1. Who We Are
This Privacy Policy explains how RECIPROCATE TECHNOLOGIES PTE LTD (UEN: 202604313E) (“we”, “us”, “our”) collects, uses, shares, and protects your personal information when you use our waitlist page at https://getreciprocate.app (the “Service”).
We are incorporated in Singapore and operate globally. Our registered address is:
By accessing or using the Service, you agree to this Privacy Policy. If you do not agree, please do not use the Service.
2. What This Policy Covers
This policy covers the waitlist phase of the RECIPROCATE platform at https://getreciprocate.app. It does not cover the full RECIPROCATE platform, which will have its own updated Privacy Policy published before launch.
This policy will be updated when the full platform launches. We will notify you of material changes by email at least 14 days before they take effect.
3. Information We Collect
When you join our waitlist, we collect:
- Name — first name, last name, or full name
- Email address
- IP address
- Referral source and referral code — how you found the waitlist and any referral links you use or share
- Device and browser information — browser type, operating system, device type
- Geographic location — derived from your IP address (city, region, country)
- Email engagement data — whether you open or click links in emails we send you
- Signup timestamp — the date and time you joined the waitlist
- Custom form field responses — any additional information you voluntarily provide
We also collect certain information automatically through cookies and similar technologies. Please refer to our Cookie Policy, managed via the CookieYes consent banner on the Service, for full details.
4. How We Use Your Information
We use the information we collect about you for the following purposes:
- Waitlist management — to register and manage your place on the waitlist, track your position, and administer our referral program
- Communications — to send you updates about our launch, product news, and waitlist status, where you have consented to receive them
- Customer support — to respond to your queries, feedback, and support requests
- Security and fraud prevention — to protect the Service against bots, fake signups, and abuse, including through Cloudflare Turnstile CAPTCHA verification
- Analytics and improvement — to understand how visitors use the Service so we can improve it, using Google Analytics and Cloudflare analytics
- Legal compliance — to comply with our obligations under applicable law, including data protection, online safety, and anti-fraud legislation
- Testimonials — where you have provided a testimonial or review and consented to its use
We will not use your information for any other purpose without first asking for your consent. If we request consent and you decline, we will not use your data for that purpose, and this will not affect your access to the waitlist.
5. Lawful Basis for Processing
Applicable data protection laws in many jurisdictions require us to identify a lawful basis for processing your personal data. Our lawful bases are as follows, with reference to the GDPR and UK GDPR where applicable, and equivalent provisions under other applicable laws:
5.1 Consent
We rely on your consent for:
- Marketing and promotional communications (including launch updates and newsletters)
- Analytics and non-essential cookies
- Any processing not strictly necessary to operate the waitlist
Under the GDPR and UK GDPR (Article 7 and Recital 42), and equivalent provisions in other applicable laws, your consent is freely given, specific, informed, and unambiguous. We will never make your use of the Service conditional on consenting to optional processing. To ensure the quality of consent, we require email verification (double opt-in) before activating your waitlist place and granting access to the leaderboard and referral features.
How to withdraw consent: You may withdraw your consent at any time using any of the following methods:
- Email: Send a withdrawal request to dataprotection@reciprocate.app
- Unsubscribe link: Click the unsubscribe link in any marketing email we send you
- Cookie preferences: Update your cookie consent choices at any time via the CookieYes banner on the Service
We will process your withdrawal request within 30 days of receipt, and within 10 business days where operationally possible. Withdrawing consent does not affect the lawfulness of any processing we carried out before you withdrew it. It also does not affect processing carried out on other lawful bases.
5.2 Legitimate Interests
We rely on our legitimate interests for:
- Security, fraud prevention, and bot protection
- Privacy-preserving analytics — Cloudflare’s analytics tool processes only anonymized, aggregated data (no cookies, no cross-site tracking, no personal identifiers). We rely on legitimate interests for this processing because it does not materially affect your rights or freedoms
- Ensuring the integrity of the waitlist
We have carried out a legitimate interests assessment and are satisfied that our interests are not overridden by your rights and freedoms in these contexts. You have the right to object to processing carried out on this basis (see Section 12).
Note on Google Analytics: Google Analytics is loaded via Google Tag Manager and processes IP addresses and behavioral data. This tool is classified as non-essential and is only activated where you have given consent via the CookieYes banner. It is not relied upon under legitimate interests.
5.3 Legal Obligation
We process personal data where required to comply with applicable law, including data protection legislation, online safety obligations, and regulatory requirements.
5.4 Applicability to Non-EEA/UK Users
If you are located outside the EEA or UK, equivalent legal bases under your applicable local law govern our processing. For Singapore residents, our processing is conducted in accordance with the purposes and consent framework of the Personal Data Protection Act 2012 (PDPA). For other jurisdictions, we process data in accordance with applicable local law.
6. Referral Program & Leaderboard
When you join the waitlist, you are automatically assigned a unique personal referral link (for example: https://getRECIPROCATE.app?ref=your-unique-code). This section explains how your data is used in connection with the referral program and the Early Access Leaderboard.
6.1 Your Referral Link
Your unique referral link is tied to your waitlist account. You may share it via any channel you choose, including via the sharing shortcuts provided on the thank-you page (X, Facebook, Instagram, LinkedIn, WhatsApp, Telegram, and Email). Each time someone joins the waitlist using your referral link, this is recorded and attributed to your account.
6.2 Points and Tracking
Each successful referral — meaning a person who joins the waitlist using your unique referral link and completes double opt-in email verification — earns you points. These points determine your position on the Early Access Leaderboard and your priority for early access to the RECIPROCATE platform.
The following data is tracked and processed as part of the referral program:
- Your referral code and the number of successful referrals attributed to you
- The referral code used by each person who signs up, linking their signup to the referrer’s account
- Points accrued per account, updated in real time
- Leaderboard position and ranking relative to other waitlist members
6.3 Leaderboard Display & Redacted Email Visibility
The Early Access Leaderboard is visible to all verified, double opt-in confirmed waitlist members. It is accessible via the thank-you page, which is reached after successful email verification, and via the “Check My Status” feature on the waitlist page.
