GDPR and Privacy Policy

X0PA AI Pte. Ltd. ( is registered in Singapore as a Private limited company (number 201708580N).

This policy is effective from 1st Jan 2019

This policy was last modified on 1st Jan 2019


We are X0PA AI Pte. Ltd., a provider of talent selection services based in Singapore. Our company number is 201708580N and our registered office is at 81 Ayer Rajah Crescent # Units 66/67 Singapore 139967. All references in this policy to "", "our", "us" or "we" refer to X0PA AI Pte. Ltd., or our suppliers which provide services to us, as appropriate.

This Privacy Policy lets you know what happens to any personal data that you give to us or that we collect from you. We collect only the minimum amount of personal information necessary for you to make use of our Services; we ensure that we meet our responsibilities under the General Data Protection Regulation (GDPR); and we will only ever use your data as this Privacy Policy describes.

Applicability of This Privacy Policy

This Privacy Policy applies to X0PA AI Pte. Ltd.’s website at (the "website"), our web application available on the website (the "Services") and other interactions (e.g. customer service inquiries, live chat etc.) you may have with

This Privacy Policy does not apply to any third party applications or software that integrate with the Services, or any other third party products, services or businesses, where we are not the controller of your personal data.

This Privacy Policy is separate to our Terms of Service, which set out the legal terms governing delivery, access and use of the Services (the "Terms of Service").

1. How We Handle Your Data

1.1 Information We Collect

Information from website browsers

What do we collect?

If you are browsing the website, we collect the same basic information that many other websites collect. We use common Internet technologies, such as cookies and web server logs. This is information we collect from everybody who visits our website, whether they have an account or not. More information on cookies may be found here.

The information we collect about all visitors to our website includes the visitor's browser type ("User Agent"), language preference, referring site, and the date and time of each visitor request. We also collect potentially personally-identifying information like Internet Protocol (IP) addresses.

Why do we collect this?

The information we collect about all visitors to our website includes the visitor's browser type ("User Agent"), language preference, referring site, and the date and time of each visitor request. We also collect potentially personally-identifying information like Internet Protocol (IP) addresses.

Information from users uploading files


What do we collect?

If you upload a file using our services we collect your email address along with details of the filename or file URL.

Why do we collect this?

We collect this information in order to provide our talent selection services to you – without this information we are not able to upload your files or provide you with talent selection service.

Information from users with accounts


What do we collect?

If you create an account with us on our website, we require some basic information at the time of account creation. You will create your own password, and we will ask you for your full name and a valid email address. We will also collect your billing details, including credit card information (card name, number, expiry and CVV), a billing address and for some customers a valid GST/ VAT number.

Why do we collect this?

  • We need this information in order to set up your account, and to provide any services you have requested from us.

  • We use your email address to identify you on and send important system and account notices to you. We do not use your email address for marketing purposes unless you have specifically consented to us doing this. We don't share or sell your email address with any 3rd parties.

  • We limit our use of your personal information to the purposes listed in this Privacy Policy. If we need to use your personal information for other purposes, we will ask your permission first. You can always see what information we have, how we're using it, and what permissions you have given us in your user profile.

People who contact us with enquiries


What do we collect?

If you contact us with an enquiry, we will collect the information provided when you correspond with us, such as your name, your address, your email address and your telephone number.

What do we collect this?

We will collect, use and store the personal information listed above to deal with any enquiries or issues you have about our Services, including any questions you may have about how we collect, store and use your personal information, or any requests made by you for a copy of the information we hold about you.

1.2 Information We Do Not Collect

We do not intentionally collect or store special categories of personal data, such as date of birth, genetic data, health information, or religious information. Although does not request or intentionally collect any special categories of personal data, we realize that you might store this kind of information in your account, via the files that you upload.

If you ask us to upload or store any files containing special categories of personal data on our servers, located in the United States, we will only do so on your instructions as a data processor and service provider and in accordance with our Data Processing Agreement with you. You are the controller of this data and you must ensure that you have a legal basis to share this data with us.

1.3 How We Use Your Information and our Legal Basis for doing so

We use the information you provide to us in a number of ways and we have set out our legal basis for processing your information below:

To provide, update and maintain the Services we offer to you

This is the most common usage of your information. We use your personal information to provide various talent selection Services to you, in accordance with our Terms of Service. In particular, we will use your data to: set-up an account; upload the files that you provide us with, to convert them to more user friendly format and fulfill task of talent selection; and to send you links to access and view our service output to the email address you provide us with.

Our use of your personal information in this way is necessary to perform our obligations to provide the Services to you, under our Terms of Service.

To communicate with you by responding to your requests, comments and questions

If you contact our support team we may use the information that you provide to us in order to help us respond to your enquiry.

