Privacy Policy

1. Who This Policy Applies To

This Privacy Policy applies to:

• parents, guardians, and other adults who interact with the NDP Trail page; and
• children participating under adult supervision.

2. Types of Data We May Collect

Depending on how you use the NDP Trail page, Zairoo.ai may collect:

• parent or guardian name;
• child name, where submitted;
• contact information such as email address or phone number, where submitted;
• campaign participation and reward-related information, including earned stars and redemption status;
• feedback submitted through the page;
• technical usage information needed to operate the page; and
• personalised certificate and share-card images generated when a parent or guardian chooses the optional photo feature.

3. Why We Collect or Handle the Data

Zairoo.ai may use the above information to:

• operate the NDP Trail page;
• support participation in the online campaign experience;
• generate or customise certificates;
• support campaign star tracking, expiry handling, account-linked redemption, and prize shop access;
• respond to feedback, issues, or follow-up questions;
• improve our campaign page, platform, and related services; and
• comply with legal or internal governance requirements.

4. Child Photo Upload for Certificate and Share Template Feature

The NDP Trail page may allow a parent or guardian to select a child's photo in the browser to generate a personalised certificate and share-card image.

For this page feature:

• the photo is provided voluntarily by the parent or guardian;
• the photo is used only for certificate-generation, certificate customisation, and/or social-share template generation purposes;
• the selected raw photo stays in browser memory and is not uploaded to Zairoo.ai's database or object storage;
• only the two generated PNG outputs are uploaded to private storage and retained for up to 90 days so they can be shared, emailed, resent, or deleted early on request;
• the parent or guardian, or the relevant rights holder, retains ownership of the uploaded photo, while granting Zairoo.ai a limited right to use and process it for this feature; and
• By choosing to use the optional photo-upload feature, the parent or guardian consents to Zairoo.ai collecting, using, and processing the child's photo for the purpose of generating the certificate and/or social-share template.

5. Feedback Data

Zairoo.ai may collect:

• feedback submitted through the page; and
• suggestions about platform improvements, bugs, or desired features.

This information may be used for product, campaign, and operational improvement.

6. Reward Redemption and Account Linking Data

If the NDP Trail page allows a child to earn campaign stars, Zairoo.ai may process information relating to:

• campaign stars earned;
• whether a platform account was created or linked for redemption;
• whether stars were redeemed through the main platform prize shop; and
• whether unredeemed stars expired at the end of the campaign.

This information may be used to operate the campaign, enforce reward and expiry rules, and support prize shop redemption through Zairoo.ai's main platform.

7. Consent and PDPA Position

Zairoo.ai collects, uses, and discloses personal data for the NDP Trail page for the purposes described in this Privacy Policy, including operating the campaign page, generating certificate and share-template outputs, administering campaign stars and redemption, responding to feedback, improving related services, and meeting legal or compliance requirements.

Where required under the Personal Data Protection Act 2012 of Singapore and other applicable laws, Zairoo.ai will rely on consent or another basis permitted by law. Where child-related content is involved, Zairoo.ai expects the parent, guardian, or other authorised adult to make the relevant submission or to authorise it.

8. Data Sharing

Zairoo.ai may share relevant information only where necessary with:

• service providers or vendors supporting the NDP Trail page or campaign operations;
• internal team members who need the data for support, follow-up, or compliance; and
• authorities or other parties where required by law or legal process.

Zairoo.ai does not sell personal data collected through the NDP Trail page.

9. Data Retention

Zairoo.ai retains personal data only for as long as reasonably necessary for the purposes described in this Privacy Policy, including page administration, follow-up, legal compliance, and record-keeping.

Generated personalised certificate and share-card PNGs are kept in private storage for no more than 90 days from generation and may be deleted earlier on request. The selected raw child photo is not retained by Zairoo.ai.

Unless a longer retention period is required or permitted by law, other personal data collected for the NDP Trail page is retained only for the duration of the campaign and related follow-up period, with deletion or anonymisation targeted by 15 September 2026.

10. Transfers to Service Providers

Where Zairoo.ai uses service providers or systems that process personal data for the NDP Trail page, including providers located outside Singapore, Zairoo.ai will take reasonable steps to ensure that the personal data transferred receives a standard of protection comparable to that required under Singapore law.

11. Security

Zairoo.ai takes reasonable security arrangements to protect personal data in its possession or under its control in order to prevent unauthorised access, collection, use, disclosure, copying, modification, disposal, or similar risks.

However, no transmission or storage method can be guaranteed to be completely secure.

12. Access, Correction, and Withdrawal

Subject to applicable law and any relevant exceptions, a parent or guardian may contact Zairoo.ai to:

• request access to personal data submitted through the NDP Trail page;
• request correction of submitted personal data;
• withdraw consent for ongoing collection, use, or disclosure of personal data that was provided on an optional basis; or
• ask questions about how personal data for the NDP Trail page is handled.

Withdrawal of consent does not affect handling that was already carried out before the withdrawal, and may affect Zairoo.ai's ability to continue providing the relevant feature or campaign function.

13. Cross-Reference to Main Website Privacy Position

This NDP Trail page Privacy Policy should be read together with the broader privacy practices communicated on the Zairoo.ai website, where applicable. If there is any inconsistency, the more specific NDP Trail page wording should govern for this page feature.

14. Updates and Latest Version of This Privacy Policy

Zairoo.ai may update this Privacy Policy from time to time. The latest page-specific version made available on the NDP Trail page will apply from the stated effective date.

15. Contact

If you have questions about privacy handling for the NDP Trail page, please contact Zairoo.ai through the contact channel stated on the Zairoo.ai website.