The leaderboard displays the following information for each listed member:
- Leaderboard position (e.g. #1, #2, #3)
- Redacted email address — displayed in the format i*****@m*****.com (first character of the local part and first character of the domain are visible; all other characters are masked)
- Points total
Your own entry is highlighted as “You” rather than displaying your redacted email to yourself. However, your redacted email address is visible to other verified waitlist members on the leaderboard.
Important: Although your email address is partially masked, the visible characters constitute personal data under applicable data protection law. By joining the waitlist and participating in the referral program, you acknowledge and consent to this limited display of your redacted email address to other verified waitlist members.
If you do not wish your redacted email address to appear on the leaderboard, you may request removal by contacting us at dataprotection@reciprocate.app. Please note that opting out of leaderboard display will not affect your waitlist position or referral tracking.
6.4 Referral Relationship Data
Where you signed up via another person’s referral link, a data relationship is created between your account and the referrer’s account. Specifically, your signup action is recorded as a successful referral attributed to the referrer. The referrer does not have access to your full email address or any personal details beyond the fact that a referral was successfully completed.
6.5 Lawful Basis for Referral Processing
The referral program and leaderboard processing is carried out on the basis of your consent, given at the point of signup. Participation in the referral program is voluntary. You may withdraw from leaderboard display at any time by contacting dataprotection@reciprocate.app.
7. How We Share Your Information
7.1 We Do Not Sell Your Data
We do not sell, rent, or trade your personal information to any third party. We do not share your personal information with advertisers or any third parties for their own marketing purposes. Your data is used solely to operate and improve the Service and to fulfill the purposes described in this policy.
7.2 Sharing with Service Providers
We share your personal information with trusted third-party service providers who assist us in operating the Service. These providers are listed in Section 8. Each provider is:
- Bound by a Data Processing Agreement or equivalent contractual safeguard
- Permitted to process your data only as instructed by us and only for the purposes set out in this policy
- Required not to retain your data for longer than necessary to fulfill their designated purpose
- Selected with reasonable care, with preference given to vendors who have established, publicly available Data Processing Agreements and who are, to the best of our knowledge, compliant with applicable data protection law
Please note that individual subprocessor agreements may be governed by the laws of the subprocessor’s jurisdiction rather than Singapore law. We remain responsible to you as data controller under applicable law regardless of the governing law of any subprocessor agreement, and we will seek to ensure our subprocessors fulfill their obligations to us in a manner consistent with your rights under this policy.
7.3 Sharing for Legal Reasons
We may disclose your personal information to third parties where required or permitted by applicable law, including:
- To comply with a legal obligation, court order, or lawful request from a government or regulatory authority
- To enforce our Terms and Conditions or other agreements
- To protect the rights, property, or safety of RECIPROCATE TECHNOLOGIES PTE LTD, our users, or the public
- To hosting, technology, and communications providers where access is strictly necessary for service delivery
- To security and fraud prevention consultants engaged to protect the integrity of the Service
Where permitted by law, we will notify you before disclosing your data in response to a legal request.
7.4 Business Transfers
All personal data we collect may be transferred to a third party in the event that we undergo a merger, acquisition, bankruptcy, asset sale, or other transaction in which that third party assumes control of our business (in whole or in part).
Should one of these events occur, we will make reasonable efforts to notify you before your information becomes subject to different privacy and security policies and practices, and we will provide you with an opportunity to request deletion of your data prior to the transfer taking effect where this is reasonably practicable.
7.5 Subprocessor Changes
Our list of subprocessors may change from time to time as we add, replace, or remove third-party providers. We will update this Privacy Policy to reflect any material changes to our subprocessor list and will notify you of such changes in accordance with Section 19. We take reasonable care to select vendors who have established Data Processing Agreements and are, to the best of our knowledge, compliant with applicable data protection law.
8. Third-Party Services & Subprocessors
We use the following third-party providers to operate the Service. Each processes your personal data only as instructed and under a Data Processing Agreement or equivalent contractual safeguard.
8.1 Waitlister.me
Our waitlist platform. Handles signup collection, referral tracking, leaderboards, and waitlist analytics.
Provider: Waitlister (259 Cleveland Street, Redfern, Sydney, NSW 2016, Australia)
Data processed: Name, email, IP address, referral data, device/browser info, geographic location, signup timestamps
Data location: United States (via Firebase/Google LLC)
Safeguards: Data Processing Agreement (Waitlister DPA PDF); EU Standard Contractual Clauses via Google’s DPA
8.2 Google LLC (Firebase)
Waitlister’s cloud infrastructure provider. Stores and processes waitlist data on Waitlister’s behalf.
Data location: United States (primary), with multi-region processing
Safeguards: Standard Contractual Clauses — cloud.google.com/terms/data-processing-terms
8.3 Resend Inc.
Transactional email provider used by Waitlister to send confirmation and notification emails.
Data location: United States
Safeguards: Data Processing Addendum including Standard Contractual Clauses — resend.com/legal/dpa
8.4 MailerLite
Our email marketing platform, used to send launch updates and communications to subscribers who have consented to receive them.
Data location: European Union
Safeguards: GDPR-compliant DPA — mailerlite.com/legal/data-processing-agreement
8.5 Make.com (Celonis SE)
Automation platform that routes waitlist signup data from Waitlister into MailerLite.
Data location: European Union (Czech Republic)
Safeguards: GDPR-compliant DPA — make.com/en/dpa
8.6 CookieYes
Our consent management platform, which records and manages your cookie consent preferences and maintains our compliance audit trail.
Data location: European Union
Safeguards: GDPR-compliant DPA — cookieyes.com/data-processing-addendum
8.7 Cloudflare Inc.
Our DNS, CDN, and security provider. Processes IP addresses and request metadata for DDoS protection, CAPTCHA verification (Turnstile), and analytics.
Data location: United States and global edge network
Safeguards: Standard Contractual Clauses — cloudflare.com/cloudflare-customer-dpa
8.8 Google Analytics / Google Tag Manager
We use Google Analytics (loaded via Google Tag Manager) to understand how visitors interact with the Service. This processes IP addresses and behavioral data.