Our use of your personal information in this way is necessary to perform our customer service obligations to you, under our Terms of Service.

If we do not have a contract with you, we may process your personal information for these purposes where it is in our legitimate interests to do so for customer services purposes.

For billing, account management and other administrative matters may need to contact you for invoicing, account management and similar reasons and we use account data to administer accounts and keep track of billing and payments.

Our use of your personal information in this way is necessary to perform our obligations to you under our Terms of Service.

As required by applicable law, legal process or regulation

We may use your information to comply with court orders and similar legal or regulatory obligations which apply to us.

This may include where we reasonably consider it is in our legitimate interests or the legitimate interests of others to comply, as well as where we are legally required to do so.

To investigate and help prevent abuse or security issues

We may use information such as your IP address to help us prevent abuse of the Services we provide and investigate any potential unauthorized use of those Services or other security breaches.

In these circumstances, we believe we have a legitimate interest in handling your data, and do not believe that this storage and use of your data will be of particular concern to you.

If we rely on our (or another person's) legitimate interests for using your personal information, we will undertake a balancing test to ensure that our (or the other person's) legitimate interests are not outweighed by your interests or fundamental rights and freedoms which require protection of the personal information. You can ask us for information on this balancing test by using the contact details at section 5.5.

We also collect and use data which is aggregated or anonymised for certain business purposes, such as creating aggregate statistics or reporting. However, no single individual will be identifiable from the anonymised details we collect for these purposes.

1.4 Cookies

What are cookies?

Cookies are small text files (typically made up of letters and numbers) placed in the memory of your browser or device when you visit a website or view a message. They allow a website to recognize a particular device or browser. Session-based cookies last only while your browser is open and are automatically deleted when you close your browser. Persistent cookies last until you or your browser delete them or until they expire.

For further information on deleting, disabling, blocking and controlling cookies please visit

Does use cookies?

Like many sites, we use cookies to make interactions with our Services easy and meaningful. We also use cookies to keep you logged in, remember your preferences and allow us to provide a more convenient service to you.

When you use the Services, we and certain partners may use cookies to recognize you and to otherwise customize your online experiences and other content. For any users of our website based outside of the European Economic Area (EEA), certain partners use cookies to tailor advertising to your preferences. We and certain partners may also use cookies to measure the effectiveness of promotions; and mitigate risk and prevent potential fraud across the Services. Certain aspects and features of the Services are only available through the use of Cookies, so if you choose to disable or decline Cookies, your use of the Services may be limited or not possible.

Where possible, security measures are set in place to prevent unauthorized access to our cookies.

How is using cookies?

We use several types of cookie:

Categories of Use



If you are signed in to the Services, authentication cookies help us personalize your experience and show you the right information.


We use security cookies to enable and support our security features, and to help us detect malicious activity.

Performance, Analytics and Research

Cookies help us and our third party suppliers to learn how well our sites and Services perform. We also use performance, analytics and research cookies to understand, improve, and investigate products, features, and services.


Some of our third party advertising partners use cookies for reporting and fraud detection. If you are based outside of the EEA, our third party advertising partners may also use cookies to provide you with personalised ads when using our website. For further information please see the section below on advertising.

What can you do if you don't want any cookies to be set or want them to be removed?

Some people prefer not to allow cookies, which is why most browsers give you the ability to manage cookies to suit you. In some browsers you can set up rules to manage cookies on a site-by-site basis, giving you more fine-grained control over your privacy. What this means is that you can disallow cookies from all sites except those that you trust.

Browser manufacturers provide help pages relating to cookie management in their products. Please click on the links below for more information on how to manage your cookie settings.

1.5 Tracking

Google Analytics

We may use third-party services, such as Google Analytics, Mixpanel, that collect, monitor and analyze this type of information in order to increase our Service’s functionality. These third-parties may use cookies to help us analyze how our users are using the Service and they have their own Privacy Policies addressing how they use such information.

  • Google Analytics service is provided by Google Inc.

    You can opt-out from Google Analytics service from using your information by installing the Google Analytics Opt-out Browser tool:

    For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page:

  • Mixpanel is provided by Mixpanel Inc.

    You can prevent Mixpanel from using your information for analytics purposes by opting-out. To opt-out of Mixpanel service, please visit this page:

    For more information on what type of information Mixpanel collects, please visit the Terms of Use page of Mixpanel:


Other Tracking

We do not allow any third party social media websites (such as Facebook or Twitter) to track you across our Services - all of the social media buttons served through our Services are configured to explicitly disallow tracking from third parties whilst using our Services.

2. How We Share Data

2.1 Sharing Your Information

We do not share, sell, rent or trade your email address with any third parties for any commercial purposes.

