Moka Official Website Privacy Policy (International)

Effective Date:[August 27th, 2025]

Version Number:【V2.0】

1. Scope and Overview

ALPHASTAR TECHNOLOGY (SINGAPORE) PTE. LTD. ("Moka," "we," "us," or "our") values your privacy. This Privacy Policy ("Policy") describes how we collect, use, disclose, and protect personal information of users ("user", "you", "your") of our international website(s) (https://www.mokahr.io/) and related services (collectively, the "Services").

Please read this Policy carefully before using our Services. By using our Services, you agree to the practices described herein.

2. Definition

2.1 Controller and Processor Information

Moka operates the Services. For most personal information processed through the Services where Moka determines the purpose and means (e.g., information collected for website browsing, free trials, customer support), Moka acts as a "data controller" or "business" under applicable laws.

When Moka processes personal information on behalf of its enterprise customers (Subscribers) pursuant to a contract (e.g., within the Moka recruiting software platform), Moka acts as a "data processor" or "service provider." This Policy primarily addresses our activities as a controller. Processing activities as a processor are governed by our agreements with Subscribers.

2.2 Personal Information

Personal information refers to any information recorded electronically or otherwise, which can identify a specific individual alone or in combination with other information, including but not limited to a person's name, date of birth, ID number, biometric information, address, phone number, email address, and location data. It does not include information that has been anonymized.

Sensitive personal information is that which, once leaked or illegally used, can easily lead to infringement of an individual's dignity or endanger their personal or property safety. This includes biometric data, religious beliefs, specific identities, medical health information, financial account details, location tracks, and information about individuals under the age of fourteen.

3. Information We Collect and How We Use It

We collect information that identifies, relates to, describes, or could be linked to you ("Personal Information").

We use this information to:

• Provide, operate, maintain, and improve our Services.
• Communicate with you, including responding to inquiries and sending service-related information.
• Understand how users interact with our Services to enhance user experience.
• Market our products and services (where permitted by law and in accordance with your preferences).
• Protect the security and integrity of our Services.
• Comply with legal obligations.

4. Legal Grounds for Processing

In addition to user consent, we will also collect and use user's personal information based on the following legal grounds:

If you are in the European Economic Area (EEA) or UK, we process your Personal Information based on:

• It is necessary for the conclusion or performance of a contract where the user is a party, or for the implementation of human resources management as required by lawfully formulated labor rules and regulations and collectively signed labor contracts;
• It is necessary to fulfill legal obligations or duties;
• It is necessary to respond to public health emergencies or, in emergency situations, to protect the life, health, and property safety of natural persons;
• For the public interest, such as conducting news reporting, public opinion supervision, etc., collecting and using personal information within a reasonable scope;
• In accordance with applicable laws, processing personal information that users have voluntarily disclosed or other information that has been legally made public within a reasonable scope;
• Other circumstances as prescribed by laws and administrative regulations.

5. How We Share Your Information

We may share your Personal Information with:

• Service Providers: We engage vendors to process information on our behalf (e.g., hosting, analytics, customer support, marketing). These providers are contractually bound to handle data securely and only per our instructions. See Section 7 for key providers.
• Corporate Transactions: In connection with a merger, acquisition, or asset sale.
• Legal Requirements: When required by law, regulation, legal process, or governmental request, or to protect our rights, property, or safety, or that of others.

We do not sell Personal Information for monetary value. We may engage in sharing or targeted advertising activities as defined under laws like the CCPA; please see Section 10.2.2 regarding your opt-out rights.

6. International Data Transfers

Moka is based in China. Your Personal Information may be processed in China, Singapore, or other countries where our service providers operate. These countries may have different data protection laws.

When we transfer Personal Information from the EEA, UK, or Switzerland to countries not deemed adequate by the European Commission, we rely on appropriate transfer mechanisms, such as the EU-U.S. Data Privacy Framework (DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF (where Moka's certifications apply), or Standard Contractual Clauses approved by relevant authorities. For transfers from other regions, we rely on adequacy decisions or other lawful mechanisms.

7. Cookies and Similar Technologies

We and our partners use cookies and similar technologies for the purposes listed below.

You can manage your cookie preferences through our cookie banner or your browser settings.

8. Data Security

We implement appropriate technical and organizational measures designed to protect your Personal Information, including encryption, access controls, and secure network architectures. However, no method of transmission over the Internet or electronic storage is 100% secure.

9. Data Retention

We retain Personal Information only as long as necessary to fulfill the purposes outlined in this Policy, unless a longer retention period is required or permitted by law (e.g., tax, accounting, legal obligations). Criteria used to determine retention periods include the nature of the data, the purpose for collection, and legal requirements.

10. Your Privacy Rights & Choices

10.1 General Rights

Depending on your location, you may have the right to:

• Access and receive a copy of your Personal Information.
• Correct inaccurate or incomplete information.
• Request deletion of your Personal Information.
• Object to or restrict certain processing activities.
• Data portability (receiving your data in a usable format).
• Withdraw consent (where processing is based on consent).

To exercise these rights, please contact us at: [email protected]. We will respond within the timeframe required by applicable law and verify your identity before processing your request.

10.2 Regional Specific Rights

• 10.2.1 EEA/UK (GDPR/UK GDPR): You have the rights listed in 10.1. You also have the right to lodge a complaint with your local supervisory authority.
• 10.2.2 California (CCPA/CPRA): As a "consumer," you have the rights in 10.1. Additionally, you have the right to:
  • Opt-out of the "sale" or "sharing" of Personal Information (for cross-context behavioral advertising). We do not currently engage in such activities based on our understanding of the terms, but you can contact us to exercise this right.
  • Opt-out of the use of Sensitive Personal Information for inferences or purposes beyond those necessary to provide the goods/services.
  • Limit the use and disclosure of Sensitive Personal Information.
  • Non-discrimination for exercising your rights.
• 10.2.3 Other U.S. States: You may have similar rights under other state laws (e.g., Virginia, Colorado, Utah, Connecticut). Contact us to exercise applicable rights.
• 10.2.4 Singapore (PDPA): You have rights to access and correct your Personal Information. To withdraw consent, please contact us. Note that withdrawal may affect our ability to provide services.
• 10.2.5 Australia/New Zealand (Privacy Act/Privacy Act 2020): You generally have rights to access and correct your Personal Information and complain to the relevant privacy commissioner.

11. Children's Privacy

Our Services are not directed to individuals under the age of 16. We do not knowingly collect Personal Information from children. If we become aware of such collection, we will take steps to delete it.

12. Third-Party Links and Services

Our Services may contain links to third-party websites or services. This Policy does not apply to those third parties. We encourage you to review their privacy policies.

13. Changes to This Policy

We may update this Policy to reflect changes in our practices or legal requirements. We will post the updated Policy on our website and update the "Last Updated" date. Material changes will be notified to you via email or a prominent notice on our website before they become effective, where required by law.

14. Contact Us

If you have questions, concerns, or requests regarding this Policy or our privacy practices, please contact us at:

• Mailing Address: ALPHASTAR TECHNOLOGY (SINGAPORE) PTE. LTD., 91 BENCOOLEN STREET, #12-03, SUNSHINE PLAZA, SINGAPORE 189652
• General Inquiries / Data Subject Requests: [email protected]
• Security Issues: [email protected]

We aim to respond to all requests within the timeframes required by applicable law.