Data location: United States
Safeguards: Standard Contractual Clauses via Google’s Data Processing Terms
Opt-out: tools.google.com/dlpage/gaoptout
8.9 Google Ads / DoubleClick (Waitlister-controlled integration)
A Google Ads / DoubleClick tracking pixel is present on this Service as part of Waitlister’s platform. This pixel is not directly controlled by RECIPROCATE TECHNOLOGIES PTE LTD.
Compliance status — resolved, monitoring: During our proactive compliance review, we identified that this pixel was not respecting consent selections. We raised a formal compliance concern with Waitlister.me and, working together with Waitlister’s founder, the issue has been remediated — the cookie is now behaving as expected and firing only in accordance with consent preferences. We are monitoring this on an ongoing basis to ensure the fix remains stable. You can manage your Google Ads preferences at adssettings.google.com at any time.
Provider: Google LLC • Data location: United States • Safeguards: Google’s Ads Data Processing Terms apply • Opt-out: adssettings.google.com
9. International Data Transfers
We are incorporated in Singapore and our service providers are primarily based in the United States and European Union. When your personal data is transferred outside your country of residence — including outside the European Economic Area (EEA) or United Kingdom — we ensure appropriate safeguards are in place, including:
- Standard Contractual Clauses (SCCs) — approved transfer mechanisms used for transfers to US-based providers, including those approved under GDPR Article 46 and equivalent provisions under other applicable laws
- Adequacy decisions — where a relevant authority has determined the destination country provides adequate protection
- Binding Corporate Rules — where applicable
Details of the safeguards applicable to each of our subprocessors are set out in Section 8 above.
10. US Cloud Act Disclosure
Some of our subprocessors (including Firebase/Google LLC and Cloudflare Inc.) are US-based companies subject to the US CLOUD Act (Clarifying Lawful Overseas Use of Data Act, 2018). This means that US law enforcement authorities may, under certain circumstances, compel these providers to disclose data stored on their infrastructure, including data belonging to non-US persons, without necessarily notifying the data subject or the data controller.
We are transparent about this risk. Where permitted by law, we will notify you if we receive such a request affecting your data. We will take reasonable steps to challenge requests we believe to be overbroad, unlawful, or disproportionate.
If this disclosure is a concern to you, you may request deletion of your data at any time by contacting us at dataprotection@reciprocate.app.
11. How Long We Keep Your Information
We retain your personal information for as long as necessary to fulfill the purpose for which it was collected, or until you request erasure. Specifically:
- Waitlist data — retained until platform launch or until you request deletion, whichever comes first
- Referral and leaderboard data — retained for the duration of the waitlist phase and for a reasonable period after launch for audit and dispute resolution purposes
- Email engagement data — retained for up to 12 months after the last interaction
- Security and fraud prevention logs — retained for up to 12 months
- Consent records (CookieYes) — retained for the duration of our legal obligation to demonstrate compliance, typically up to 3 years
- Legal and compliance records — retained for as long as required by applicable law
Anonymized or aggregated data that cannot identify you may be retained indefinitely for analytical purposes. Upon expiry of the applicable retention period, data will be securely deleted or irreversibly anonymized.
12. Your Rights
Depending on where you are located, you have the following rights in relation to your personal data. We will respond to all requests within the timeframe required by applicable law in your jurisdiction, and in any event within 30 days of receipt.
12.1 Rights Available to All Users
- Right to access — you may request a copy of the personal data we hold about you
- Right to rectification — you may ask us to correct inaccurate or incomplete data. Please note that in certain circumstances, where we determine based on the totality of available information that your data is accurate, we may decline a correction request and will explain our reasons for doing so
- Right to erasure — you may ask us to delete your personal data where we have no legitimate reason to continue processing it
- Right to withdraw consent — you may withdraw consent at any time via email to dataprotection@reciprocate.app, via the unsubscribe link in any email, or via the CookieYes banner on the Service (see Section 5.1 for full details)
- Right to opt out of direct marketing — you may opt out at any time via the unsubscribe link in any marketing email or by contacting us directly
12.2 EEA and UK Users (GDPR / UK GDPR)
In addition to the above, EEA and UK residents have the following rights under the GDPR and UK GDPR:
- Right to data portability (GDPR Article 20) — you may request your data in a structured, commonly used, machine-readable format
- Right to restrict processing (GDPR Article 18) — you may ask us to pause processing of your data in certain circumstances
- Right to object (GDPR Article 21) — you may object to processing based on legitimate interests at any time. We will cease such processing unless we can demonstrate compelling legitimate grounds that override your interests
- Right not to be subject to automated decision-making (GDPR Article 22) — we do not make automated decisions that produce legal or similarly significant effects on you
- Right to lodge a complaint — you may complain to your national supervisory authority (see Section 13)
12.3 Singapore Users (PDPA)
Singapore residents have the following rights under the Personal Data Protection Act 2012 (PDPA) and its 2020 amendments:
- Right of access — to request access to your personal data and information about how it has been used or disclosed in the past year
- Right of correction — to request correction of your personal data that is inaccurate, incomplete, misleading, or not up to date
- Right to withdraw consent — subject to legal or contractual restrictions and reasonable notice. Note that withdrawal may affect our ability to continue providing the Service to you
- Right to data portability — under the PDPA 2020 amendments, you may request that your data be transmitted to another organization in a structured, machine-readable format
12.4 California Users (CCPA — Courtesy Reference)
Although RECIPROCATE TECHNOLOGIES PTE LTD does not currently meet the thresholds that make the California Consumer Privacy Act (CCPA) strictly applicable, we voluntarily extend the following rights to California residents:
- Right to know what personal information we collect, use, disclose, and sell
- Right to correct — you may request correction of inaccurate personal information. Please note that under the CCPA, this right is subject to certain exceptions: for example, if we determine based on the totality of circumstances related to your personal data that such data is correct, we may decline your request and will explain our reasons
- Right to delete your personal information (subject to certain exceptions)
- Right to opt out of the sale of personal information — we do not sell personal information
- Right to non-discrimination for exercising your privacy rights
12.5 Canadian Users (PIPEDA)
Canadian residents have rights under the Personal Information Protection and Electronic Documents Act (PIPEDA), including the right to access and correct your personal information and to withdraw consent subject to legal restrictions.