We may share personal information with a limited number of third-party vendors who process it on our behalf to provide or improve our Services, and who have agreed to privacy restrictions and security obligations consistent with this Privacy Policy.

We will share your personal information with the following third party vendors:

  • Microsoft Azure Services, Amazon AWS and Netlify who provides server hosting and content distribution networks (CDN's) services;

  • Squarespace Inc who provides Domain Name Services;

  • Amazon Simple Email Service Inc who provides us email sending services;

  • Stripe Inc who provides payment processing services; and

  • Microsoft Office Suite, who provide customer relationship management and customer service tools.

When we transfer your data to our vendors, we remain responsible for it. We try to ensure that any third parties with whom we share your personal information are limited (by law and by contract) in their ability to use your personal information for any purpose other than to provide services for us.

We may share personal information where it is in our legitimate interests to do so to run, grow and develop our business if we are involved in a merger, sale, or acquisition. If any such change of ownership happens, we will ensure it is under terms that preserve the confidentiality of personal information, and we will notify you on our website or by email before any transfer of your personal information.

2.2 Third Party Advertising

We do not host any third party advertising at Therefore, whether you access our service Outside or Inside of European Economic Area (EEA), none of personal or user data is shared with any third party advertising. 

2.3 Legal Disclosures may disclose personally-identifying information or other information we collect about you in response to a valid subpoena, court order, warrant, or similar government order, or when we believe in good faith that disclosure is reasonably necessary to protect our property or rights, or those of third parties or the public at large. This may include exchanging personal information with other organisations for the purposes of fraud protection and credit risk reduction.

We will also disclose your personal information to third parties in order to enforce or apply our terms and conditions or any other agreement or to respond to any claims, to protect our rights or the rights of a third party, to protect the safety of any person or to prevent any illegal activity.

3. How We Manage Data

3.1 Security takes the security of data very seriously, and we work hard to protect any information you provide to us from loss, misuse, and unauthorized access or disclosure. We take all reasonable precautions to safeguard the confidentiality of your personal information, including through use of appropriate organisational and technical measures. These measures take into account the sensitivity of the data we collect, process and store, and the current state of technology.

Given the nature of communications and information processing technology, cannot guarantee that information, during transmission through the Internet or while stored on our systems or otherwise in our care, will be absolutely safe from intrusion by others, but we do our utmost to protect it. Once we have received your personal information, we will use strict procedures and security features to prevent unauthorised access to it.

As a minimum we take the following measures to secure your data:

  • Physical Security - infrastructure is only hosted in data centres which meet rigorous security standards. Physical access is strictly controlled both at the perimeter and at building ingress points by professional security staff utilising video surveillance, intrusion detection systems, and other electronic means.

  • Data Transfer Integrity - All traffic to and from servers is secured by transport level security (TLS) sent over a Secure Socket Layer (SSL), and secured using an AES 256-bit SSL certificate. This ensures that data sent between your systems and ours is encrypted using military grade encryption.

  • Password Encryption - user account passwords are stored in our database after being salted and hashed using the encryption algorithms.

  • Firewalls - enforces network level control for access to infrastructure by using multiple different firewall technologies to ensure that different components of its systems are logically isolated from one another.

  • Operational Access Controls - employees require access to production services for operational reasons. We employ multiple authentication mechanisms to ensure that production systems are accessed only by authorised members of staff and are protected from unauthorised access.

  • Software Updates - regularly applies software patches to production infrastructure in order to ensure a strong security posture to known software vulnerabilities.

  • Bug Bounty Program - operates an informal "bug bounty" program that encourages security researchers to perform limited and authorised testing of the integrity of systems.

3.2 Data Retention and Deletion

If you have an account with

If you have an account with, we will retain your personal information for as long as your account is active or as needed to provide you with Services that you request (in accordance with our Terms of Service).

Once your account is deactivated we will permanently remove any files associated with your account 90 days after deactivation.

We may retain certain other personal information (such as your email address) for 18 months after your account is deactivated, unless you delete it or request its deletion. For example, we don't automatically delete inactive user accounts, so unless you ask us to permanently delete your account we will retain some account information to enable you to return and use our Services more easily in future.

If you do not have an account with

We will store any files you upload to us for trying the Service, and their converted format on our systems for no longer than 180 days following upload. After this time they will be permanently removed from our storage systems.

We will retain personal information such as your IP address, email address and browser details for no longer than 30 days. After this time we permanently delete your browser data and anonymise your IP address and email address so that we can no longer personally identify you.

3.3 International Data Transfers may transfer your personal data to countries other than the one in which you live, including to our hosting servers with reputed suppliers located in the United States and Asia.

