1. Identity of Data Controller

The data controller responsible for your personal data is:

Our DPO is responsible for ensuring compliance with the PDPA and handling all data protection matters. You may contact the DPO at any time with questions, access requests, correction requests, or withdrawal-of-consent notices.

2. Personal Data We Collect

We collect personal data from you (as a subscriber) and, where applicable, from third parties (callers who contact you through our Service). The categories of personal data we may collect include:

Third-Party Callers: When a third party places a call that is answered by your Zero AI agent, their voice, caller ID, and the content of their communication will be recorded and processed. As a subscriber, you are solely responsible for ensuring that all persons who call your Zero AI-enabled number are duly informed that their call may be answered, recorded, and processed by an AI system. Zero AI is not responsible for any failure by you to provide such notice.

3. Purposes of Collection, Use and Disclosure

We collect, use, and disclose personal data for the following purposes:

• Service Delivery: Answering incoming calls on your behalf, generating transcripts, and delivering SMS call summaries to your registered number.
• Account Management: Registering and administering your subscriber account, verifying your identity, and processing subscription payments.
• Service Improvement: Analysing usage patterns, call quality, and AI performance to improve accuracy, reliability, and user experience. Where call recordings or transcripts are used for AI model improvement, they are de-identified and aggregated to the fullest practicable extent.
• Security & Fraud Prevention: Detecting, investigating, and preventing abuse, unauthorised access, fraudulent activity, or violations of our Terms of Service.
• Customer Support: Responding to queries, resolving disputes, and providing technical assistance.
• Legal Compliance: Complying with applicable laws, regulations, court orders, or requests from competent public authorities in Singapore (including IMDA, PDPC, and law enforcement agencies).
• Marketing Communications: Sending you product updates, promotional offers, and service announcements where you have provided consent or where permitted under the PDPA. You may opt out at any time.

We will not use your personal data for a new purpose materially different from those stated above without first notifying you and, where required by the PDPA, obtaining your consent.

4. Consent and Legal Basis

Under the PDPA, we rely primarily on your consent as the legal basis for collecting and processing your personal data. By subscribing to our Services, you consent to the collection, use, and disclosure of your personal data as described in this Policy. Where we process personal data on the basis of legitimate interests (e.g., fraud prevention, network security), we have assessed that our interests are not overridden by your data-protection rights.

You may withdraw your consent to any specific processing purpose at any time by contacting our DPO. Please note that withdrawal of consent may affect our ability to provide some or all of our Services to you.

Certain data processing activities (e.g., responding to a lawful order from a government authority, protecting against fraud) may be carried out without consent pursuant to exceptions under the Second Schedule of the PDPA.

5. Call Recording Notice and Caller Consent

Our core service involves the recording of telephone calls. By activating our telephony AI Service, you:

• Acknowledge that all calls to your Zero AI-enabled number will be recorded by our AI agent.
• Accept sole responsibility for informing callers, prior to or at the commencement of each call, that the call may be answered, recorded, and processed by an AI system, as may be required under applicable Singapore laws and any other laws applicable to you or your callers.
• Agree to configure your Zero AI agent greeting to include a clear disclosure to callers that they are speaking with an AI and that the call is being recorded. Zero AI provides a standard compliant greeting template for your use; modifications that remove or dilute this disclosure are made entirely at your own risk and responsibility.

Zero AI disclaims all liability arising from any failure by a subscriber to obtain appropriate consent from third-party callers.

6. SMS Summaries and the Do Not Call Registry

Our Service delivers SMS call summaries to your registered mobile number. These messages are transactional in nature (relating directly to calls handled by your agent) and are not subject to the DNC Registry provisions of the PDPA.

Where we send any marketing or promotional messages via SMS, we will comply fully with the PDPA’s Do Not Call provisions. We will check the DNC Registry before sending any specified message to a Singapore telephone number and will honour all DNC registrations. You may register your number on the DNC Registry at pdpc.gov.sg.