12.6 How to Exercise Your Rights
To exercise any of your rights, please contact us at dataprotection@reciprocate.app with your full name and the email address used to join the waitlist. We may request additional information to verify your identity before processing your request. We will not charge a fee for reasonable requests.
13. Supervisory Authorities
You have the right to lodge a complaint with a data protection or privacy authority in your jurisdiction. We encourage you to contact us first at dataprotection@reciprocate.app so we can try to resolve your concern directly. Relevant authorities include:
- Singapore: Personal Data Protection Commission (PDPC) — pdpc.gov.sg
- European Union: Your national data protection authority — full list at edpb.europa.eu
- United Kingdom: Information Commissioner’s Office (ICO) — ico.org.uk
- Australia: Office of the Australian Information Commissioner (OAIC) — oaic.gov.au
- Canada: Office of the Privacy Commissioner of Canada (OPC) — priv.gc.ca
- United States: Federal Trade Commission (FTC) — ftc.gov
14. Age Restrictions — No Users Under 18
The Service is intended exclusively for adults aged 18 and over. We do not knowingly collect personal data from anyone under the age of 18. If you are under 18, please do not use the Service or provide any personal information.
If we become aware that we have collected personal data from a person under 18, we will delete it promptly and without undue delay. If you believe we may have inadvertently collected data from a minor, please contact us at dataprotection@reciprocate.app immediately.
Prior to accessing the full RECIPROCATE platform upon launch, all users will be required to self-verify and confirm that they are aged 18 or over.
We are committed to compliance with applicable online safety legislation, including:
- UK Online Safety Act 2023 — we take our obligations seriously and will implement appropriate age assurance measures before the platform launches, in line with Ofcom’s codes of practice
- Australia Online Safety Act 2021 — we acknowledge our obligations under the eSafety Commissioner’s framework, including the Basic Online Safety Expectations (BOSE)
- Singapore Broadcasting Act and IMDA Framework — as a Singapore-incorporated company, we operate in accordance with the Infocomm Media Development Authority (IMDA) framework and applicable provisions of the Broadcasting Act governing online content and safety standards
- Other applicable legislation — including child protection, online safety, and age verification requirements in other jurisdictions in which we operate, including the US Children’s Online Privacy Protection Act (COPPA) and equivalent laws in Canada, Singapore, and other territories
15. Data Breaches
We take the security of your personal data seriously and have implemented technical and organizational measures to prevent unauthorized access, loss, or disclosure. Despite these measures, no system is entirely immune to security incidents.
15.1 Our Obligations
In the event of a personal data breach, we will:
- Notify the relevant supervisory authority — within the timeframe required by applicable law in the relevant jurisdiction. Under the GDPR and UK GDPR this is generally within 72 hours of becoming aware of a qualifying breach; under the Singapore PDPA this is within 3 calendar days of assessing that a breach is notifiable; other jurisdictions have their own applicable timeframes
- Notify affected users without undue delay — where a breach is likely to result in significant harm to you, as required by applicable law. We will endeavor to notify you as promptly as practicable, and in any event within the timeframe required by applicable law in your jurisdiction
- Contain and investigate — take immediate steps to contain the breach, assess its scope and impact, and implement remediation measures
- Maintain records — document all breaches in our internal breach register, including those that do not meet the threshold for external notification
15.2 What We Will Tell You
Where we are required to notify you of a breach, we will contact you at the email address you provided at signup. Our notification will include:
- A description of the nature of the breach
- The categories and approximate volume of personal data affected
- The name and contact details of our data protection contact
- The likely consequences of the breach
- The measures we have taken or propose to take to address the breach and mitigate its effects
15.3 Reporting a Security Concern
If you believe your data may have been compromised or you have identified a security vulnerability in the Service, please contact us immediately at dataprotection@reciprocate.app. We take all security reports seriously and will respond promptly.
16. Security
We use reasonable technical and organizational measures to protect your personal data against unauthorized access, loss, misuse, or alteration. These measures include:
- Encryption of personal data in transit using TLS/SSL
- Encryption of personal data at rest via Firebase security features
- Database security rules restricting access to authorized users only
- Authentication and access controls for system access
- Cloudflare DDoS protection, bot filtering, and edge security
- Regular security updates and monitoring
- Logical separation of customer data within multi-tenant architecture
However, no method of transmission over the internet or electronic storage is completely secure. While we strive to protect your personal data, we cannot guarantee absolute security. You transmit data to us at your own risk. If you suspect any misuse or unauthorized access to your data, please contact us immediately at dataprotection@reciprocate.app.
17. Liability
Our liability in connection with your use of the Service, including in relation to the processing of your personal data, is addressed in the Waitlist Terms for getreciprocate.app. The Waitlist Terms are published alongside this Privacy Policy on the Service and, once published, are incorporated by reference into this policy. Nothing in this Privacy Policy excludes or limits any liability that cannot be excluded or limited under applicable law, including mandatory consumer protection rights.
18. Third-Party Links
The Service may contain links to third-party websites or services that are not operated by us. This Privacy Policy does not apply to those sites. We have no control over and accept no responsibility for the content, privacy policies, or practices of any third-party sites or services. We encourage you to review the privacy policy of every site you visit.
19. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or for other operational reasons.
19.1 How We Will Notify You
We will notify you of any material changes by:
- Posting the updated policy on the Service with a revised “Last Updated” date
- Sending an email notification to the address you provided at signup, at least 14 days before the changes take effect
For non-material changes (such as clarifications, corrections, or updates to contact details), we may update the policy without prior notice, though we will always update the “Last Updated” date.
19.2 Your Continued Use
Your continued use of the Service after the effective date of any material changes constitutes your acceptance of the updated Privacy Policy. If you do not agree with the changes, you should stop using the Service and may request deletion of your data by contacting us at dataprotection@reciprocate.app.
19.3 Policy History
Previous versions of this Privacy Policy are available upon request by contacting us at dataprotection@reciprocate.app.