If we provide any personal information about you to any such non-EEA entities, we will take appropriate measures to ensure that the recipient protects your personal information adequately in accordance with this privacy policy. These measures may include the following permitted in Articles 45 and 46 of the GDPR:

  • in the case of US based entities, entering into European Commission approved standard contractual arrangements with them, or ensuring they have signed up to the EU-US Privacy Shield (see further; or

  • in the case of entities based in other countries outside the EEA, entering into European Commission approved standard contractual arrangements with them.

Further details on the steps we take to protect your personal information, in these cases is available from us on request by contacting us by email at at any time.

4. Your Rights

If you have a user account for the Services you may review and edit any personal data you have supplied to us in your user profile. If you do not have a user account, or if you have questions about your account information or other personal data please contact us by email at

Individuals located in certain countries, including the European Economic Area and Switzerland, have certain statutory rights in relation to their personal data. While some of these rights apply generally, certain rights apply only in certain limited circumstances. We describe these rights below.

Please note that we may ask you to verify your identity before taking further action on your request. Additionally your request and choices may be limited in certain cases: for example, if fulfilling your request would reveal information about another person, or if you ask to delete information which we are permitted by law or have compelling legitimate interests to keep.

4.1 Right to be Informed

You have the right to be provided with information about the data we hold, our data processing activities and whether we transfer personal data outside of the EAA, along with the methods we use to safeguard such data.

4.2 Right to Access

In some jurisdictions, applicable law may entitle you to request copies of your personal information held by us.

4.3 Right to Rectification

You have the right to ask us to correct inaccurate, out of date or incomplete personal information concerning you (and which you cannot update yourself within the Services).

4.4 Right to Erasure

We generally retain any personal information for as long as is necessary for the performance of the contract between you and us and to comply with our legal obligations. If you no longer want us to use your information to provide the Services to you, you can request that we erase your personal information and (if you have one) close your user account. Please note that if you request the erasure of your personal information:

  • We may retain some of your personal information as necessary for our legitimate business interests, such as fraud.

  • We may retain and use your personal information to the extent necessary to comply with our legal obligations.

  • Because we maintain the Services to protect from accidental or malicious data loss and destruction, residual copies of your personal information may not be removed from our backup systems for a limited period of time.

4.5 Right to Object / Restrict Processing

In some jurisdictions, applicable law may entitle you to request not to process your personal information for certain specific purposes where such processing is based on our (or another party's) legitimate interests. If you object to such processing will no longer process your personal information for these purposes unless we can demonstrate compelling legitimate grounds for such processing or such processing is required for the establishment, exercise or defence of legal claims.

4.6 Right to Data Portability

You may be entitled to request copies of personal information that you have provided to us in a structured, commonly used, and machine-readable format and/or request us to transmit this information to another service provider (where technically feasible). This right only applies where we use your personal information on the basis of your consent or performance of a contract; and where our use of your information is carried out by automated means.

4.7 Lodging Complaints

Subject to applicable law, you also have the right to lodge a complaint with your local data protection authority or the Singapore Information Commissioner's Office, which is's lead supervisory authority in the Singapore.

5. Other Important Information

5.1 Data Processing Agreement will be the controller of personal data provided to, or used in connection with our Services, as described in this Privacy Policy.

To the extent that we act as a data processor on your behalf in connection with the performance of our Services, we will enter into a separate "Data Processing Agreement" with you. You can find out more information on this Data Processing Agreement by emailing us at

5.2 Data Protection Authority

If you believe we are the controller of your personal data, you may direct questions or complaints to our lead supervisory authority:

Personal Data Protection Commission of Singapore
460 Alexandra Road
#10-02 PSA Building 
Singapore 11996310

Phone: +65 6508 7333 or +65 6377 3131
Fax: +65 6273 7370

5.3 Age Limitations

If you're a child under the age of 13, you may not use's Services. does not knowingly collect information from or direct any of our content specifically to children under 13. As set out in our Terms of Service, if we learn or have reason to suspect that you are a user who is under the age of 13, and you have an account with us we will unfortunately have to close your account.

5.4 Changes to This Privacy Policy may change this Privacy Policy from time to time. Laws, regulations and industry standards evolve, which may make those changes necessary, or we may make changes to our business. We will post the changes to this page and update the "last modified date" when we do. We would encourage you to review our Privacy Policy to stay informed. If we make changes that materially alter your privacy rights, will provide additional notice, such as via email or through the Services. If you disagree with the changes to this Privacy Policy, you should deactivate your registered account for the Services, or otherwise cease use of the Services.

5.5 Contacting

Please feel free to contact if you have any questions about this Privacy Policy or complaints about's practices relating to your personal information, or if you are seeking to exercise any of your rights described in this Privacy Policy. You may contact us at or at our mailing address below: Ltd Data Protection Representative at

81 Ayer Rajah Crescent # Units 66/67
Singapore 139967