Privacy Policy

Introduction

LEAPMIND GROWTH PTE. LTD. ("Golgent," "we," "us," or "our"), a company incorporated in Singapore, operates the Golgent platform ("Platform")—an AI Agent affiliate marketing platform that connects advertisers and brand owners ("Advertisers") with AI agents, publishers, and developers ("Publishers") to promote products and services to end users ("Consumers") through AI-powered recommendation channels ("Channels").

This Privacy Policy describes how we collect, use, disclose, and protect personal information through:

• Our Platform and related services
• Our website at www.golgent.com and any related subdomains
• Our marketing activities and communications
• Other activities described in this Privacy Policy

(collectively, the "Services")

This Privacy Policy does not apply to information that we process on behalf of our Advertisers or Publishers while providing the Platform to them. Our use of such information is governed by our agreements with them. If you have concerns regarding personal information that we process on behalf of an Advertiser or Publisher, please direct your concerns to them.

Personal Information We Collect

Information You Provide to Us

Account Information: When you create an account on our Platform, we collect information such as your name, email address, phone number, password, and company details.

Business Contact Information: For Advertisers and Publishers, we collect business-related information including company name, business registration details, billing address, payment information, and authorized representative details.

Profile Information: Information you add to your account profile, such as biographical details, profile picture, preferences, and interest areas.

Communications Data: Information from our exchanges with you, including when you contact us through customer support, email, or other channels.

Marketing Data: Your preferences for receiving our marketing communications and details about your engagement with them.

Transaction Data: Information about transactions conducted through our Platform, including campaign details, performance metrics, and payment records.

Information We Collect Automatically

Device Data: Your device's operating system, browser type and version, IP address, unique device identifiers, language settings, screen resolution, and general location information (such as city or country).

Usage Data: Pages or screens you viewed, time spent on pages, navigation paths, access times, and interactions with our Platform features.

Log Data: Server logs that record your activity on our Services, including timestamps, referring URLs, and error reports.

Cookie Data: We use cookies and similar tracking technologies to collect information about your browsing activities. See our Cookie section below for more details.

Information from Third Parties

Social Media Platforms: If you connect your social media accounts, we may receive profile information, follower counts, and engagement metrics as permitted by your privacy settings on those platforms.

Business Partners: We may receive information from marketing partners, data providers, and other third parties to enhance our Services.

Public Sources: We may collect information from publicly available sources to verify business information or for fraud prevention purposes.

How We Use Your Personal Information

We use your personal information for the following purposes:

Service Delivery and Operations

• Provide, operate, maintain, and improve our Platform
• Process transactions and send related information
• Verify Advertiser and Publisher accounts
• Enable the connection between Advertisers and AI Agents/Publishers
• Facilitate campaign management and performance tracking
• Provide customer support and respond to inquiries

Analytics and Improvement

• Analyze usage patterns to improve our Services
• Conduct research and development for new features
• Create aggregated, anonymized data for business insights
• Monitor and analyze trends and user behavior

Marketing and Communications

• Send promotional communications about our Services (with your consent where required)
• Personalize content and recommendations
• Notify you of updates, announcements, and relevant information

Security and Compliance

• Detect, prevent, and address fraud, security breaches, and technical issues
• Comply with applicable laws, regulations, and legal processes
• Enforce our Terms of Service and other agreements
• Protect the rights, property, and safety of Golgent, our users, and the public

How We Share Your Personal Information

We may share your personal information with the following parties:

Affiliates

We may share information with our current and future affiliated companies for purposes consistent with this Privacy Policy.

Service Providers

Third-party vendors that provide services on our behalf, including cloud hosting, payment processing, analytics, customer support, email delivery, and marketing services. These providers are contractually obligated to protect your information and use it only for the services they provide to us.

Platform Participants

• For Advertisers: We may share relevant information with Publishers and AI Agents participating in your campaigns
• For Publishers: We may share relevant information with Advertisers whose campaigns you participate in

Payment Processors

Payment information is collected and processed by our third-party payment processors in accordance with their privacy policies.

Professional Advisors

Lawyers, auditors, accountants, and insurers where necessary for professional services.

Legal and Regulatory Authorities

We may disclose information when required by law, legal process, or government request, or to protect the rights, property, or safety of Golgent, our users, or others.

Business Transfers

In connection with any merger, acquisition, reorganization, sale of assets, or bankruptcy, your information may be transferred to the acquiring entity.

