Moka Official Website Privacy Policy (International)

Effective Date:[June 4th, 2026]

Version Number:【V2.1】

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 sixteen. We do not seek to collect sensitive personal information through our website, and we ask that you do not submit such information to us unless we specifically request it. Where we do process sensitive personal information, we rely on your explicit consent or another basis permitted by applicable law.

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.
• Proactively contact you after you register an account or submit your contact details, through channels such as telephone, email, and WhatsApp, to follow up on your inquiries, assist with onboarding and your use of our Services, provide service-related updates, and share information about our products and services (where permitted by law and in accordance with your preferences).
• 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. 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:

• Your consent, where we have asked for and you have given it (for example, for certain marketing communications or non-essential cookies); you may withdraw your consent at any time as described in Section 10;
• Our legitimate interests (or those of a third party), where these are not overridden by your interests or fundamental rights and freedoms, for example, to operate, secure, and improve our Services and to carry out direct marketing where permitted by law;
• 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.

Direct marketing and proactive outreach. Where we contact you for direct marketing or other proactive outreach, including telephone calls, emails, and WhatsApp messages following your registration or submission of your contact details, we do so only where we have a lawful basis. If you are in the EEA or UK, we rely on your consent for such communications where consent is required by applicable law (including for electronic mail, SMS, and messaging-app marketing such as WhatsApp, and for unsolicited marketing calls), and otherwise on our legitimate interests in promoting our Services, balanced against your rights and interests. We will obtain your prior consent where the law requires it, and you may withdraw consent or object to direct marketing at any time, free of charge, as described in Section 10. Withdrawing consent does not affect the lawfulness of processing carried out before the withdrawal.

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 Standard Contractual Clauses (SCCs) approved by the European Commission, the UK International Data Transfer Agreement (or Addendum to the EU SCCs), and the corresponding clauses recognised under Swiss law, together with supplementary measures and a transfer risk assessment where required by applicable law. For transfers from other regions, we rely on adequacy decisions or other lawful transfer 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).
• Opt out of, or object to, direct marketing and proactive outreach at any time, including telephone, email, and WhatsApp communications. You can do this by using the unsubscribe link in any marketing email, replying STOP (or as otherwise indicated) to a message, telling us during a call, or contacting us at voc@mokahr.com. We will action your request without undue delay; you may still receive non-promotional, service-related messages necessary to provide the Services.

To exercise these rights, please contact us at: voc@mokahr.com. 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 sell Personal Information for monetary value; however, some of the advertising and analytics technologies described in Section 7 (such as Google Ads and the LinkedIn Insight Tag) may constitute "sharing" under the CCPA/CPRA. You can opt out by managing your choices through our cookie banner or your browser settings, or by contacting us using the details in Section 14.
  • 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: voc@mokahr.com
• Security Issues: security@mokahr.com

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