Privacy Policy 

Effective Date: 7^th April 2019

Last Updated: 18^th October 2025

1. Introduction

Avernixx Pte. Ltd. (“Avernixx,” “we,” “us,” or “our”) respects your privacy and is committed to protecting personal data collected through our websites, including www.avernixx.com and www.whalecrunch.com (collectively, the “Websites”).

This Privacy Policy explains how we collect, use, disclose, and safeguard your personal information in accordance with applicable privacy laws, including but not limited to:

• Singapore PDPA
• EU GDPR
• UK GDPR & Data Protection Act 2018
• Australian Privacy Act 1988
• Relevant US state privacy laws (e.g., CCPA/CPRA)

By accessing or using our Websites or services, you consent to the practices described in this Privacy Policy.

2. Personal Data We Collect

We may collect personal information from you when you:

• Register an account or profile on the Websites
• Use our AI Marketplace (www.whalecrunch.com) or other services
• Subscribe to newsletters or communications
• Contact us via forms, email, or other channels
• Participate in surveys, promotions, or events

Types of personal data we may collect include:

• Identity information: Name, username, date of birth
• Contact information: Email, phone number, mailing address
• Account credentials: Login credentials and authentication data
• Payment information: Billing details for subscriptions or services
• Usage data: IP address, device information, browser type, browsing behavior, and analytics
• Communications: Messages sent to or received from us

3. How We Use Personal Data

We use personal data for purposes including:

• Providing, maintaining, and improving our services and Websites
• Verifying accounts, managing subscriptions, and processing payments
• Sending relevant communications and marketing updates (with your consent where required)
• Ensuring compliance with legal obligations
• Conducting analytics, research, and security monitoring
• Resolving disputes, enforcing Terms of Use, or protecting legal rights

4. Data Processing Responsibilities

Avernixx acts as a Data Controller when collecting and processing personal data related to clients and registered users. We are responsible for managing your data in compliance with applicable data protection laws.

Note for WhaleCrunch AI Marketplace users: When you share personal information with freelancers or third-party users, Avernixx cannot control how such information is used and shall not bear vicarious liability for any misuse. Accordingly, personal data processing agreements do not apply to Avernixx in these contexts.

5. Legal Basis for Processing

Where applicable, we process personal data on one or more of the following lawful bases:

• Performance of a contract with you
• Compliance with legal obligations
• Legitimate interests pursued by Avernixx (e.g., improving services, fraud prevention)
• Consent provided by you

6. Disclosure of Personal Data

We may share personal data with:

• Service providers, technology partners, and contractors necessary to provide our services
• Regulators, authorities, or law enforcement when required by law
• Affiliates or subsidiaries for internal business purposes

We do not sell personal data to third parties.

7. International Data Transfers

Avernixx may store, process, or transmit your personal data in countries outside Singapore, including the United States, as part of providing our services. This may include the use of cloud, email, or other service providers located in jurisdictions outside your home country.

We take appropriate safeguards to ensure that any international transfers of personal data comply with applicable data protection laws, including:

• Utilizing internationally recognized service providers that implement robust security measures and privacy compliance standards;
• Applying contractual, organizational, or technical safeguards where required, in line with GDPR, UK GDPR, PDPA, and other relevant laws;
• Limiting cross-border access to personal data only to authorized personnel for legitimate business purposes.

By using our Websites or services, you acknowledge and consent to such international transfers and processing of your personal data in accordance with this Privacy Policy.

8. Data Retention

Avernixx retains personal data only for as long as necessary to fulfill the purposes outlined in this Privacy Policy, comply with legal obligations, resolve disputes, enforce agreements, and protect our rights.

In general, personal data will be retained for no longer than seven (7) years after the last interaction, unless a longer retention period is required by law or regulation.

9. Your Rights

Depending on your location, you may have the following rights:

GDPR/UK GDPR: Access, correction, deletion, restriction of processing, objection to processing, data portability, and withdrawal of consent.

CCPA/CPRA (US residents): Right to know, right to delete, right to opt-out of sale of personal information, and right to non-discrimination.

Australian Privacy Act: Access, correction, and complaint rights.

To exercise your rights, please contact us using the information in clause 15.

10. Security Measures

We implement reasonable technical, administrative, and physical safeguards to protect personal data from unauthorized access, loss, misuse, or alteration.

However, no system is completely secure. You acknowledge and accept that Avernixx cannot guarantee absolute security of personal data transmitted through the Websites.

11. Cookies and Tracking Technologies

Our Websites may use cookies and similar technologies to enhance user experience, analyze traffic, and deliver personalized content.

You may manage or disable cookies through your browser settings. Disabling cookies may affect certain functionalities of the Websites.

12. Children’s Privacy

The Websites are not directed to children under the minimum age for consent to data processing in their jurisdiction, including but not limited to:

• 13 years old (UK, Australia, USA)
• 16 years old (EU, unless a lower age applies under local law)

Or the applicable minimum age in your jurisdiction. We do not knowingly collect personal data from children below these ages. If we become aware that we have collected data from a child without parental consent, we will take steps to delete it.

13. Third-Party Links and Services

The Websites may contain links to third-party websites, applications, or services. Avernixx is not responsible for the privacy practices or content of such third parties. Your interactions with these third parties are at your own risk.

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in law, technology, or our services. Updates will be posted on this page with the “Last Updated” date revised accordingly.

Your continued use of the Websites after such updates constitutes acceptance of the updated Privacy Policy.

15. Contact Information

If you have any questions, concerns, or complaints regarding this Privacy Policy or your personal data, please contact:

Avernixx Pte. Ltd. (Singapore)
60 Paya Lebar Road
#06-28 Paya Lebar Square
Singapore 409051
Website: www.avernixx.com
Email: legal@avernixx.com