirm that you have informed them that their Personal Data will be collected, used, and disclosed through our Platforms and Services. Where required by law, you represent and warrant that you have obtained their consent before sharing their Personal Data with us. We are not responsible for verifying the legal basis for such disclosures. You also confirm that all Personal Data you provide is true, complete, and accurate to the best of your knowledge.

5.2 Business Provision of Personal Data

Where you are providing Personal Data in a business context (for example, Personal Data of your employees, customers, or partners), you confirm that such disclosure is lawful and that all required notices or consents have been provided or obtained.

5.3 Provision of Personal Data of Children.

If you provide Personal Data about a Child or any individual who is legally unable to give consent, you confirm that: (a) you are their parent or legal guardian; (b) you have parental responsibility over them; or (c) you have been legally appointed to manage their affairs for the purposes of using our Platforms and Services.

Our Platforms and Services are not directed to Children. If we become aware that Personal Data of a Child has been submitted without proper authority, we will delete it unless legally required to retain it.

6.1 Duration of Retention.

We retain Personal Data for as long as reasonably necessary to fulfil the purposes set out in this Policy, or as required by applicable law. This may include retaining Personal Data to support the operation of our Services, train and improve our models, or develop new technical features. We may also retain de-identified or aggregated data for research, analytics, or business purposes, provided such data cannot reasonably be used to identify any individual.

6.2 Processing on Behalf of Third Parties.

Where we process Personal Data on behalf of third parties, those third parties are responsible for ensuring that they have a legal basis to collect and disclose such data to us. We process such data solely on their instructions and are not responsible for how they collect, use, or share that data outside our control.

6.3 Inputs for Legal Document Generation or Review.

Information you enter into our Platforms and/or Services for the purpose of generating or reviewing legal documents may be processed, stored, and used to deliver the Services, improve our technical infrastructure, and develop new features. This may include the use of inputs for testing, debugging, model enhancement, or related purposes, in accordance with this Policy. We do not disclose such content externally to third parties except as required by law.

6.4 Retention of User-Generated Content.

We may retain documents, responses, drafts, or other content that you generate, upload, or submit through our Platforms and/or Services for the purpose of providing the Services, supporting ongoing access, or facilitating related features such as editing, downloading, or duplication. Retention may be time-limited or event-triggered depending on the specific feature. If you wish to delete any stored content, you may submit a deletion request to our Data Protection Officer. Once deleted, the content will no longer be accessible through the user interface.

7.1 International Data Transfers.

Where Personal Data is transferred outside Singapore, we ensure that appropriate safeguards are in place to provide a standard of protection comparable to the Personal Data Protection Act 2012. These safeguards may include contractual agreements with data recipients, adherence to applicable regulatory frameworks, intra-group data transfer agreements, or reliance on adequacy decisions by relevant authorities.

7.2 Law Enforcement Requests.

We may disclose your Personal Data to law enforcement, regulators, or government authorities if required by law, regulation, or legal process. Where permitted, we will notify you before such disclosure unless doing so would prejudice an ongoing investigation or violate legal restrictions, or any law or court order.

8.1 Data Security.

We take reasonable steps to protect your Personal Data from loss, unauthorised access, disclosure, alteration, or other misuse. These measures include technical, organisational, and procedural safeguards such as encryption, access controls, and periodic security reviews.

8.2 Data Breach.

In the event of a data breach that is likely to result in significant harm to affected individuals, we will assess and notify affected users as soon as practicable in accordance with the Personal Data Protection Act 2012 and any other applicable legal requirements. Where required, we will also report the breach to the relevant authorities.

9.1 Access, Correction and Objection.

You may request access to the Personal Data we hold about you in connection with your use of our Platforms and/or Services. You may also request that we correct or update your Personal Data if it is inaccurate or incomplete, or request deletion where appropriate, subject to legal and business retention requirements. You may object to our continued use of your Personal Data in certain circumstances.

A reasonable fee may be charged for an access request. If applicable, we will inform you of the fee before processing your request. This Policy is primarily governed by Singapore's Personal Data Protection Act 2012. You may have additional rights under the laws of your jurisdiction.

9.2 Complaints.

If you are unhappy with the way we are processing your Personal Data, please let us know by emailing administrator@foundersdoc.com. We will review and investigate your complaint and respond within a reasonable time.

9.3 Withdrawal of Consent.

You may withdraw your consent (in full or in part) for the collection or processing of your Personal Data at any time by providing us with written notice. Withdrawal of consent does not affect the lawfulness of any processing based on consent before withdrawal. Certain processing activities may continue where permitted by law, including those necessary for the operation of our Platforms and/or Services.

9.4 Marketing Communications & Opt-Outs.

We may send you marketing and promotional materials relating to our Platforms and/or Services, where permitted by law or with your consent. You may opt out of such communications at any time by clicking the unsubscribe link in our emails or contacting us directly.

9.5 Legal Basis for Collecting Data.

We may collect, use, or disclose Personal Data based on various grounds permitted under the Personal Data Protection Act 2012 in relation to your use of our Platforms and/or Services. These may include: (a) your consent, (b) where necessary for the performance of a contract, (c) where required to comply with legal obligations, and (d) where necessary for our legitimate business purposes, provided this does not override your rights and freedoms.

11.1 Implementation of Cookies.

We may from time to time use "cookies" or other features to allow us or third parties to collect or share information that helps improve our Platforms and/or Services or introduce new features.

11.2 What are Cookies.

Cookies are small files that are placed on your computer when a website is accessed by you. Cookies help users navigate efficiently between pages and assist the website operator in tracking usage on our Platforms and/or Services.

11.3 What we use Cookies for.

Cookies allow us to recognise your computer or device and tell us how and when the Services are used or visited, by how many people, and to track activity within our Services. Cookies are also used to personalise content and enhance user experience on our Platforms and/or Services. If we use cookies for advertising or marketing purposes, this will be done in accordance with applicable laws.

11.4 Your Options Regarding the Use of Cookies.

By using our Platforms and/or Services, you acknowledge that we use cookies and similar technologies as described in this Policy. You may manage or disable cookies through your browser settings, but some features may be affected.