20. Data Protection Contacts & Representatives
20.1 General Data Protection Contact (Rest of World / DPO)
RECIPROCATE TECHNOLOGIES PTE LTD
UEN: 202604313E
10 Anson Road, 20-05 International Plaza, Singapore 079903
Data Protection / DPO: dataprotection@reciprocate.app
20.2 Data Protection Officer (DPO)
A Data Protection Officer will be appointed in due course. This policy will be updated with DPO contact details upon appointment.
20.3 EU Representative (GDPR Article 27)
As a company established outside the European Union that processes personal data of individuals in the EU, we are required under Article 27 of the GDPR to designate a representative in the European Union.
Our appointed EU representative is:
Prighter GmbH
Schellinggasse 3/10, 1010 Vienna, Austria
Website:
prighter.com
Note: Specific query contact link will be updated here upon Prighter onboarding finalization.
EU residents retain the right to contact their national supervisory authority at any time (see Section 13).
20.4 UK Representative (UK GDPR Article 27)
As a company established outside the United Kingdom that processes personal data of UK individuals, we have appointed a UK representative:
Prighter Ltd (UK Representative)
Website:
prighter.com
Note: Specific query contact link will be updated here upon Prighter onboarding finalization.
20.5 EU Digital Services Act (DSA) Representative
Prighter GmbH (DSA Representative)
Schellinggasse 3/10, 1010 Vienna, Austria
Website:
prighter.com
Note: Specific query contact link will be updated here upon Prighter onboarding finalization.
21. Governing Law
This Privacy Policy is governed by the laws of Singapore. Our primary regulatory obligations are under Singapore’s Personal Data Protection Act 2012 (PDPA) and its 2020 amendments.
The laws listed below are applicable to us to the extent indicated. We distinguish between laws that directly bind us based on where our users are located, and those we honor as a matter of good practice and operational commitment:
Directly applicable based on user location:
- The EU General Data Protection Regulation (GDPR) 2016/679 — where we process personal data of individuals located in the EEA
- The UK GDPR and Data Protection Act 2018 — where we process personal data of individuals located in the United Kingdom
- The Australian Privacy Act 1988 and Australian Privacy Principles — where we process personal data of individuals located in Australia
- The Canadian Personal Information Protection and Electronic Documents Act (PIPEDA) — where we process personal data of individuals located in Canada
Honored as a matter of operational commitment and good practice:
- The California Consumer Privacy Act (CCPA) — we do not meet the CCPA applicability thresholds but voluntarily extend its core rights to California residents as described in Section 12.4
- Other applicable data protection and privacy laws in the jurisdictions in which we operate, to the extent we have assessed those laws as relevant to our activities
Any disputes relating to this Privacy Policy shall be subject to the non-exclusive jurisdiction of the courts of Singapore, without prejudice to your right to seek relief from the data protection or supervisory authority in your own jurisdiction.
Privacy Policy — RECIPROCATE TECHNOLOGIES PTE LTD (UEN: 202604313E) | getreciprocate.app | Effective 09 March 2026
1. About These Terms
These Waitlist Terms (the “Terms”) govern your participation in the waitlist for the RECIPROCATE platform, operated by RECIPROCATE TECHNOLOGIES PTE LTD (UEN: 202604313E) (“we”, “us”, “our”) via https://getreciprocate.app (the “Service”).
The RECIPROCATE platform is the social community platform operated by RECIPROCATE TECHNOLOGIES PTE LTD, accessible at https://reciprocate.app upon launch. The waitlist at https://getreciprocate.app is a separate pre-launch service. References in these Terms to “the platform” mean the full RECIPROCATE platform at https://reciprocate.app.
Acceptance by signup: By submitting your details to join the waitlist, you agree to these Terms and our Privacy Policy, which is published alongside these Terms on the Service and incorporated by reference. If you do not agree, please do not join the waitlist.
Acceptance by use: To the extent permitted by applicable law, your use of the Service at https://getreciprocate.app and its sub-domains also constitutes your acceptance of these Terms, regardless of whether you complete the signup process. This applies where clear notice of these Terms is provided on the Service. In jurisdictions where a higher standard of consent is required for contractual acceptance, the signup statement and these Terms together constitute the basis of the agreement.
These Terms apply to the waitlist phase only. Separate terms of service will govern your use of the full RECIPROCATE platform when it launches.
Accessibility: Accessibility commitments for the full RECIPROCATE platform will be set out in the full platform Terms of Service, to be published before launch. We are committed to making the platform as accessible as possible and will address applicable accessibility standards at that time.
2. What the Waitlist Is (and Is Not)
The RECIPROCATE waitlist is an expression-of-interest mechanism that allows you to register your interest in gaining early access to the RECIPROCATE platform.
Joining the waitlist does not:
- Guarantee you access to the RECIPROCATE platform
- Create any binding obligation on us to launch the platform by any particular date, or at all
- Entitle you to any product, service, feature, or benefit
- Create any contractual relationship between you and us beyond these Terms
- Constitute acceptance of any offer to provide services
- Confer any ownership, equity, or financial interest in RECIPROCATE TECHNOLOGIES PTE LTD or the RECIPROCATE platform
Your waitlist position and points total are for indicative purposes only. They reflect your current standing relative to other waitlist members under the referral program and do not constitute a guarantee of early access priority. We reserve the right to modify the access allocation methodology at any time.
3. Eligibility
By joining the waitlist, you confirm that you:
- Are at least 18 years of age
- Have the legal capacity to enter into these Terms in your jurisdiction
- Are not prohibited from receiving services from us under applicable law
- Are joining the waitlist as an individual, not on behalf of any organization unless you have authority to bind that organization to these Terms
We reserve the right to verify eligibility and to remove any person from the waitlist who does not meet these requirements. The RECIPROCATE platform is an adult platform intended exclusively for users aged 18 and over.
4. Joining the Waitlist
To join the waitlist, you must provide your name and a valid email address and complete our double opt-in email verification process. Your waitlist place is not activated until email verification is complete.
Verification and waitlist confirmation emails are sent via our waitlist platform provider, Waitlister.me. These emails will be sent from reciprocate@waitlist.waitlister.me with a reply-to address of get@reciprocate.community. Please add these addresses to your safe sender list to ensure delivery. If you do not receive a verification email within a few minutes of signup, please check your spam or junk folder.