7. Disclosure to Third Parties

We do not sell, rent, or trade your personal data. We may disclose personal data to the following categories of recipients, strictly on a need-to-know basis and under appropriate contractual safeguards:

• Zero1 Group Pte Ltd (Parent Company): For group-level reporting, compliance oversight, and shared IT infrastructure.
• Telecommunications Providers: Licensed network operators and VoIP carriers used to route and receive calls.
• AI Infrastructure Providers: Third-party AI model providers (including automatic speech recognition, natural language processing, and text-to-speech vendors) engaged under data processing agreements.
• SMS Gateway Providers: Licensed messaging aggregators used to deliver call-summary SMS messages.
• Payment Processors: PCI-DSS-compliant payment service providers for processing subscription fees.
• Cloud & Hosting Providers: Infrastructure providers hosting our platform and data.
• Professional Advisors: Lawyers, auditors, and accountants bound by professional confidentiality obligations.
• Regulatory and Law Enforcement Authorities: Where required by law, court order, or where we reasonably believe disclosure is necessary to protect our legal rights, the safety of any person, or to investigate fraud or security incidents.

8. Overseas Transfer of Personal Data

Some of our AI infrastructure and subprocessors may operate in jurisdictions outside Singapore, which may include but is not limited to the United States, the European Economic Area, and other countries in Asia-Pacific. Where personal data is transferred overseas, we will comply with the transfer obligations under Part X of the PDPA, including by ensuring that the recipient organisation provides a standard of protection comparable to the PDPA through contractual arrangements (e.g., binding data processing agreements incorporating approved standard contractual clauses).

By using our Services, you consent to the transfer of your personal data to overseas recipients as described in this section.

9. Retention of Personal Data

We retain personal data only for as long as necessary to fulfil the purposes for which it was collected or as required by law:

Upon expiry of the applicable retention period, personal data will be securely deleted or anonymised such that individuals can no longer be identified. Subscribers may request deletion of their call recordings and transcripts at any time via the account dashboard, subject to overriding legal obligations.

10. Security of Personal Data

We implement a comprehensive security programme proportionate to the sensitivity of the personal data we hold, including:

• Encryption of call recordings and transcripts at rest (AES-256) and in transit (TLS 1.2 or higher).
• Role-based access controls and least-privilege principles limiting staff access to personal data.
• Regular security assessments, penetration testing, and vulnerability scanning.
• Multi-factor authentication for administrative systems.
• Incident response and data breach notification procedures aligned with PDPC requirements.

In the event of a data breach that is notifiable under the PDPA, we will notify the Personal Data Protection Commission (PDPC) within three (3) calendar days of assessment that the breach is notifiable and will inform affected individuals as required by law.

11. Your Rights Under the PDPA

Subject to the exceptions and limitations provided under the PDPA, you have the following rights:

• Right of Access: To request a copy of the personal data we hold about you and information about how it has been used or disclosed.
• Right of Correction: To request correction of any inaccuracy or error in your personal data.
• Right to Withdraw Consent: To withdraw consent to any processing at any time, subject to legal or contractual restrictions.
• Right to Data Portability: To request a copy of personal data you provided to us in a structured, machine-readable format where technically feasible.

To exercise any of these rights, please submit a written request to our DPO at dpo@zeroai.sg. We will respond within thirty (30) calendar days. We may charge a reasonable fee for access requests as permitted under the PDPA.

12. Cookies and Tracking Technologies

Our website uses essential cookies required for site operation (e.g., session management) and analytics cookies to understand usage patterns. Analytics cookies collect data in an aggregated form and do not identify individuals. By using our website, you consent to the use of these cookies.

You may disable cookies via your browser settings; however, doing so may impair certain features of our website. We do not use third-party advertising cookies or cross-site tracking technologies.

13. Children’s Privacy

Our Services are intended for individuals aged 18 years and above. We do not knowingly collect personal data from persons under the age of 18. If we become aware that personal data of a minor has been collected without appropriate parental or guardian consent, we will take prompt steps to delete it. If you believe we have inadvertently collected such data, please contact our DPO immediately.

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, the Services we offer, or applicable law. Where material changes are made, we will notify you by prominent notice on our website and, where we have your contact details, by email, at least fourteen (14) days prior to the changes taking effect. Your continued use of the Services after the effective date of the revised Policy constitutes your acceptance of the changes. We encourage you to review this Policy periodically.

