Updated at 2022-10-11


The purpose of this document (“Privacy Policy”) is to inform you of how we handle or process Personal Data (as defined below) which is subject to the Personal Data Protection Act 2012 of Singapore (“PDPA”). Please take a moment to read this Privacy Policy so that you know and understand the purposes for which we collect, use and disclose your Personal Data.

By interacting with us, submitting information to us or signing up for any products or services offered by us, accessing our website or using our mobile application the “Wave App”, you agree and consent to [Wave Metaverse Pte. Ltd. (Company Registration No. 202209949D), with a registered office address of 3 Fraser Street, #05-25, Duo Tower, Singapore 189352] its related corporations and affiliates (collectively, the "Companies"), as well as our respective representatives and/or agents ("Representatives") (the Companies and Representatives collectively referred to herein as "Wave", "us", "we" or "our") collecting, using, disclosing and sharing amongst themselves your Personal Data, and disclosing such Personal Data to the Companies’ authorised service providers and relevant third parties in the manner set forth in this Privacy Policy. In addition, this Privacy Policy will also provide you with more information on the basis upon which we may lawfully collect, use and/or disclose your Personal Data without your consent, where permitted by applicable law.

This Privacy Policy supplements but does not supersede nor replace any other consents you may have previously provided to us in respect of your Personal Data, and your consents herein are cumulative and additional to any rights which we may have at law to collect, use, disclose and/or process your Personal Data. This Privacy Policy does not affect any rights which we may have at law in connection with the collection, use, disclosure and/or processing of your Personal Data.

We reserve, in our sole discretion, the right to revise this Privacy Policy at any time and send you notification of updates to this Privacy Policy in any form as we may deem appropriate. While you should regularly check this Privacy Policy, we may also inform you of how we process your Personal Data by publishing (or amending) this Privacy Policy and, where required by applicable law, by posting a notice, or reaching you via other forms of communication (e.g. sending you an SMS message or email, or giving you a phone call) according to such contact particulars that we may have of you in our records from time to time. You may also contact us in the manner disclosed in this Privacy Policy to learn about our handling or processing of your Personal Data.

We may from time to time update this Privacy Policy to, for example, ensure that this Privacy Policy is consistent with our future developments, industry trends and/or any changes in legal or regulatory requirements. To the maximum extent permissible under applicable law, you agree to be bound by the prevailing terms of this Privacy Policy as may be updated from time to time on our website https://app.waveuniverse.org/, and/or as you may be notified. Please check back regularly for updated information on the handling or processing of your Personal Data.


1.1 In this Privacy Policy, "Personal Data" means all data that falls within the definition of personal information, personal data, personally identifiable information or similar language under any applicable law relating to the protection, privacy and security, collection, use or disclosure of sensitive or other personally identifiable information, including the PDPA (collectively, "Data Protection Laws").

1.2 Examples of such Personal Data which we collect and/or which you may provide us include (depending on the nature of your interaction with us) include:

• (a)personal details (such as name, gender, date of birth/age, nationality, passport or national ID number, social security number, tax identification number);

• (b)contact details (such as mailing address, email address, telephone number, social media account details);

• (c)log in information (such as username, email address, password);

• (d)photographs (such as those taken via / uploaded from your device);

• (e)information about your visit and use of our Site and Services, including date/time stamps, cookies, information about your domain name and IP addresses; and

• (f)financial details including but not limited to bank information, credit card information, utility bill, credit report, other financial details;

• (g)corporate details including but not limited to name, place of registration, registration number, transparency register number, details with respect to articles of association and other similar documents/certificates, details with respect to shareholders and/or beneficial owners (including their personal and contact details; and

• (h)technical information of your device which you use for orders and communication (such as cell phone, tablet, notebook, personal computer, IP address).

1.3 In the course of your interaction with us, we may also create Personal Data about you, such as records of your interactions with us and details of your transaction history.

1.4 In order to comply with international sanctions and applicable regulations for securities and to fight money-laundering or the financing of terrorism, we may need to check any Personal Data provided by you against publicly available databases.

