Tourna Privacy Policy

Important Notice

Welcome to Tourna (hereinafter referred to as \'Tourna\', \'we\' or \'Platform\'). Tourna is an information matching service platform connecting users with local tour guides. The operating entity of the Tourna platform is established in the Republic of Singapore.

We deeply understand the importance of personal information to you and are committed to processing your personal information in accordance with the principles of legality, legitimacy, necessity, and transparency. This privacy policy (hereinafter referred to as \'this Policy\') will explain in detail: how we collect, use, store, share, transfer, disclose, and protect your personal information, as well as the relevant rights you enjoy under the law. This policy is governed by the Personal Data Protection Act (PDPA) of the Republic of Singapore and relevant laws and regulations.

Before registering, logging in, or using Tourna services, you must carefully read and fully understand all contents of this privacy policy, especially those relating to sensitive personal information, information sharing, and your rights. If you have any questions about this policy, please contact us through the contact methods specified in this policy.

When you start or continue to use Tourna services, you are deemed to have fully read, understood, and agreed to accept all contents of this privacy policy. If you do not agree to any content of this policy, please do not use Tourna services.

Article 1: Personal Information We Collect

1.1 Collection Principles

We only collect your personal information within the scope necessary to achieve product functions and service purposes, and follow the principle of minimum necessity. We will not collect personal information unrelated to providing services.

1.2 Information You Actively Provide

To provide you with better services, you may need to actively provide us with the following information when using platform services:

1.2.1 Account Registration Information

• Mobile phone number (for account registration, login verification, and receiving service notifications)
• Email address (optional, for account recovery and receiving important notifications)
• Username, nickname, avatar (for identity recognition and personalized display)

1.2.2 Identity and Authentication Information (Tour Guide Users Only)

• Real name
• ID card number or passport information
• Tour guide qualification certificate documents
• Other supporting materials used for identity review and compliance requirements

Note: The above identity and authentication information is only used for tour guide identity review, qualification verification, and meeting relevant laws, regulations, and regulatory requirements. We will not use it for other purposes.

1.2.3 Order and Payment Information

• Order number, order details, service content
• Payment amount, payment method, payment status
• Refund records, settlement information
• Invoice information (if needed)

1.2.4 Communication Information

• Chat records, voice messages, images, etc. between you and tour guides, other users, or platform customer service
• Reviews, feedback, complaint content

Note: The above communication information is used for order fulfillment, dispute handling, customer service, and service improvement. We will not use it for other commercial purposes.

1.3 Information We Automatically Collect During Your Use of Services

To ensure the normal operation of platform services and improve user experience, we will automatically collect the following information during your use of services:

1.3.1 Device Information

• Device model, device identifiers (such as IMEI, IDFA, Android ID, etc.)
• Operating system type and version
• Application version number
• Device hardware information

1.3.2 Log Information

• IP address
• Access time, access duration
• Operation records, function usage records
• Exception logs, error information
• Network type, carrier information

1.3.3 Location Information (With Your Explicit Authorization)

• Precise location information (GPS positioning)
• Approximate location information (location information based on network, IP address)

Note: Location information is used to match local tour guides, display nearby services, optimize itinerary arrangements, etc. You can turn off location permissions through device settings, but this may affect the normal use of some functions.

1.3.4 Album and Camera (With Your Explicit Authorization)

• The purpose of using the album and camera is to upload avatars and image content to the platform.

1.4 Information Provided by Third Parties

1.4.1 When you use third-party accounts (such as Apple ID, Google account, WeChat, Alipay, etc.) to log into Tourna, we may obtain basic account information shared by such third parties within the scope of your authorization (such as account nickname, avatar, etc.).

1.4.2 We will not obtain other information about you on the above third-party platforms unless you explicitly authorize it.

1.5 Sensitive Personal Information

According to relevant laws and regulations, the following information is sensitive personal information:

• ID card number, passport number
• Precise location information
• Payment information

When we collect and use sensitive personal information, we will strictly comply with legal requirements, take more stringent protection measures, and obtain your separate consent.