You agree to provide accurate, complete, and truthful information when joining the waitlist. You must not use a false identity, a temporary email address, or any other means of circumventing our signup process.
Each person may register once. Multiple registrations by the same person using different email addresses or identities are not permitted and may result in removal from the waitlist.
We process your personal data in connection with your waitlist registration in accordance with our Privacy Policy.
5. Referral Program
5.1 How It Works
Upon completing email verification, you will be assigned a unique referral link. You may share this link to invite others to join the waitlist. Each person who successfully joins and verifies their email using your referral link earns you points, which improve your position on the Early Access Leaderboard.
5.2 Points Have No Monetary Value
Points accumulated through the referral program:
- Have no monetary value and cannot be redeemed for cash, credit, or any other consideration
- Cannot be sold, transferred, gifted, or assigned to another person
- Do not constitute property of any kind
- May be adjusted, reduced, or voided by us at any time if we determine they were obtained in breach of these Terms or through fraudulent or abusive means
- Will expire and be of no effect if the waitlist is cancelled or if the platform does not launch
5.3 Acceptable Referral Conduct
You must not:
- Create fake, duplicate, or bot-generated signups using your referral link
- Use automated tools, scripts, or services to generate referrals
- Offer incentives, payments, or rewards to others in exchange for signing up via your link
- Misrepresent the RECIPROCATE platform or your relationship with us when sharing your referral link
- Use spam, unsolicited messaging, or deceptive practices to distribute your referral link
We reserve the right to investigate referral activity, void any points we reasonably believe were obtained improperly, and remove any person from the waitlist for breach of these rules, without notice and without liability.
5.4 Voluntary Promotion — No Partnership, Affiliation, or Association
Any sharing of your referral link, promotion of the RECIPROCATE platform, or participation in the referral program is entirely voluntary. By sharing your referral link or promoting the platform, you:
- Do so without any obligation, expectation of compensation, or promise of reward beyond waitlist points as described in Section 5.2
- Do not become an affiliate, partner, agent, representative, or employee of RECIPROCATE TECHNOLOGIES PTE LTD
- Are not authorized to make any representations, warranties, or commitments on our behalf
- Must not represent yourself as being associated with, endorsed by, affiliated with, or in partnership with RECIPROCATE TECHNOLOGIES PTE LTD or the RECIPROCATE platform in any way that implies an official relationship, ownership interest, or organizational connection
- Must not use our name, logo, trademarks, or branding in any promotional material without our prior written consent
We reserve the right to require you to cease any promotional activity that we reasonably consider to be misleading, inaccurate, harmful, or in breach of these Terms.
6. Acceptable Use
By using the Service, you agree not to:
- Use the Service for any unlawful purpose or in violation of any applicable law or regulation
- Attempt to gain unauthorized access to any part of the Service or its underlying systems
- Interfere with, disrupt, or place an unreasonable burden on the Service or its infrastructure
- Submit false, misleading, or fraudulent information
- Use the Service to transmit spam, malware, or any harmful content
- Attempt to reverse-engineer, scrape, or extract data from the Service
- Impersonate any person or entity or misrepresent your affiliation with any person or entity
We reserve the right to remove any person from the waitlist, without notice or liability, for any breach of these acceptable use provisions.
6.2 Anti-Disparagement
Our approach: We welcome honest feedback, legitimate complaints, and open public discourse about RECIPROCATE and the people behind it. What this clause addresses is a different matter entirely: deliberate, false, or malicious conduct intended to damage our reputation. This obligation applies whether or not you are currently on the waitlist, have ever activated an account, or have any ongoing relationship with us — because reputational harm does not stop at the moment you leave.
This clause applies to and protects:
- The RECIPROCATE platform (accessible at https://reciprocate.app upon launch)
- RECIPROCATE TECHNOLOGIES PTE LTD (UEN: 202604313E)
- The officers, directors, employees, contractors, and agents of RECIPROCATE TECHNOLOGIES PTE LTD
You agree not to:
- Make, publish, broadcast, or distribute any false statement of fact about any of the above, whether online, via social media, via electronic messaging, or by any other means
- Engage in, organize, or participate in any coordinated campaign, scheme, or pattern of conduct designed or intended to systematically damage the reputation of RECIPROCATE, the platform, or its personnel
- Publish, share, or disclose any non-public information, trade secrets, confidential communications, or inside information obtained through your participation in the waitlist or any interaction with us, in a manner designed to cause harm or embarrassment
- Harass, intimidate, or target any officer, employee, contractor, or agent of RECIPROCATE TECHNOLOGIES PTE LTD online or via any electronic means
Fact-checking requirement: Before making any public statement about RECIPROCATE, the platform, or our personnel that could be understood as factual, you agree to take reasonable steps to verify the accuracy of that statement. We encourage you to contact us at legal@reciprocate.app if you have concerns you wish to raise privately before making them public.
What this clause does not restrict: Nothing in this clause prohibits or restricts: (a) honest opinions, personal views, or genuine reviews, clearly identified as such; (b) accurate factual statements supported by evidence; (c) good-faith complaints made to regulatory authorities or consumer protection bodies; (d) any right of free speech or expression protected by applicable law in your jurisdiction.
Consequences: Breach of this clause may result, at our sole discretion, in: (a) removal from the waitlist; (b) a permanent ban from creating or holding a RECIPROCATE account on the platform, including any future account using a different identity or email address; (c) legal action as described below.
Our rights in response to breach: In the event of a breach or suspected breach of this clause, we reserve the right to:
- Pursue legal action against you in Singapore or in the jurisdiction where the conduct occurred or where you are located, at our election
- Request that platforms, social media networks, hosting providers, and other online venues where the conduct occurred provide identifying or contact information to the extent permitted by applicable law
- Publicly respond to, rebut, or correct any false or misleading statements made about us
- Require you to retract and remove any statement that is demonstrably false, contains non-public or confidential information, or includes trade secrets — promptly upon our written request and in any event within 72 hours of that request
Survival: This clause survives and remains binding indefinitely, regardless of: (a) your deletion of your waitlist registration; (b) your removal from the waitlist by us; (c) your choice not to complete signup or email verification; (d) your failure to activate or your loss of a RECIPROCATE account; or (e) any termination or expiry of these Terms for any other reason. The obligations in this clause are not limited to the period of your active participation in the waitlist or the platform.