15. Contact and Complaints

For any questions, concerns, access requests, or complaints regarding the handling of your personal data, please contact our Data Protection Officer:

If you are not satisfied with our response, you have the right to lodge a complaint with the Personal Data Protection Commission of Singapore at www.pdpc.gov.sg.

1. Account Registration and Eligibility

To use the Services, you must:

• Be at least 18 years of age and have the legal capacity to enter into a binding contract under Singapore law.
• Provide complete, accurate, and current registration information, including a valid Singapore mobile number to receive SMS summaries.
• Maintain and promptly update your account information to keep it accurate.
• Keep your account credentials strictly confidential and immediately notify us at support@zeroai.sg of any unauthorised use of your account.

You are solely responsible for all activity that occurs under your account. Zero AI reserves the right to refuse registration, suspend, or terminate any account at our sole and absolute discretion, without prior notice or liability.

2. Description of Services

Zero AI provides an AI-powered telephony service that:

• Answers incoming telephone calls to your designated number on your behalf using an AI voice agent.
• Engages callers in natural-language conversation, collects messages, and manages call interactions according to your configured preferences.
• Generates a machine-produced text transcript of each call.
• Delivers a concise SMS summary of the call to your registered mobile number.

The Services are provided on a subscription basis. Zero AI may, at its discretion, introduce, modify, suspend, or discontinue any feature or component of the Services at any time. We will endeavour to provide reasonable advance notice of material changes, but are not obligated to do so.

4. Subscriber Obligations Regarding Callers

As a condition of using our Services, you agree and warrant that:

• You will take all steps necessary to ensure that any person who calls your Zero AI-enabled number is, prior to or at the commencement of the call, duly notified that: (a) they are being answered by an AI agent and not a human; and (b) the call will be recorded and processed.
• You will not disable, modify, or remove the default AI disclosure greeting provided by Zero AI without putting in place an equivalent or superior disclosure mechanism.
• You will comply with all applicable laws and regulations in Singapore (and any other jurisdiction from which your callers may originate) relating to call recording, consent, and communications privacy.
• You will not use the Services to intercept, record, or monitor any communication in a manner that violates any applicable law.
• You will not direct or permit the Services to handle calls on behalf of any third party other than yourself without Zero AI's prior written consent.

Zero AI bears no responsibility for any legal liability you incur as a result of your failure to comply with applicable call recording or consent requirements.

5. Acceptable Use Policy

You agree to use the Services only for lawful purposes and in compliance with these Terms. Without limiting the foregoing, you must not:

• Use the Services for any unlawful, fraudulent, deceptive, abusive, defamatory, or harassing purpose.
• Use the Services to impersonate any person or entity, or to falsely represent your identity or affiliation.
• Use the Services to transmit unsolicited communications, spam, phishing messages, or any communication that violates the PDPA's Do Not Call provisions or Singapore's Spam Control Act.
• Reverse-engineer, decompile, disassemble, or attempt to extract the source code, AI model weights, training data, or algorithms underlying our Services.
• Circumvent, disable, or interfere with any security feature, access-control system, or technical protection measure of the Services.
• Use automated scripts, bots, crawlers, or data-mining tools to access, scrape, or extract data from the Services.
• Conduct or facilitate load-testing, penetration testing, or any security assessment of our infrastructure without our prior written consent.
• Resell, sublicense, or commercially exploit access to the Services without our prior written consent.
• Use the Services in any manner that could damage, overburden, or impair the infrastructure of Zero AI or Zero1 Group Pte Ltd.

Zero AI reserves the right to immediately suspend or terminate your access to the Services and take any appropriate legal action upon detection of any violation of this Acceptable Use Policy.

6. AI Outputs — Accuracy Disclaimer

Our Services employ artificial intelligence technologies including automatic speech recognition, natural language understanding, and large language models. You acknowledge and agree that:

• AI-generated transcripts and SMS summaries may contain errors, omissions, or inaccuracies and do not constitute verbatim legal records of calls.
• The AI agent may misinterpret caller intent, provide incorrect information, or fail to handle unusual or complex interactions appropriately.
• You should not rely solely on AI outputs for any critical business decision, legal matter, medical situation, financial transaction, or emergency.
• Zero AI makes no representation or warranty that AI outputs will be accurate, complete, timely, or fit for any particular purpose.