1.5 For the avoidance of doubt, in the event that Data Protection Laws permits us to collect, use, disclose and/or process your Personal Data without your consent, such permission granted by such Data Protection Laws shall continue to apply.


2.1 Generally, we collect your Personal Data in the following ways:

• (a) when you submit any form to us, including but not limited to any registration or referral forms, or when you update or add information to your user profile, whether on our websites or platforms (such as the Wave App);

• (b) when you use our services provided through online and other technology platforms, such as websites and apps, including when you establish any online accounts with us;

• (c) when you enter into any agreement or provide other documentation or information in respect of your interactions and transactions with us, or when you use our services;

• (d) when you interact with our staff and Representatives, for example, via telephone calls (which may be recorded), letters, fax, face-to-face meetings and email;

• (e) when you request that we contact you, be included in an email or other mailing list, or when you respond to our request for additional Personal Data, our promotions and other initiatives;

• (f) when you are contacted by, and respond to, our marketing representatives and agents and other service providers;

• (g) when we seek information about you and receive your Personal Data in connection with your relationship with us, including for our services and/or job applications, for example, from business partners, public agencies, your ex-employer and the relevant authorities;

• (h) when you submit an employment application or when you provide documents or information including your resume and/or curriculum vitae in connection with any appointment or position;

• (i) when you contact us via e-mail, telephone or by any other means;

• (j) when you visit any of our websites or use the Wave App, or use any features or resources available on or through our websites or Wave App;

• (k) when you have subscribed to our newsletter, responded to a survey or filled out any forms on our websites or the Wave App;

• (l) where you have manifestly chosen to make such Personal Data public, including via any of your social media profiles;

• (m) when you link any of your account with us with third-party services and applications, such as your instant messaging (e.g. WhatsApp) or other social media accounts (e.g. Facebook and Instagram);

• (n) when we receive your Personal Data from third parties, for example, when you submit your email address to us to show interest, we receive information from a third party that provides automated fraud detection services to the Wave App, or from parties that legally provide it to us, such as credit reference agencies or law enforcement agencies;

• (o) when you submit your Personal Data to us for any other reason.

2.2 If you provide us with any Personal Data relating to a third party (e.g. information on your dependent, spouse, children and/or parents), by submitting such information to us, you represent and warrant to us that you have obtained the consent of such third party to you providing us with their Personal Data, and for the further collection, use, disclosure and/or processing by us of their Personal Data, for the purposes contemplated hereunder, and that such consents have not been withdrawn.

2.3 You shall ensure that all Personal Data submitted to us is complete, accurate, true and correct. Failure on your part to do so may result in our inability to provide you with the products and/or services which you have requested.


3.1 In general, we collect, use, disclose and/or process your Personal Data for the following purposes:

• (a) processing your registration;

• (b) providing you with goods and/or services which you have purchased or requested to receive;

• (c) to personalise your experience and to allow us to better respond to your individual needs;

• (d) to improve our websites and platforms, including the Wave App;

• (e) to provide, maintain and improve our services;

• (f) to improve our customer service and to allow us to more effectively respond to your customer service requests and support needs;

• (g) verifying your identity;

• (h) to send periodic emails;

• (i) to process all transactions conducted on our website and the Wave App;

• (j) matching any Personal Data held which relates to you for any of the purposes listed herein;

• (k) requesting feedback or participation in surveys, as well as conducting market research and/or analysis for statistical, profiling or other purposes for us to design our products, understand customer behaviour, preferences and market trends, and to review, develop and improve the quality of our products and services;

• (l) to administer any contest, promotion, survey, or other site feature;

• (m) for us or our business partners to inform you via e-mail about upcoming opportunities and promote our respective products and services, where you have consented to receiving information/newsletters from us;

• (n) facilitating business asset transactions (which may extend to any mergers, acquisitions or asset sales) involving any of the Companies;

• (o) to respond to, handle, and process queries, requests, applications, complaints, and feedback from you;