Cookies and Tracking Technologies

We use cookies and similar technologies to:

• Remember your preferences and settings
• Authenticate users and prevent fraud
• Analyze how our Services are used
• Deliver and measure the effectiveness of advertising

Types of Cookies We Use

Your Cookie Choices

You can manage cookies through your browser settings. Most browsers allow you to block or delete cookies. However, blocking certain cookies may impact your ability to use some features of our Services.

Data Retention

We retain personal information for as long as necessary to:

• Provide our Services and fulfill the purposes described in this Privacy Policy
• Comply with legal, accounting, and reporting obligations
• Resolve disputes and enforce our agreements
• Protect against fraudulent or illegal activity

When we no longer need your personal information, we will securely delete or anonymize it. Anonymized data may be retained indefinitely for analytical purposes.

Data Security

We implement appropriate technical and organizational measures to protect personal information against unauthorized access, alteration, disclosure, or destruction. These measures include:

• Encryption of data in transit and at rest
• Access controls and authentication requirements
• Regular security assessments and audits
• Employee training on data protection

However, no method of transmission over the Internet or electronic storage is 100% secure. While we strive to protect your information, we cannot guarantee absolute security.

International Data Transfers

Golgent is headquartered in Singapore. Your personal information may be transferred to and processed in countries other than your own, including Singapore and other jurisdictions where we or our service providers operate.

When we transfer personal information internationally, we implement appropriate safeguards to ensure your information remains protected, including:

• Standard contractual clauses approved by relevant authorities
• Ensuring recipients are in jurisdictions with adequate data protection laws
• Obtaining your consent where required

Your Rights and Choices

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

Access and Portability

You may request access to the personal information we hold about you and receive a copy in a commonly used format.

Correction

You may request that we correct inaccurate or incomplete personal information.

Deletion

You may request that we delete your personal information, subject to certain legal exceptions.

Restriction and Objection

You may request that we restrict processing of your personal information or object to certain processing activities.

Withdraw Consent

Where we rely on your consent, you may withdraw it at any time without affecting the lawfulness of prior processing.

Opt-Out of Marketing

You may opt out of receiving marketing communications by following the unsubscribe instructions in our emails or contacting us directly.

To exercise these rights, please contact us using the information in the "Contact Us" section below. We may need to verify your identity before processing your request.

Children's Privacy

Our Services are not intended for individuals under 18 years of age. We do not knowingly collect personal information from children. If you believe we have collected information from a child, please contact us immediately, and we will take steps to delete such information.

Third-Party Links and Services

Our Services may contain links to third-party websites, applications, or services. We are not responsible for the privacy practices of these third parties. We encourage you to review the privacy policies of any third-party services you access through our Platform.

Changes to This Privacy Policy

We may update this Privacy Policy from time to time. When we make material changes, we will notify you by:

• Posting the updated policy on our website with a new "Last Updated" date
• Sending you an email notification (if you have provided your email address)
• Displaying a prominent notice on our Platform

Your continued use of our Services after any changes indicates your acceptance of the updated Privacy Policy.

Region-Specific Provisions

For Users in the European Economic Area (EEA) and United Kingdom

If you are located in the EEA or UK, the following additional provisions apply:

Legal Bases for Processing: We process your personal information based on one or more of the following legal bases:

• Contract: Processing necessary to perform our contract with you
• Legitimate Interests: Processing necessary for our legitimate business interests, where those interests are not overridden by your rights
• Consent: Where you have given us explicit consent
• Legal Obligation: Processing necessary to comply with applicable laws

Your Additional Rights: Under the GDPR, you have additional rights including the right to lodge a complaint with your local supervisory authority. For EEA residents, contact information for data protection authorities can be found at https://edpb.europa.eu/. For UK residents, visit https://ico.org.uk/.

For Users in Singapore

We comply with the Personal Data Protection Act 2012 (PDPA) of Singapore. You may access and correct your personal data held by us. If you wish to do so, or have any questions about your personal data, please contact our Data Protection Officer using the contact information below.

For Users in California (USA)

Under the California Consumer Privacy Act (CCPA), California residents have additional rights, including the right to know what personal information we collect, the right to delete personal information, and the right to opt out of the "sale" of personal information. We do not sell personal information as defined by the CCPA.

Contact Us

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

LEAPMIND GROWTH PTE. LTD.

Email: privacy@golgent.com

For data protection inquiries in Singapore, you may also contact the Personal Data Protection Commission (PDPC) at https://www.pdpc.gov.sg/.

This Privacy Policy is effective as of February 5, 2026.