Article 2: How We Use Your Personal Information

2.1 Purpose of Use

We only use your personal information for the following purposes:

2.1.1 Account Services

• Provide you with account registration, login, and identity verification services
• Manage your account information and ensure account security

2.1.2 Core Business Functions

• Realize information matching between users and tour guides, order creation, and service fulfillment
• Process payments, refunds, and related financial settlements
• Provide communication tools to facilitate communication between users and tour guides

2.1.3 Security and Compliance

• Conduct tour guide qualification review and identity verification
• Conduct platform security risk control, fraud prevention, and anomaly detection
• Handle complaints, disputes, and dispute resolution
• Fulfill legal, regulatory, and regulatory requirements

2.1.4 Customer Service

• Provide customer support and consulting services
• Handle your feedback, suggestions, and complaints

2.1.5 Service Improvement

• Improve product functions and optimize user experience
• Conduct data analysis and user research (using de-identification and anonymization processing)

2.1.6 Notification Services

• Send you necessary service notifications (such as order reminders, system notifications, security reminders)
• Send you important policy change notifications

2.2 Methods of Use

2.2.1 We use automated decision-making mechanisms (such as information matching, recommendation algorithms) to process your personal information to improve service efficiency and user experience.

2.2.2 If you have objections to automated decision-making results, you can contact us through the contact methods specified in this policy, and we will provide manual review channels.

2.3 Exceptions to Consent

According to the Personal Data Protection Act (PDPA) of the Republic of Singapore and relevant laws and regulations, we may use your personal information without your consent in the following circumstances:

• (i) Necessary for the conclusion or performance of a contract to which you are a party;
• (ii) Necessary for the performance of statutory duties or statutory obligations;
• (iii) Necessary to respond to public health emergencies or to protect the life, health, and property safety of natural persons in emergency situations;
• (iv) Necessary for the public interest in implementing news reporting, public opinion supervision, etc., and processing personal information within a reasonable scope;
• (v) Processing your publicly disclosed or otherwise lawfully disclosed personal information within a reasonable scope in accordance with legal provisions;
• (vi) Other circumstances provided for by the laws of the Republic of Singapore.

Article 3: How We Share, Transfer, or Disclose Personal Information

3.1 Personal Information Sharing

3.1.1 We will not sell your personal information to any third party.

3.1.2 We only share your personal information with third parties in the following circumstances:

(i) To Complete Order Fulfillment

To complete order fulfillment, we may need to disclose necessary information to tour guides or users, including but not limited to:

• User nickname, avatar (disclosed to tour guides)
• Tour guide nickname, avatar, service information (disclosed to users)
• Service time, itinerary location, contact information (disclosed to both parties)

(ii) Payment and Settlement Services

To complete payments and refunds, we may need to provide payment institutions and settlement service providers with information necessary to complete payments and refunds, including but not limited to:

• Order information, payment amount
• Payment method, payment status
• Necessary identity information (if needed)

(iii) Technical Service Providers

To ensure the normal operation of platform services, we may cooperate with legally compliant technical service providers, including but not limited to:

• Cloud service providers
• Message push service providers
• Data analysis service providers
• Security service providers

We require the above technical service providers to strictly comply with confidentiality obligations and not use your personal information for other purposes.

3.1.3 When we share personal information with third parties, we will conduct security assessments and sign strict confidentiality agreements, requiring third parties to process personal information in accordance with our requirements, this policy, and other relevant confidentiality and security measures.

3.2 Personal Information Transfer

3.2.1 We will not transfer your personal information to any company, organization, or individual, except in the following circumstances:

• (i) We have obtained your explicit consent;
• (ii) In the event of merger, acquisition, or asset transfer, if personal information transfer is involved, we will require the new company or organization holding your personal information to continue to be bound by this policy; otherwise, we will require such company or organization to seek your authorization and consent again.