7. Our Right to Modify or Cancel
We reserve the right, at our sole discretion and at any time, to:
- Modify, suspend, or discontinue the waitlist or any aspect of it
- Change the referral program rules, point values, or leaderboard mechanics
- Change the criteria for early access or platform launch eligibility
- Cancel the waitlist entirely, including in circumstances where the platform does not launch
- Remove any person from the waitlist for any reason, including breach of these Terms
We will make reasonable efforts to notify waitlist members of material changes by email where practicable, but we are not obligated to provide notice for operational adjustments or where removal is due to breach of these Terms.
We will not be liable to you or any third party for any modification, suspension, or cancellation of the waitlist. Your sole remedy in the event of cancellation is deletion of your data upon request.
8. Intellectual Property
All content, design, trademarks, logos, text, graphics, software, and other materials on the Service are the property of RECIPROCATE TECHNOLOGIES PTE LTD or our licensors and are protected by applicable intellectual property laws.
Nothing in these Terms grants you any right, title, or interest in our intellectual property. You must not copy, reproduce, distribute, modify, adapt, create derivative works of, or otherwise exploit any part of the Service without our prior written consent.
The RECIPROCATE name, logo, and associated marks are trademarks of RECIPROCATE TECHNOLOGIES PTE LTD. Use of our trademarks without prior written consent is strictly prohibited.
9. Limitation of Liability
9.1 Exclusions
To the fullest extent permitted by applicable law, RECIPROCATE TECHNOLOGIES PTE LTD shall not be liable for:
- Any indirect, incidental, special, consequential, or punitive damages arising from your participation in the waitlist or use of the Service
- Any loss of data, revenue, profits, business opportunity, or goodwill
- Any reliance placed on the waitlist, your position in it, or any communications about the platform or its launch
- Any failure to launch the platform, delay in launch, or change in launch plans
- Any unauthorized access to, or alteration or disclosure of, your personal data that occurs despite our reasonable security measures
- Any interruption, suspension, or termination of the Service or the waitlist
9.2 Cap on Liability
Where liability cannot be excluded under applicable law, our total aggregate liability to you in connection with these Terms, the waitlist, or your use of the Service shall not exceed SGD 5. This cap reflects the fact that participation in the waitlist is free of charge and no payment or consideration has been provided by you.
9.3 Non-Excludable Liability
Nothing in these Terms limits or excludes our liability for: (a) death or personal injury caused by our negligence; (b) fraud or fraudulent misrepresentation; or (c) any liability that cannot be excluded or limited under applicable law, including mandatory consumer protection rights.
9.4 Consumer Rights
If you are a consumer resident in the European Union, United Kingdom, Australia, Singapore, or another jurisdiction with mandatory consumer protection laws, you may have statutory rights that cannot be excluded or limited by these Terms. Nothing in this section affects those rights.
10. Dispute Resolution & Governing Law
10.1 Governing Law
These Terms are governed by and construed in accordance with the laws of Singapore, without regard to its conflict of law principles.
10.2 Mandatory Arbitration
Any dispute, controversy, or claim arising out of or in connection with these Terms, the waitlist, or the Service, including any question regarding the existence, validity, or termination of these Terms, shall be referred to and finally resolved by arbitration administered by the Singapore International Arbitration Centre (SIAC) in accordance with the SIAC Arbitration Rules for the time being in force, which rules are deemed to be incorporated by reference into this clause.
The seat of arbitration shall be Singapore. The language of arbitration shall be English. The tribunal shall consist of one arbitrator.
Nothing in this clause prevents either party from seeking urgent interim or injunctive relief from the courts of Singapore pending resolution of a dispute by arbitration.
10.3 No Class or Collective Actions
All disputes must be brought on an individual basis only. You expressly waive any right to bring or participate in any class action, collective action, consolidated arbitration, or representative proceeding against us. Disputes may not be consolidated with any other person’s dispute without our prior written consent.
10.4 Jurisdiction for Court Proceedings
To the extent that any matter is not subject to arbitration under these Terms, or where interim relief is sought, you submit to the exclusive jurisdiction of the courts of Singapore. Nothing in this clause prejudices your right to seek relief from a data protection or consumer protection authority in your own jurisdiction.
11. General
11.1 Severability
If any provision of these Terms is found to be invalid, unlawful, or unenforceable by a competent authority, that provision shall be modified to the minimum extent necessary to make it enforceable, or severed if modification is not possible, without affecting the validity and enforceability of the remaining provisions.
11.2 No Waiver
Our failure to enforce any right or provision of these Terms shall not constitute a waiver of that right or provision. Any waiver must be in writing and signed by an authorized representative of RECIPROCATE TECHNOLOGIES PTE LTD.
11.3 Assignment
You may not assign or transfer any rights or obligations under these Terms without our prior written consent. We may assign our rights and obligations under these Terms to a successor entity in the event of a merger, acquisition, or sale of assets, subject to the notification commitments in our Privacy Policy.
11.4 Changes to These Terms
We may update these Terms from time to time. We will notify you of any material changes by email to the address you provided at signup, at least 14 days before the changes take effect, and by posting the updated Terms on the Service with a revised effective date. Your continued participation in the waitlist after the effective date constitutes acceptance of the updated Terms.
11.5 Contact
11.6 Entire Agreement
These Terms, together with our Privacy Policy and Cookie Policy, each published alongside these Terms at https://getreciprocate.app, constitute the entire agreement between you and us in connection with your use of the Service and participation in the waitlist. They supersede all prior representations, communications, understandings, and agreements on this subject, whether oral or written.
In the event of any conflict between these Terms and the Privacy Policy or Cookie Policy, these Terms shall prevail to the extent of the conflict, except in relation to matters governed exclusively by the Privacy Policy or Cookie Policy, in which case those documents shall prevail.