Zero AI shall not be liable for any loss or damage arising from your reliance on AI-generated content.

7. Subscriptions, Fees, and Payment

• Access to the Services requires a paid subscription. Applicable fees are set out in the pricing schedule published on our website, which may be updated from time to time.
• All fees are quoted and payable in Singapore Dollars (SGD) unless otherwise stated, and are exclusive of applicable GST or other taxes, which will be added where required by law.
• Subscriptions are billed in advance on a recurring basis (monthly or annually, as selected). Payment is due on the billing date. Failure to pay may result in suspension or termination of your account.
• All fees paid are non-refundable except where expressly stated in our refund policy or where required by applicable law, including the Consumer Protection (Fair Trading) Act.
• We reserve the right to change our pricing upon thirty (30) days' notice. Continued use of the Services after the effective date of a price change constitutes your acceptance of the new pricing.
• We may offer free trials at our discretion. Trials automatically convert to paid subscriptions at the end of the trial period unless cancelled beforehand.

8. Service Availability

We will use commercially reasonable efforts to maintain high availability of the Services. However:

• The Services are provided on an "as available" basis. We do not guarantee uninterrupted, error-free, or continuous access.
• We may carry out planned or emergency maintenance at any time, which may temporarily affect availability. Where practicable, we will give advance notice of planned maintenance.
• We are not liable for any loss arising from service interruptions caused by third-party telecommunications network failures, carrier outages, force majeure events, or circumstances beyond our reasonable control.

9. Intellectual Property

All right, title, and interest in and to the Services, including but not limited to our website, platform software, AI models, algorithms, brand names, logos, trade marks, and user interface designs, are and shall remain the exclusive property of Zero AI Pte. Ltd. and/or Zero1 Group Pte Ltd. Nothing in these Terms grants you any licence, right, or interest in our intellectual property except the limited right to use the Services in accordance with these Terms.

As between you and Zero AI, you retain ownership of any content you provide to us (e.g., call preferences, agent scripts). By providing such content, you grant Zero AI a non-exclusive, worldwide, royalty-free licence to use, process, and store that content solely to provide and improve the Services.

10. Suspension and Termination

• You may cancel your subscription at any time through your account dashboard. Cancellation takes effect at the end of the current billing period; no partial refunds are provided for unused periods.
• Zero AI may immediately suspend or terminate your access to the Services, without liability to you, if: (a) you breach these Terms; (b) we are required to do so by law or a regulatory authority; (c) we reasonably suspect fraudulent, abusive, or illegal activity on your account; or (d) continued provision of the Services poses a risk to other users or our infrastructure.
• Upon termination, your right to use the Services ceases immediately. We may retain your data for the periods specified in our Privacy Policy; otherwise, we will delete your account data in accordance with our data retention schedule.

11. Disclaimer of Warranties

TO THE FULLEST EXTENT PERMITTED BY APPLICABLE LAW, THE SERVICES AND ALL AI-GENERATED OUTPUTS (INCLUDING TRANSCRIPTS AND SMS SUMMARIES) ARE PROVIDED "AS IS" AND "AS AVAILABLE", WITHOUT ANY WARRANTY OF ANY KIND, WHETHER EXPRESS, IMPLIED, STATUTORY, OR OTHERWISE.

ZERO AI EXPRESSLY DISCLAIMS ALL IMPLIED WARRANTIES, INCLUDING ANY WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, TITLE, ACCURACY, NON-INFRINGEMENT, AND ANY WARRANTIES ARISING FROM COURSE OF DEALING OR USAGE OF TRADE. WE DO NOT WARRANT THAT THE SERVICES WILL BE UNINTERRUPTED, ERROR-FREE, SECURE, OR FREE FROM VIRUSES OR OTHER HARMFUL COMPONENTS.