3.3 Personal Information Disclosure

3.3.1 We will only disclose your personal information in the following circumstances:

• (i) We have obtained your explicit consent;
• (ii) Required by laws and regulations, or required by judicial or administrative organs in accordance with the law;
• (iii) In emergency situations, necessary to protect the life, property, and safety of users, the platform, or the public.

3.3.2 When we disclose personal information, we will strictly comply with relevant laws and regulations and take reasonable measures to protect your legitimate rights and interests.

Article 4: Storage and Protection of Personal Information

4.1 Storage Location

4.1.1 Your personal information will be primarily stored within the territory of the Republic of Singapore. To provide better services, we may transfer your personal information to servers outside the Republic of Singapore for storage and processing.

4.1.2 If cross-border transfer of personal information is required, we will strictly comply with the Personal Data Protection Act (PDPA) of the Republic of Singapore and relevant laws and regulations, take necessary security measures, and obtain your separate consent (if required).

4.1.3 Your personal information will be stored on servers that meet legal requirements and have appropriate security protection capabilities. Regardless of where information is stored, we will take reasonable security measures to protect the security of your personal information.

4.2 Storage Period

4.2.1 We only retain your personal information for the period necessary to achieve the purposes described in this policy.

4.2.2 The determination of the storage period is based on:

• (i) The retention period required by laws and regulations;
• (ii) The period necessary to achieve the purposes of collection and use;
• (iii) The retention period agreed with you.

4.2.3 After the storage period expires, we will delete or anonymize your personal information, unless otherwise provided by laws and regulations.

4.3 Security Protection Measures

4.3.1 We take reasonable and feasible security technical and management measures to protect your personal information, including but not limited to:

• (i) Data encryption: Encrypting sensitive personal information for storage and transmission;
• (ii) Access control: Strictly restricting access permissions, allowing only authorized personnel to access personal information;
• (iii) Permission management: Establishing a comprehensive permission management system to prevent unauthorized access;
• (iv) Security audit: Regularly conducting security audits to timely discover and fix security vulnerabilities;
• (v) Security training: Conducting security training for employees to improve security awareness.

4.3.2 Although we have taken the above security measures, please note that no method of information transmission and storage is 100% secure. We cannot guarantee absolute security of information, but we will do our best to protect the security of your personal information.

4.4 Security Incident Handling

4.4.1 If a personal information security incident occurs, we will, in accordance with legal requirements, promptly inform you of the basic situation of the security incident and its possible impact, the measures we have taken or will take, suggestions for you to prevent and reduce risks independently, and remedial measures for you.

4.4.2 We will promptly inform you of relevant situations through email, letters, phone calls, push notifications, etc. When it is difficult to inform each personal information subject individually, we will adopt reasonable and effective methods to publish announcements.

Article 5: Your Rights

5.1 Rights Content

According to relevant laws and regulations, within the scope permitted by laws and regulations, you enjoy the following rights:

5.1.1 Right to Access

You have the right to access the personal information we process about you and understand the processing situation of personal information.

5.1.2 Right to Copy

You have the right to copy the personal information we process about you.

5.1.3 Right to Rectification

You have the right to correct or supplement inaccurate or incomplete personal information.

5.1.4 Right to Deletion

You have the right to request us to delete your personal information in the following circumstances:

• (i) Our processing of personal information violates laws and regulations;
• (ii) We collected and used your personal information without obtaining your consent;
• (iii) Our processing of personal information violates agreements with you;
• (iv) You no longer use our products or services, or you have cancelled your account;
• (v) We no longer provide products or services to you.

5.1.5 Right to Withdraw Consent

You have the right to withdraw the authorization and consent you previously gave us. After withdrawal of consent, we will no longer process the corresponding personal information, but the withdrawal of consent does not affect the personal information processing activities carried out based on your consent before the withdrawal.

5.1.6 Right to Account Cancellation

You have the right to cancel your account. After account cancellation, we will process your personal information in accordance with this policy and the \'Terms of Service\'.

5.1.7 Right to Complain and Report

You have the right to file complaints, reports, or inquiries with us regarding personal information protection issues.