Waitlist Terms — RECIPROCATE TECHNOLOGIES PTE LTD (UEN: 202604313E) | getreciprocate.app | Effective 09 March 2026 | legal@reciprocate.app
Why we publish this
RECIPROCATE TECHNOLOGIES PTE LTD is a Singapore-incorporated company. As a company with annual turnover below £36 million, we are not legally required to publish a Modern Slavery Statement under Section 54 of the UK Modern Slavery Act 2015.
We publish this statement voluntarily because operating a platform for adults carries a responsibility to take a clear and public position against exploitation, trafficking, and modern slavery. Silence is not neutrality in this space.
RECIPROCATE is a community platform built around authentic human connection — real people, real identities, genuine relationships. It is not an adult content platform. The platform does not permit nudity, explicit sexual content, or sexual discussions outside an educational context. The promotion of sex worker services is expressly prohibited. These are not incidental policies; they are part of the foundational character of what RECIPROCATE is.
Zero Tolerance — What We Absolutely Prohibit
The following are strictly prohibited on the RECIPROCATE platform and will result in immediate content removal, account termination, and where applicable, mandatory referral to law enforcement:
- Nudity and explicit adult or sexual content of any kind
- Sexual discussions that are not educational in scope
- Promotion of, or solicitation for, sex worker services
- Any content that facilitates, advertises, solicits, or enables exploitation, trafficking, coercion, or non-consensual conduct
- Facilitation of modern day slavery, forced labour, or human trafficking in any form
- Any content, conduct, or communication that facilitates the sexual exploitation, grooming, or abuse of minors
- Any attempt to use the platform to recruit, coerce, or deceive individuals for purposes of labour or sexual exploitation
CSAM — Zero Tolerance, No Exceptions: Child Sexual Abuse Material (CSAM) in any form results in: immediate removal of the material • immediate account termination • mandatory referral to relevant national authorities and, where applicable, the Internet Watch Foundation or equivalent body • provision of all available account information, access records, and metadata in accordance with legal reporting obligations. There are no exceptions to this policy under any circumstance.
Platform Structure as a Safety Mechanism
Real Identity & Authentic Presence
All members of RECIPROCATE are required to register and present using their real name and a genuine, current photograph of themselves. This is a deliberate anti-exploitation, anti-impersonation, and anti-trafficking measure. The platform is not designed for anonymous or pseudonymous participation. This policy significantly reduces the ability of bad actors to operate undetected.
Members with documented personal safety or security concerns may use a variation of their real name (e.g. Anne Katherine Smith may use "Annie K" or "A.K. Smith") but may not use a wholly fabricated identity. All such cases are assessed individually.
Age Assurance
RECIPROCATE is an adults-only platform. Our age assurance framework includes:
- All users confirm they are over 18 at sign-up
- Date of birth is required to activate an account
- Posting and member features are gated behind completion of all required profile fields including date of birth
- Automated moderation blocks posts that appear to target or be aimed at minors
- Where a user is identified as potentially under 18 — through behavioural signals, self-disclosure, date of birth review, or moderation referral — their posting access is suspended and the account reviewed by our Trust & Safety Team before any activity can resume
Our Trust & Safety Framework
RECIPROCATE maintains a Trust & Safety programme comprising user reporting mechanisms, automated content moderation tools, and defined escalation paths for suspected exploitation, trafficking, or policy violations.
Reports and concerns are reviewed by our Trust & Safety Team. For serious matters, the team may include:
- Senior team members with Trust & Safety responsibility
- Member Panel volunteers — vetted community members who support platform safety
- Third-party contracted Trust & Safety support
- Our legal team, for matters with legal or regulatory dimensions
- AI-assisted tools, used to surface content and accounts for human review
Human oversight is mandatory for decisions involving account suspension, account deletion, referral to law enforcement, and the assessment of significant or contested member reports. Automated action without human confirmation is not permitted for these categories of decision.
Our Supply Chain
RECIPROCATE's current supply chain comprises primarily cloud infrastructure providers, SaaS vendors, payment processors, and professional services partners — predominantly established technology companies operating in regulated jurisdictions. We do not currently source physical goods or use manufacturers.
From Q3 2026, all new vendor engagements are subject to a formal onboarding checklist that includes explicit modern slavery compliance expectations. Existing vendors are also being back-checked against this framework.
For future physical product and merchandise supply chains, the same ethics onboarding requirements will apply from the point of first engagement with any manufacturing or fulfilment partner.
Reporting Concerns
RECIPROCATE maintains a designated Trust & Safety contact point accessible to signed-in members, staff, and third parties to report concerns about modern slavery, exploitation, or trafficking in connection with the platform or its operations. All reports are handled with confidentiality and reviewed by the Trust & Safety Team.
Staff and contractors are encouraged to raise concerns — including about colleagues, vendors, or operational matters — without fear of retaliation. RECIPROCATE does not tolerate any adverse treatment of a person who raises a genuine concern in good faith.
Report a concern: abuse_policy@reciprocate.app
Trust & Safety: Available to signed-in platform members via the in-app reporting tools.
RECIPROCATE TECHNOLOGIES PTE LTD — 10 Anson Road, 20-05 International Plaza, Singapore 079903
Applicable Legislation
This statement is published in recognition of obligations under, or in voluntary alignment with:
- UK Modern Slavery Act 2015 — Section 54 (Transparency in Supply Chains) — published voluntarily; below mandatory threshold
- Australian Modern Slavery Act 2018
- Singapore Prevention of Human Trafficking Act 2014
- UK Online Safety Act 2023 — including obligations in relation to CSAM and child safety
- Australia Online Safety Act 2021 — eSafety Commissioner framework and Basic Online Safety Expectations
- Relevant provisions of the ILO Forced Labour Convention and equivalent international standards
Approval & Sign-Off
This Trust & Safety Statement has been reviewed and approved by the Board of Directors of RECIPROCATE TECHNOLOGIES PTE LTD. It is our inaugural statement, published proactively in March 2026 — early in our first financial year running from 26 January 2026 to 31 December 2026. It will be reviewed and updated each January.
RECIPROCATE TECHNOLOGIES PTE LTD
UEN: 202604313E
Legal enquiries: legal@reciprocate.app
10 Anson Road, 20-05 International Plaza, Singapore 079903
