Last Updated: 15 December 2025

Welcome to Accountably! We are committed to protecting your personal data. This privacy policy (“Privacy Policy”) sets out the manner in which Uplift Intelligence Pte Ltd (“we,” “us,” or “our“) may collect, process the data, whether true or not, about an individual who can be identified either (a) from that data; or (b) from that data and other information to which we have or are likely to have access (“personal data”) in accordance with the Personal Data Protection Act 2012 of Singapore, as may be amended from time to time (“PDPA”).

This Privacy Policy applies to all users of our mobile application (the “App”). Please read this Privacy Policy carefully. If you do not agree with the terms of this policy, please do not access or use the App.

1. Personal Data We Collect (The “What” and “How”)

Accountably is an AI-first application purpose-built to provide a discreet, intelligent, and personalized path to freedom from online addiction. It uses AI to understand and adapt to the user and support the user’s recovery journey. It is simple, easy-to-use, and revolves around engagement with a customised AI and a tailor made plan for you that also sends emails and notifications and responds to your journaling.

In order for us to provide the App to you, we collect personal data that you provide directly to us, personal data we collect automatically, and personal data we may receive from third parties.

a) Personal Data You Provide to Us:

• Account data: Such as your name, user ID and email address when you create an account.
• User Content and Inputs: Such as text, images, or other data you provide when using our App, including inputs you provide to our AI models (“Inputs“).
• Identity Data: Such as your country of residence, job title, religion, age, marital status and/or gender;
• Contact Data: Such as your residential address, email address and/or telephone number;
• Transaction Data: Such as your credit card details, your billing address, your mailing address or the mailing address of the intended recipient of your order, payments and orders to and from you, and other details of products and services that you have supplied to or purchased from us;
• Marketing and Communications Data: Such as your interests, feedback, survey responses, preferences in receiving marketing materials from us and your communication preferences, as well as your preferences for particular products or services;

b) Personal Data We Collect Automatically:

• Usage Data: Information about how you use the App, such as features you use, actions you take, and the time, frequency, and duration of your activities.
• Device Information: Information about your mobile device, including device model, operating system, unique device identifiers, and mobile network information.
• AI-Generated Outputs: We process your Inputs to generate responses or results (“Outputs“) through our AI models. We may store these Inputs and Outputs to provide and improve our services.

2. How We Use Your Personal Data (The “Why”)

We may collect and use your personal data for any or all of the following purposes:

• To verify your identity and register you as a new customer and manage our relationship with you.
• To administer, operate, provide, maintain and protect our business and App.
• To deliver relevant content to you through our App.
• To create and manage your account, provide you with the App’s functionalities, and process your requests.
• To process your Inputs, generate Outputs, and enhance the capabilities of our AI models.
• To analyze user behavior, improve our App and AI models, and develop new features.
• To improve the accuracy, safety, and performance of our AI models and to train our underlying models. We take steps to anonymise your personal data where possible.
• To send you technical notices, updates, security alerts, and support messages.
• To protect the security and integrity of our App and our users.
• To contact you in relation to all of the above.
• To comply with applicable laws, regulations, and legal processes.
• For any other purposes for which you have provided the personal data.
• Any other incidental business purposes related to or in connection with the above.

The purposes listed above may continue to apply even in situations where your relationship with us has been terminated or altered in any way, for a reasonable period thereafter (including, where applicable, a period to enable us to enforce our rights under any contract with you).

We will only process your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for a new purpose, we will notify you before such use and will explain the legal basis which allows us to do so as well as obtain your consent to the use of your personal data for such purposes where we are required to so by law.

3. How We Share Your Personal Data

We may share your personal data with our affiliates and third parties in the following limited situations:

• With Service Providers: We may share your personal data with third-party vendors and service providers who perform services for us, such as cloud hosting and data analytics.
• For Legal Reasons: We may disclose your personal data if required to do so by law or in the good faith belief that such action is necessary to comply with a legal obligation.
• Business Transfers: We may share or transfer your personal data in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition.

We do not disclose your personal data to unaffiliated third parties for their independent use unless we have obtained your consent to do so and pursuant to executing confidentiality agreements with such unaffiliated third parties. We also require all third parties to respect the security of your personal data and to treat it in accordance with the applicable law.

4. Retention of Personal Data

We will retain your personal data only for as long as is necessary for the purposes set out in this Privacy Policy, or as required by law. However, please be advised that we may retain some of your personal data after you cease to use our services, for instance if the data is necessary to meet our legal obligations, such as retaining the information for tax and accounting purposes.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this personal data indefinitely without further notice to you.

5. Withdrawing your Consent

The consent that you provide for the collection, use and disclosure of your personal data will remain valid until such time it is being withdrawn by you in writing. You may withdraw consent and request us to stop collecting, using and/or disclosing your personal data for any or all of the purposes listed above by submitting your request in writing or via email to our Data Protection Officer at the contact details provided below.

Whilst we respect your decision to withdraw your consent, please note that depending on the nature and scope of your request, we may not be in a position to continue providing our goods or services to you and we shall, in such circumstances, notify you before completing the processing of your request. Should you decide to cancel your withdrawal of consent, please inform us in writing in the manner described in clause 5 above.

Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclose without consent is permitted or required under applicable laws.

6. Access and Correction of Personal Data

If you wish to make (a) an access request for access to a copy of the personal data which we hold about you or personal data about the ways in which we use or disclose your personal data, or (b) a correction request to correct or update any of your personal data which we hold about you, you may submit your request in writing or via email to our Data Protection Officer at the contact details provided below.

Please note that a reasonable fee may be charged for an access request. If so, we will inform you of the fee before processing your request.

7. Accuracy of Personal Data

We generally rely on personal data provided by you (or your authorised representative). In order to ensure that your personal data is current, complete and accurate, please update us if there are changes to your personal data by informing our Data Protection Officer in writing or via email at the contact details provided below.

8. International Data Transfers

Your personal data may be transferred to and maintained on computers located outside of Singapore where the data protection laws may differ. We will take steps to ensure that your personal data continues to receive a standard of protection that is at least comparable to that provided under the PDPA. For example, we will ensure that there is a proper legal agreement that covers the data transfer.

9. Security of Your Personal Data

We use commercially reasonable administrative, technical, and physical security measures to help protect your personal data against unauthorised access. While we have taken reasonable steps to secure the personal data you provide to us, please be aware that no security measures are perfect or impenetrable. You are responsible for keeping your login information and passwords confidential.

10. Children’s Privacy

Our App is not intended for children under the age of 13 and we do not knowingly collect personal data from children under this age. If you are under the age of 13, please do not use this App without a parent or guardian nor provide personal data to us of any kind whatsoever.

11. Effect and Changes to This Privacy Policy

This Privacy Policy applies in conjunction with any other notices, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your personal data by us.

We may update this Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy within the App and updating the “Last Updated” date. Your continued use of our App constitutes your acknowledgement and acceptance of such changes.

12. Contact Us

If you have any questions or concerns about this Privacy Policy or our data practices, please contact our Data Protection Officer at:

Uplift Intelligence Pte Ltd
3 Raffles Place, #06-01, Bharat Building, Singapore 048617
support@youraccountably.com
www.youraccountably.com