5.2 Methods of Exercising Rights

5.2.1 You may exercise the above rights through the following methods:

• (i) Operate through the \'Settings → Privacy Settings\' or related functions in the App;
• (ii) Contact platform customer service and operate according to customer service guidance.

5.2.2 To ensure security, you may need to provide a written request or prove your identity in other ways. We may first require you to verify your identity before processing your request.

5.2.3 For your reasonable requests, we generally do not charge fees, but for multiple repeated requests beyond reasonable limits, we may charge certain cost fees.

5.2.4 In the following circumstances, we may not be able to respond to your requests:

• (i) Related to the personal information processor\'s fulfillment of obligations under laws and regulations;
• (ii) Directly related to national security and defense security;
• (iii) Directly related to public security, public health, and major public interests;
• (iv) Directly related to criminal investigation, prosecution, trial, and execution of judgments;
• (v) The personal information processor is maintaining the life, property, and other major legitimate rights and interests of the personal information subject or other individuals, but it is difficult to obtain the consent of the person;
• (vi) Responding to your request will cause serious damage to the legitimate rights and interests of the personal information subject or other individuals or organizations;
• (vii) Involving trade secrets.

Article 6: Protection of Minors

6.1 Service Target

Tourna does not provide services to minors under 18 years of age. We will not actively collect personal information of minors.

6.2 Handling Measures

6.2.1 If we discover that we have mistakenly collected personal information of minors, we will promptly delete the relevant personal information.

6.2.2 If you are a guardian of a minor, when you have questions about the processing of personal information of the minor under your guardianship, please contact us through the contact methods specified in this policy.

Article 7: Cookies and Similar Technologies

7.1 Purpose of Use

We may use cookies and similar technologies (such as Web Beacons, pixel tags, etc.) to collect and store information to improve user experience, analyze service usage, conduct advertising, etc.

7.2 Management Methods

You can manage cookies through browser settings. If you choose to disable cookies, it may affect the normal use of some functions.

Article 8: Privacy Policy Updates

8.1 Right to Update

We may update this privacy policy from time to time based on changes in laws and regulations, business development needs, or regulatory requirements.

8.2 Update Notification

8.2.1 The updated policy will be published in the App or on the official website and take effect from the date of publication.

8.2.2 If significant changes are involved, we will notify you in a prominent manner (such as platform announcements, in-app messages, emails, etc.) and re-obtain your consent (if required).

8.2.3 Significant changes include but are not limited to:

• (i) Major changes in our service model;
• (ii) Changes in the main objects of personal information sharing, transfer, or disclosure;
• (iii) Major changes in your rights to participate in personal information processing and the methods of exercising such rights;
• (iv) Changes in the responsible department, contact methods, and complaint channels for handling personal information security;
• (v) Personal information security impact assessment reports indicate high risks.

8.3 Continued Use

If you continue to use Tourna services, you are deemed to have agreed to accept the updated privacy policy.

Article 9: Other Provisions

9.1 Applicable Law

The formation, validity, interpretation, execution, modification, and termination of this policy are governed by the laws of the Republic of Singapore, particularly the Personal Data Protection Act (PDPA) and relevant laws and regulations.

9.2 Contact Us

If you have any questions, opinions, suggestions, or complaints regarding this privacy policy or personal information protection, please contact us through the following methods:

• Customer Service Email: support@tourna.io
• Official Website: https://www.tourna.io

We will reply to your inquiries within a reasonable time (generally within 15 business days).

9.3 Regulatory Complaints

If you are not satisfied with our response, especially if our personal information processing behavior has harmed your legitimate rights and interests, you may also:

• (i) File a complaint or report with the Personal Data Protection Commission (PDPC) of Singapore;
• (ii) File a lawsuit with a court with jurisdiction in the Republic of Singapore;
• (iii) Handle it according to the dispute resolution methods specified in Article 10 of the \'Terms of Service\'.

This policy takes effect from January 8, 2026.

Thank you for choosing Tourna, and we wish you a pleasant journey!