• (p) detect, prevent, and address technical issues;

• (q) enhance security, monitor and verify identity or service access, combat spam or other malware or security risks;

• (r) managing and preparing reports on incidents and accidents;

• (s) send information including confirmations, technical notices, updates, security alerts, and support and administrative messages;

• (t) detect, prevent and mitigate fraud and abuse of our services and to protect you against account compromise or funds loss;

• (u) in connection with any claims, actions or proceedings (including but not limited to drafting and reviewing documents, transaction documentation, obtaining legal advice, and facilitating dispute resolution), and/or protecting and enforcing our contractual and legal rights and obligations;

• (v) complying with any applicable rules, laws and regulations, codes of practice or guidelines or to assist in law enforcement and investigations by relevant authorities; and

• (w) for purposes which are reasonably related to the aforesaid.

These purposes may also apply even if you do not maintain any account(s) with us, or have terminated these account(s).

3.2 In addition, Wave App collects, uses and discloses your Personal Data for the following purposes depending on the nature of our relationship:

• (a) verifying and processing your personal particulars and payments in relation to the purchase or provision of goods and/or services;

• (b) providing you with goods and/or services which you have purchased or requested to receive, and to push content to you which may be relevant to you (including to personalise and customise your experience based on your interactions with our platform(s) and the Wave App, and other content you submit from time to time);

• (c) communicating with you and informing you of changes and development to the Companies' policies, terms and conditions and other administrative information, including for the purposes of servicing you in relation to the products and services offered to you;

• (d) resolving complains and handling requests and enquiries;

• (e) conducting market research for statistical, profiling and statistical analysis for the improvement of services provided to you; and

• (f) processing of your Personal Data in relation to any of the purposes stated above.

3.3 In addition, and without prejudice to the generality of the foregoing, if you submit an application to us as a candidate for employment or an internship, or are an existing employee of us, we collect, use, disclose and/or process your Personal Data for the following purposes:

• (a) for management and/or evaluative purposes, including without limitation to process your employment application, to conduct pre-recruitment checks, and/or to provide or obtain employee references or other references where relevant for background screening and/or vetting;

• (b) for personnel administration, including to administer benefits and payroll processing, to administer or execute employee remuneration schemes, and/or to his/her employment-related work activities;

• (c) to enter into an employment relationship with you or to appoint you to any office;

• (d) to manage or terminate the employment relationship with you or appoint you, including without limitation role assessment, job compatibility assessment, career progression and/or management of staffing requirements; and/or

• (e) for purposes which are reasonably related to the aforesaid.

3.4 Furthermore, and without prejudice to the generality of the foregoing, and where permitted under Data Protection Laws, we may also collect, use, disclose and/or process your Personal Data for any of the following purposes:

• (a) providing or marketing services, products and benefits to you, including promotions, loyalty and reward programmes including joint marketing and/or cross promotions with third parties;

• (b) matching Personal Data with other data collected for other purposes and from other sources (including third parties) in connection with the customisation, provision or offering of products, services, marketing or promotions, whether by us or other third parties;

• (c) administering contests and competitions, and personalising your experience at our touchpoints;

• (d) recommending, identifying and/or contacting you to inform you of products, services, special offers and rewards, either to our customers generally, or which we have identified may be of interest to you, or that are or may be relevant to you, in any case including on behalf of third parties, or sharing your Personal Data with such third parties or their service providers for them to collect, use, disclose or process your Personal Data for any of such purposes; and/or

• (e) conducting research, analysis and development activities (including data analytics, surveys, product and service development and/or profiling), understanding and analysing customer behaviour, location, preferences and demographics for us to offer you products and services as well as special offers and marketing programmes which may be relevant to your preferences and profile.

3.5 If you have provided us with your Singapore telephone number(s) and have indicated that you consent to receiving marketing or promotional information via your Singapore telephone number(s), then from time to time, we may contact you using such Singapore telephone number(s) (including via voice calls, text, fax or other means) with information about our products and services.

