Last updated at 15th Feb 2023

Thank you for choosing to be part of our community at Pombeebee AI-based study buddy by Blubberbee Pte Ltd. (“Company,” “we,” “us,” or “our”). We are committed to protecting your personal information and your right to privacy.

This Privacy Policy explains:

1. The type of personal information about you which is processed by Pombeebee when you use the Pombeebee Services.

2. How Pombeebee processes the personal information about you when you use the Pombeebee Services.

3. The purposes for which Pombeebee collects and processes your personal information;

4. Your right to access and correct your personal information;

5. The class of third parties to which Pombeebee may disclose your personal information;

6. Whether it is obligatory or voluntarily for you to supply the personal information and the consequences of failing to provide your personal information when it is obligatory

7. How Pombeebee safeguards the confidentiality and security of your personal information.

8. Any changes will be notified to you via the e-mail address provided by you on registration or via a suitable announcement on the Pombeebee. If we make any material changes we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on this Site prior to the change becoming effective. If you do not wish to accept the new Terms you should not continue to use the Pombeebee Services. If you continue to use the Pombeebee Services after the date on which the changes come into effect, your use of the Pombeebee Services indicates your agreement to be bound by the new Terms.


1. When you register for the Pombeebee Services Each time when you register with Pombeebee for any of the Pombeebee Services, you will be asked to provide certain personal information about yourself in order to create a Pombeebee account. Whenever the personal information requested by Pombeebee is marked as “Required Field”, you must provide and agree to the processing of this personal information by Pombeebee. If you do not agree to provide this personal information and/or do not agree us to process it in the manner set out in this Privacy Notice, then Pombeebee will be unable to provide the relevant services to you and your application for such services will be rejected.

2. From your use of the Pombeebee Services and/or the Pombeebee Application

a. We collect personal information directly from you when you choose to engage any of the Pombeebee Services and/or to use the Pombeebee Application. The following are examples of personal information Pombeebee may collect directly from our candidates:

i, Name;

ii, Date of birth;

iii, Gender;

iv, Location;

v, Profile Picture;

vi, Email address;

vi, Information preferences

b. If you wish to stop Pombeebee from processing this type of personal information about you, Pombeebee will no longer be able to provide the relevant services to you.

c. When you visit the Pombeebee Application:

i, When you visit any Pombeebee Application, our web servers automatically collect information about your visit to these Application, including your UIUD (universally unique identifier) which is a calculated string that is used to identify a device for the purposes of app installation, registration, and MDM enrollment.

ii, Cookies allow Pombeebee to save preferences for you so that you will not have to re-enter them the next time you visit. Cookies also help Pombeebee collect anonymous clickstream data for tracking user trends and patterns.

iii, You can remove cookies by following directions provided in your internet browser’s “help” file. You should understand that areas of certain applications will not function properly if you set your internet browser to not accept cookies. Our partners and service providers use cookies to collect information about the usage of Pombeebee Application. The use of cookies by our partners and service providers is not covered by our privacy policy. We do not have access or control over these cookies.


1. The purposes for which Pombeebee processes your personal information are as follows:

a. To verify your identity;

b. To provide the Pombeebee Services which you have requested;

c. To administer and manage the Pombeebee Services provided to you;

d. To contact you in respect of Pombeebee Services;

e. To contact the referee and/or the guarantor whom details have been provided by you;

f. To process your order for the Pombeebee Services which you have requested;

g. To investigate and resolve any of the Pombeebee Services, billing queries, complaints or other enquiries that you submit to Pombeebee regarding Pombeebee Services;

h. To monitor and improve the performance of the Pombeebee Application and the Pombeebee Services;

i. To maintain and develop the Pombeebee Application and Pombeebee Services;

j. To assist Pombeebee in understanding your browsing preferences on the Pombeebee Application so that Pombeebee can tailor content accordingly;

k. To detect and prevent fraudulent activity.

l. To post testimonials: posted testimonials on our App that may contain personal information.

m. To enable user-to-user communications: we may use your information in order to enable user-to-user communications with each user’s consent.

n. To send you marketing and promotional communications

2. If you do not consent to Pombeebee processing your personal information for the said purposes, you must terminate your relevant agreement with Pombeebee for the Pombeebee Services and stop using the Pombeebee Application.

3. In addition, Pombeebee may use your personal information to promote and market to you:

a. Other Pombeebee Services;

b. Services of third parties which Pombeebee thinks may be of interest of you;

4. Pombeebee will ask for your consent before processing your personal information other than those mentioned in clause I “ Collection of Personal Information”.


Pombeebee gives you the option of putting your Pombeebee Profile in the Pombeebee Information Preferences Database provided that you use Pombeebee’s preset format for uploading your information. There are two ways of doing so:

a. Pombeebee uses its best effort to restrict access to the Pombeebee Information Preferences Database only to those who have subscribed to the Pombeebee Services, these parties may retain a copy of your Pombeebee Profile in their own files or databases.

b. Pombeebee will take reasonable steps to ensure that parties other than those mentioned above will not, without Pombeebee’s consent, gain access to the Blubberbee Information Preferences Database. However, Pombeebee is not responsible for the retention, use or privacy of Pombeebee Profile by any third parties


You may have different privacy concerns. Pombeebee’s goal is to be clear of what information it collects, so that you can make meaningful choices about how it is used. For example:

1. You can control who you share your personal information with;

2. You can review and control your subscription to various marketing preferences, Pombeebee Services;

3. You may view, edit or delete your personal information and preferences at any time;

4. You may choose not to receive any marketing materials from Pombeebee;

5. You may also subscribe to additional Pombeebee Services by logging into a Blubberbee account;

6. You can delete your Pombeebee account at any time in which event Pombeebee will remove all access to your account and Pombeebee Profile in the database. The deletion of your Pombeebee account does not affect Pombeebee Profile that you had already provided.


