Micro Cloud Technology operates in two primary capacities—as a data processor and as a data controller:

• As a Data Processor: Many of our customers use our platform to enable communications between their businesses and their end-users (e.g., sending transactional SMS or making VoIP calls). In such cases, Micro Cloud Technology acts as a data processor on behalf of our customers. We handle the personal data strictly based on the customer’s instructions and in accordance with service agreements and data processing agreements (DPAs). Our customers are the data controllers, responsible for determining the purpose and legality of the data processing.

For example, if you receive an SMS through our platform from one of our customers, that customer controls the content and purpose of the message, while we process and transmit it on their behalf. If an end-user submits a data access or deletion request, we forward it to the relevant customer, as they are the data controller.

• As a Data Controller: When we collect personal data for our own business purposes—such as account management, billing or product development—Micro Cloud Technology operates as a data controller. This means we determine the purposes and means of processing your personal data and ensure compliance with the PDPA and other applicable laws.

We use your personal data for purposes directly related to our communication services, as outlined below:

• Account setup and service provision: To verify your identity, activate communication services (e.g., SMS, VoIP, e-SIM), and manage your subscriptions.
• Communication services: To transmit and deliver SMS messages, VoIP calls, and e-SIM services, ensuring smooth interconnection with telecom operators and other communications providers.
• Billing and payments: Generating invoices, processing payments, and resolving billing inquiries.
• Service improvements: To analyze service usage data, enhance platform performance, develop new features, and optimize our services.
• Compliance with legal and regulatory requirements: To fulfill obligations under the PDPA and other relevant laws, including those related to telecommunications services.

By using our SMS, VoIP, or e-SIM services—either directly or through a customer’s application—you provide implied consent for the collection, use, and disclosure of your personal data as outlined in this Privacy Notice. Your consent is inferred when you:

• Interact with our communication services by sending or receiving SMS messages or VoIP calls.
• Activate or utilize e-SIM services on your device.
• Use our platform via APIs or integrations to facilitate communication between businesses and their end-users.

We process your data based on your consent or other legal bases, such as the necessity to fulfill contractual obligations or comply with legal requirements. If you use our platform through a third-party service (e.g., a business sending you SMS via our platform), that third party is responsible for obtaining your consent.

Micro Cloud Technology adheres to the PDPA’s principle of data minimization. We only collect, use, and disclose the personal data necessary to provide our services or meet legal obligations. We do not sell or share personal data with third parties for marketing purposes. Personal data is only shared with trusted partners essential to service delivery, technical support, and operational maintenance.

In the course of delivering our services, particularly SMS and VoIP, we may need to transmit data across borders through telecom operators, communication providers, or other necessary partners. This could result in personal data being transferred outside of Singapore. When international data transfers occur, we ensure compliance with the PDPA’s Transfer Limitation Obligation by verifying that foreign entities provide a comparable level of data protection.

You have the right to withdraw consent for the collection, use, or disclosure of your personal data at any time. To withdraw consent or make data requests (e.g., access or correction of your data), please contact our DPO at commercial@microcloudltd.com or mail us at 7 Temasek Boulevard #18-03, Suntec Tower One, Singapore 038987. We will respond to such requests within a reasonable time, in accordance with the PDPA. Please note that withdrawing consent may impact our ability to provide certain services.

Micro Cloud Technology implements strict security measures, including encryption and access controls, to safeguard personal data from unauthorized access, loss, or misuse. We retain personal data only for as long as necessary to fulfill the purposes for which it was collected or to comply with legal obligations. Once it is no longer required, personal data will be securely deleted or anonymized, in accordance with the PDPA.

If you have concerns or complaints about how we handle your personal data, please reach out to our Data Protection Officer at commercial@microcloudltd.com or mail us at 7 Temasek Boulevard #18-03, Suntec Tower One, Singapore 038987. We take all complaints seriously and aim to resolve them in a fair and timely manner, in line with PDPC guidelines.

Our services are not intended for individuals under the age of 21. We do not knowingly collect personal data from minors. If we become aware that personal data has been provided by a minor, we will take reasonable steps to delete that information from our systems. If you suspect that a minor is using our services, please contact us immediately at commercial@microcloudltd.com.

We may revise this Privacy Notice periodically to reflect changes in technology, legal obligations, or service offerings. We encourage you to review this notice regularly to stay informed of any updates. Continued use of our services indicates your acceptance of any revised terms.

This policy is governed by the laws of Singapore and aligns with the requirements set out by the Personal Data Protection Commission (PDPC).

• e-SIM: A digital SIM that allows you to activate a mobile plan without needing a physical SIM card.
• VoIP: Voice over Internet Protocol, enabling voice communication over the internet instead of traditional phone lines.