3.6 In relation to particular products or services or in your interactions with us, we may also have specifically notified you of other purposes for which we collect, use, disclose and/or process your Personal Data. If so, we will collect, use, disclose and/or process your Personal Data for these additional purposes as well, unless we have specifically notified you otherwise.

3.7 We also reserve the right to monitor, check and process your Personal Data if necessary to investigate or obtain evidence concerning any complain, claim or dispute or any actual or suspected illegal or unlawful conduct or to aid in such investigation or evidence gathering by any law enforcement or regulatory authorities.

3.8 You may withdraw your consent by contacting us using the contact details set out at paragraph 8 below.


4.1 Subject to the provisions of any applicable law, you hereby agree, acknowledge and consent that your Personal Data may be disclosed for any of the purposes listed above in this Privacy Policy (as applicable) to the following entities or parties, regardless of whether they are located overseas or in Singapore:

• (a) our advertisers, contest sponsors, our promotional and marketing partners, and others who provide our content or whose products or services we think may interest you;

• (b) any business partner, investor, assignee or transferee (actual or prospective) to facilitate business asset transactions (which may extend to any merger, acquisition or asset sale);

• (c) agents, contractors or third-party service providers (including software providers) who we engage to perform functions and provide services to us;

• (d) analytics, search engine providers or other third party service providers that assist us in delivering our products, services, websites and platforms as well as improving and optimising the same;

• (e) any business partner, investor, assignee or transferee (actual or prospective) to facilitate business asset transactions (which may extend to any merger, acquisition or any debt or asset sale) involving any of the Companies;.

• (f) the Companies;

• (g) our service providers and contractors, including third party vendors that provide data processing or management services;

• (h) our business partners (and in particular, where you have consented to receiving information/newsletters from us);

• (i) relevant government regulators, government ministries, statutory boards or authorities and/or law enforcement agencies, to comply with any directions, laws, rules, guidelines, regulations or schemes issued or administered by any of them;

• (j) banks, credit agencies and other financial and/or payment service providers;

• (k) IT-service providers;

• (l) our professional advisers such as our board of directors, auditors and lawyers;

• (m) external business and charity partners in relation to corporate promotional events; and/or

• (n) any other party to whom you authorise us to disclose your Personal Data to.


5.1 In addition to the matters set forth above, subject to and in accordance with applicable law, you shall be deemed to have consented to us collecting, using, disclosing and sharing amongst ourselves your Personal Data, and disclosing such Personal Data to the Companies' authorised service providers and relevant third parties:

• (a) where in response to a request for your Personal Data in connection with identified purposes, you voluntarily provide such Personal Data to us for such purpose(s) and it is reasonable that you would voluntarily provide such Personal Data; and

• (b) where the collection, use and/or disclosure of your Personal Data is reasonably necessary for the conclusion and/or performance of a contract, between you and us or any other organisation entered into at your request, which may include recipients of your Personal Data not indicated in this Privacy Policy.


6.1 In addition to and without limiting the consents you have provided to our collection, use and/or disclosure of your Personal Data for the purposes set out elsewhere in this Data Protection Policy, where permitted by applicable law, Wave App may also in accordance the requirements thereof also collect, use and/or disclose your Personal Data as further detailed below including without consent, where we meet the requirements of applicable law:

• (a) for our legitimate interests or the legitimate interests of another person (but not for sending you direct marketing messages unless you have otherwise provided your consent), including without limitation for the following purposes:
(i) any investigations or proceedings;
(ii) fraud detection and prevention;
(iii) entering into, managing or terminating an employment relationship or appointment; and
(iv) detection and prevention of misuse of services by users; and

• (b) we may collect your Personal Data from any of the Companies, we may use your Personal Data, and any of the Companies may disclose your Personal Data to us, for improving our products, services, processes or business, understanding customer preferences and personalising experiences and recommendations (regardless whether you are an existing or prospective customer of any of the Companies).


We encourage you to contact us as soon as possible to enable us to update any Personal Data we have about you. Incomplete or outdated Personal Data may result in our inability to provide, or delays in providing you with products and services you have requested, or processing any requests and applications you may have made to us.


We retain your information only for the duration we need to provide you with the services and to fulfil the purposes described in this Privacy Policy. This is also the case for third-parties to whom we share your information with and who carries out services on our behalf. Your information will be retained as is reasonably necessary for our business and to comply with our legal or regulatory obligations. Where your data is no longer needed, we will either remove it from our systems or depersonalise it so that we cannot identify you.


9.1 We will take reasonable efforts to protect Personal Data in our possession or under our control by making reasonable security arrangements to prevent unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, as well as the loss of any storage medium or device on which Personal Data is stored.

9.2 We offer the use of a secure server. All supplied sensitive/credit information is transmitted via Secure Socket Layer (SSL) technology and then encrypted into our Payment gateway providers database only to be accessible by those authorized with special access rights to such systems, and are required to keep the information confidential. After a transaction, your private information (credit cards, social security numbers, financials, etc.) is never kept on file.

9.3 However, we cannot completely guarantee the security of any Personal Data we may have collected from or about you, or that for example no harmful code will enter our website. You should be aware of the risks associated with using websites.

9.4 We cannot ensure the security of the information you transmit to us via the Internet, and we urge you to take every precaution to protect your Personal Data when you use our platforms. We recommend that you change your passwords often, use a combination of letters and numbers, and ensure that you use a secure browser..


10.1 You acknowledge and agree that our websites and platforms may include analytics code and other tools that may allow us to gather information on any use of any of our websites and platforms, and may include our use of cookies, running of verification and compliance analysis and/or use of data capture, syndication analysis, and/or other similar tools to track, extract, compile, aggregate, archive, disclose or otherwise analyse any data and/or information resulting from any person's access to and/or use of any of our websites and platforms, and further that: (a) we shall retain all rights, title and interest in and to all such gathered information and data; (b) you shall not disable or interfere with any such analytics code and tools; and (c) any intellectual property rights of or in the results of such analytics shall vest solely in us. For the avoidance of doubt, we may monitor, track and share with third parties your geo-location information obtained by any of our websites and platforms for safety, security, technical, marketing and commercial purposes, including to provide and improve our products and services.

10.2 For example, our websites and platforms may use cookies and other technologies. In this regard:

• (a) Cookies are small text files stored in your computing or other electronic devices when you visit our website and platforms for record keeping purposes. Cookies are stored in your browser's file directory, and the next time you visit the website or platform, your browser will read the cookie and relay the information back to the website, platform or element that originally set the cookie. Depending on the type of cookie it is, cookies may store user preferences and other information.

• (b) Web beacons (also known as pixel tags and clear GIFs) involve graphics that are not apparent to the user. Tracking links and/or similar technologies consist of a few lines of programming code and can be embedded in our websites or platforms. Web beacons are usually used in conjunction with cookies and primarily used for statistical analysis purposes. This technology can also be used for tracking traffic patterns on websites and platforms, as well as finding out if an e-mail has been received and opened and to see if there has been any response.

10.3 Without limiting the generality of the foregoing, we may employ cookies and other technologies as follows:

• (a) tracking information such as the number of visitors and their frequency of use, profiles of visitors and their preferred sites;

• (b) making our websites and platforms easier to use. For example, cookies may be used to help speed up your future interactions with our websites and platforms;

• (c) to better tailor our products and services to your interests and needs. For example, cookies information may be identified and disclosed to our vendors and business partners to generate consumer insights;

• (d) collating information on a user's search and browsing history;

• (e) when you interact with us on our websites and platforms, we may automatically receive and record information on our server logs from your browser. We may collect for the purposes of analysis, statistical and site-related information including, without limitation, information relating to how a visitor arrived at the website or platform, the browser used by a visitor, the operating system a visitor is using, a visitor's IP address, and a visitor's click stream information and time stamp (which may include for example, information about which pages they have viewed, the time the pages were accessed and the time spent per web page, your searches for hotels or experiences, bookings you have made, and other actions);

• (f) using such information to understand how people use our websites and platforms, and to help us improve their structure and contents;

• (g) using cookies that are necessary in order to enable our websites and platforms to operate, for example, cookies that enable you to log onto secure parts of our websites and platforms; and/or

• (h) personalising the website and platform for you, including delivering advertisements which may be of particular interest to you and using cookie related information to allow us to understand the effectiveness of our advertisements.

10.4 We may also collect information about your precise or approximate location as determined through data such as your IP address or mobile device's GPS to offer you an improved user experience. Most mobile devices allow you to control or disable the use of location services for applications in the device's settings menu. Wave App may also collect this information even when you are not using the app if this connection is enabled through your settings or device permissions.

10.5 Some cookies we use are from third party companies to provide us with web analytics and intelligence about our websites and platforms. These companies collect information about your interaction with our websites and platforms. We use such information to compile statistics about visitors who interact with the websites, platforms and other Wave App online content, to gauge the effectiveness of our communications, and to provide more pertinent information to our visitors.

10.6 If you do not agree to such use of cookies, you can adjust your browser settings. Unless you have adjusted your browser settings to block cookies, our system will issue cookies as soon as you visit our site or click on a link in a targeted email that we have sent you, even if you have previously deleted our cookies.

10.7 The way which cookies can be managed depends on your browser. Please check with your browser provider on how you may configure or disable cookies on your browser.

10.8 If you do not agree to our use of cookies and other technologies as set out in this Data Protection Policy, you should delete or disable the cookies associated with our websites and platforms by changing the settings on your browser accordingly. However, you may not be able to enter certain part(s) of our websites or platforms. This may also impact your user experience while on our websites or platforms.


We do not intentionally collect Personal Data from persons under the age of 13. Please contact us if you are a parent or guardian and you are aware that your child has provided us with Personal Data without your permission. If we become aware that we have collected Personal Data from anyone under the age of 13 without parental consent, we will take steps to remove such Personal Datafrom our servers.


Certain links contained on our websites may direct you to co-branded websites maintained by us or to companies which we have established business relationships. When you submit information to one of these co-branded sites or partner companies, you may be submitting it to both us and these business partners. This Privacy Policy does not apply to any information that you may provide to third parties, such as through other sites linked to our website. We are not responsible for those sites and cannot control the content of what is offered on those sites, or links from those sites, or the privacy policy or data security, if any, of those sites, and we therefore strongly encourage you to read their respective privacy policies as they may differ from ours.


13.1 If you:

• (a) have any questions or feedback relating to your Personal Data or about this Privacy Policy, including without limitation our reliance on the legitimate interests and/or deemed consent bases of collecting, using and/or disclosing your Personal Data as described in this Privacy Policy;

• (b) would like to withdraw your consent to any use of your Personal Data as set out in this Privacy Policy;

• (c) would like to obtain access and make correction to your Personal Data records;

• (d) change your preferences with respect to communications and other information you receive from us; or

• (e) would like to request the restriction of certain uses and disclosures of Personal Data, you can approach us via the following channels:
(i) email us [•];
(ii) call us at [•].

13.2 You may also write to our Data Protection Officer as follows:

• Data Protection Officer

• [Wave Metaverse Pte. Ltd.]

• [•insert DPO details]

13.3 Please note that if your Personal Data has been provided to us by a third party, you should contact that organisation or individual to make such queries, complaints, and access and correction requests to us on your behalf.

13.4 You may withdraw your consent as provided under PDPA. However, if you withdraw your consent to any or all collection, use, and/or disclosure of your Personal Data, depending on the nature of your request, we may not be in a position to continue to provide its products or services to you, administer any contractual relationship already in place, or perform or conclude an existing or prospective agreement. This may also result in the termination of any agreements you have with us, and your being in breach of your contractual obligations or undertakings. Our legal rights and remedies in such event are expressly reserved.


This Privacy Policy shall be governed in all respects by the laws of Singapore.

PRIVACY POLICY LAST UPDATED: Updated at 2022-10-11