Pombeebee will retain your personal information for the period necessary to fulfil mentioned purposes and any legal or business purposes.


1. Pombeebee is committed to keeping personal information secure. Pombeebee has appropriate technical, administrative and physical procedures in place to protect personal information from loss, theft and misuse, as well as against unauthorized access, disclosure, alteration and destruction. Sensitive information (such as a credit card number, Momo account, Zalopay account) entered on our payment gateway services are encrypted during the transmission of that information using secure socket layer technology (SSL).

2. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security. If you have any questions about security on our Application, you can contact us at the contact provided below;


1. Personal information mentioned in Clause I above may be disclosed to the classes of third parties as follows in order for Pombeebee to effectively manage its business including to render the Pombeebee Services to you to achieve the purposes in Clause II

a. Third parties contracted by Pombeebee to assist Pombeebee in delivering all or part of the Pombeebee Services to you, including without limitation, to the following:

i. Payment gateway services for optional services;

ii. Data storage, analytics and cloud services;

b. Regulatory bodies, governmental bodies or other authorities if required or authorized to do so to discharge any regulatory function, under any law or in relation to any order or judgment of a court;

c. Regulatory bodies, governmental bodies or other authorities for the purpose of detection or prevention of crime, illegal/unlawful activities or fraud or for the apprehension or prosecution of offenders, or for an investigation relating to any of these;

d. Any party involved in or related to a legal proceeding (or prospective legal proceeding), for purposes of the legal proceedings;

e. Pombeebee’s professional advisors on a need to know basis for the purpose of those advisors providing advice to Pombeebee;

f. Any third party which acquires all or part of the assets or business of Pombeebee (including accounts and trade receivables) for the purpose of that third party continuing to provide all or that part of the Pombeebee Services which it acquired;

g. Otherwise permitted under any data protection legislation.

2. Other than set out above, you will receive notice when personal information about you might go to third parties, and you will have an opportunity to choose not to share the information.

3. Pombeebee does not sell or rent any personal information collected to any other parties.


1. You are responsible for providing accurate, not misleading, complete and up-to-date information to Pombeebee about yourself and any other person whose personal information you provide us and for updating this personal information as and when it becomes inaccurate, misleading, incomplete and out-of-date by contacting Pombeebee via provided contact information below.

2. In the circumstances you may need to provide to Pombeebee personal information about someone other than yourself (for example, your referee or guarantor). If so, we rely on you to inform these individuals that you are providing their personal information to Pombeebee, to make sure they consent to you giving us their information and to advise them about where they can find a copy of this Privacy Policy.


It may be necessary for Pombeebee to transfer your Personal Information outside of your local jurisdiction if any of Pombeebee service providers or strategic partners (“overseas entities”) is involved in providing part of the Pombeebee Services.

In view of you providing your consent to Pombeebee to transfer Personal Information outside of local jurisdiction (Vietnam), we hereby undertake that:

1. We shall only transfer your Personal Information outside of your local jurisdiction strictly for the purpose of, and only to the extent necessary for, fulfilling our obligations, and providing the Services, under this Policy;

2. We shall protect any and all your personal information transferred outside of your local jurisdiction at a standard comparable to the standards required under the Personal Data Protection Act 2012 of Singapore and, without prejudice to the generality of the foregoing, we shall make reasonable Security arrangements (including, where appropriate, physical, administrative, procedural and information & communications technology measures) acceptable to our assistant to prevent

a. the unauthorized or accidental access, collection, use, disclosure, copying, modification, disposalor destruction of such 3. Personal Information, or other similar risks, and

b. the loss of any storage medium or device on which such Personal Information is stored; In the event we transfer Personal Information to any third party outside your local jurisdiction, we shall procure that such third party provide to our assistants written undertakings substantially similar to the undertakings set forth herein before we transfer Personal Data to such third party; and

4. We shall indemnify our employees, against any and all actions, claims, demands, liabilities, losses, damages, statutory penalties, expenses and costs (including legal costs on an indemnity basis) arising or resulting from or in relation to or in connection with

a. the unauthorized or accidental access, collection, use, disclosure, copying, modification, disposal or destruction of Personal Information,

b. the loss of any storage medium or device on which Personal Information is stored, and

c. breaches of the undertaking set forth herein or the undertakings of third parties to whom we have transferred your Personal Information.


In using the Pombeebee Services, you consent to the collections and use of the personal information by Pombeebee in the ways described hereinabove (which may change from time to time) unless and until you inform Pombeebee to the contrary.


We may update this privacy policy from time to time. The updated version will be effective as soon as it is accessible. If we make material changes to this privacy policy, we may notify you either by prominently posting on our site of such changes or by directly sending you a notification via the primary email you have used to sign up Pombeebee account. We encourage you to review this privacy policy frequently to be informed of how we are protecting your information.


If you still have questions about this Privacy Policy, please contact Pombeebee Officer at Pombeebee requests your name, phone number, email address so that Pombeebee may respond to your concerns effectively and work to improve the Pombeebee Services and/or Pombeebee Application