12. Limitation of Liability

TO THE MAXIMUM EXTENT PERMITTED BY THE LAWS OF SINGAPORE:

• ZERO AI, ZERO1 GROUP PTE LTD, AND THEIR RESPECTIVE DIRECTORS, OFFICERS, EMPLOYEES, AGENTS, LICENSORS, AND SUBPROCESSORS SHALL NOT BE LIABLE TO YOU OR ANY THIRD PARTY FOR ANY INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL, EXEMPLARY, OR PUNITIVE DAMAGES, OR DAMAGES FOR LOSS OF PROFITS, REVENUE, DATA, BUSINESS, GOODWILL, OR OTHER INTANGIBLE LOSSES, HOWEVER CAUSED AND REGARDLESS OF THE THEORY OF LIABILITY.
• IN NO EVENT SHALL ZERO AI'S TOTAL AGGREGATE LIABILITY TO YOU FOR ALL CLAIMS ARISING OUT OF OR RELATED TO THESE TERMS OR THE SERVICES EXCEED THE TOTAL AMOUNT OF SUBSCRIPTION FEES ACTUALLY PAID BY YOU TO ZERO AI IN THE THREE (3) MONTHS IMMEDIATELY PRECEDING THE EVENT GIVING RISE TO THE CLAIM, OR SGD 100, WHICHEVER IS GREATER.
• THE LIMITATIONS IN THIS SECTION APPLY EVEN IF ZERO AI HAS BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES AND EVEN IF ANY REMEDY FAILS OF ITS ESSENTIAL PURPOSE.

Some jurisdictions do not allow the exclusion or limitation of certain damages. In such jurisdictions, our liability is limited to the greatest extent permitted by law.

13. Indemnification

You agree to defend, indemnify, and hold harmless Zero AI Pte. Ltd., Zero1 Group Pte Ltd, and their respective directors, officers, employees, and agents from and against any and all claims, damages, losses, costs, and expenses (including reasonable legal fees) arising out of or in connection with: (a) your use of the Services; (b) your violation of these Terms; (c) your failure to obtain or provide required disclosures or consents to third-party callers; (d) any content you configure on the Services; or (e) your violation of any applicable law or the rights of any third party.

14. Amendments to These Terms

We may revise these Terms at any time. For material changes, we will provide at least fourteen (14) days' advance notice via email or prominent notice on our website. If you do not agree with the revised Terms, you must stop using the Services before the effective date of the changes. Your continued use of the Services after the effective date constitutes acceptance of the revised Terms.

15. Governing Law and Dispute Resolution

These Terms are governed by and construed in accordance with the laws of the Republic of Singapore, without regard to its conflict-of-laws principles.

In the event of a dispute arising out of or in connection with these Terms, the parties shall first attempt to resolve the dispute through good-faith negotiation for a period of thirty (30) days following written notice of the dispute.

If the dispute is not resolved through negotiation, either party may refer the dispute to mediation administered by the Singapore Mediation Centre ("SMC") in accordance with the SMC's Mediation Procedure in force for the time being. If mediation is unsuccessful, the dispute shall be finally submitted to the exclusive jurisdiction of the courts of the Republic of Singapore.

16. General Provisions

• Entire Agreement: These Terms, together with the Privacy Policy and any applicable order form or subscription agreement, constitute the entire agreement between you and Zero AI with respect to the Services and supersede all prior agreements, representations, and understandings.
• Severability: If any provision of these Terms is found to be invalid or unenforceable, that provision shall be modified to the minimum extent necessary to make it enforceable, and the remaining provisions shall continue in full force and effect.
• No Waiver: Our failure to enforce any right or provision of these Terms shall not constitute a waiver of that right or provision.
• Assignment: You may not assign or transfer any rights or obligations under these Terms without our prior written consent. Zero AI may assign these Terms (including in connection with a merger, acquisition, or sale of assets) without restriction.
• Force Majeure: Neither party shall be liable for any failure or delay in performance due to causes beyond its reasonable control, including natural disasters, acts of government, war, terrorism, pandemic, or telecommunications network failures.
• Language: These Terms are executed in the English language. In the event of any conflict between an English version and a translated version, the English version shall prevail.

17. Contact Us

For questions, legal notices, or complaints regarding these Terms, please contact: