Legal
Last updated: May 2026
These Terms apply to your use of the Service (as that term is defined below). By setting up an account:
If you do not agree to these Terms, you are not authorised to access and use the Service, and you must immediately stop doing so.
If the processing of Data (as defined below) is governed by the GDPR (as defined below), the additional terms in the Data Processing Addendum attached to these Terms also form part of these Terms.
We may change these Terms at any time by notifying you of the change by email or by posting a notice on the Website. Unless stated otherwise, any change takes effect from the date set out in the notice. You are responsible for ensuring you are familiar with the latest Terms. By continuing to access and use the Service from the date on which the Terms are changed, you agree to be bound by the changed Terms.
These Terms were last updated in May 2026.
In these Terms:
Confidential Information means any information that is not public knowledge and that is obtained from the other party in the course of, or in connection with, the provision and use of the Service. Our Confidential Information includes Intellectual Property owned by us (or our licensors), including the Tuu Software. Your Confidential Information includes the Data.
Data means all data, content, and information (including personal information and sustainability-related operational data) owned, held, used, or created by you or on your behalf that is stored using, or inputted into, the Service. This includes operational, energy, water, waste, food and training data submitted as part of Tuu Verified, which is collected for the purposes of independent verification, benchmarking and the production of an Evidence Pack.
Evidence Pack means the structured, period-specific output of the Tuu Verified process: a record of submitted operational data, verified KPIs, benchmark context and supporting documentation, independently reviewed by HLB and identified by a Record ID registered on the Blockmark Registry.
Fees means the applicable fees set out on our pricing page on the Website at /pricing or as agreed otherwise in writing between you and us, as may be updated from time to time in accordance with clause 7.6.
Force Majeure means an event that is beyond the reasonable control of a party, excluding:
GDPR means the European Union General Data Protection Regulation 2016/679 and the equivalent laws of the United Kingdom.
including and similar words do not imply any limit.
Intellectual Property Rights includes copyright and all rights existing anywhere in the world conferred under statute, common law or equity relating to inventions (including patents), registered and unregistered trade marks and designs, circuit layouts, data and databases, confidential information, know-how, and all other rights resulting from intellectual activity. Intellectual Property has a consistent meaning, and includes any enhancement, modification or derivative work of the Intellectual Property.
Objectionable includes being objectionable, defamatory, obscene, harassing, threatening, harmful, or unlawful in any way.
a party includes that party's permitted assigns.
Permitted Users means your personnel who are authorised to access and use the Service on your behalf in accordance with clause 5.3.
a person includes an individual, a body corporate, an association of persons (whether corporate or not), a trust, a government department, or any other entity.
personal information means information about an identifiable, living person, and includes personal data, personally identifiable information and equivalent information under applicable privacy and data protection laws.
personnel includes officers, employees, contractors and agents, but a reference to your personnel does not include us.
Service means the service having the core functionality described on the Website, including participation in Tuu Verified, which involves the submission, collection, independent verification by HLB and analysis of sustainability-related operational data for the production of an Evidence Pack and the registration of a Record ID on the Blockmark Registry, as the Website is updated from time to time.
Start Date means the date that you set up an account.
Terms means these terms titled Tuu terms of use.
Tuu Software means the software owned by us (and our licensors) that is used to provide the Service.
Underlying Systems means the Tuu Software, IT solutions, systems and networks (including software and hardware) used to provide the Service, including any third party solutions, systems and networks.
We, us or our means Tuu Pte. Limited, company number 201930040C, a company incorporated in Singapore whose registered office is at 30 Cecil Street, #19-08 Prudential Tower, Singapore 049712.
Website means the internet site at https://tuu.eco/, or such other site notified to you by us.
Year means a 12-month period starting on the Start Date or the anniversary of that date.
You or your means you or, if clause 1.1.2 applies, both you and the other person on whose behalf you are acting.
Words in the singular include the plural and vice versa. A reference to a statute includes references to regulations, orders or notices made under or in connection with the statute or regulations and all amendments, replacements or other changes to any of them.
We must use reasonable efforts to provide the Service:
Our provision of the Service to you is non-exclusive. Nothing in these Terms prevents us from providing the Service to any other person.
Subject to clause 4.4, we must use reasonable efforts to ensure the Service is available on a 24/7 basis. However, it is possible that on occasion the Service may be unavailable to permit maintenance or other development activity to take place, or in the event of Force Majeure. We must use reasonable efforts to publish on the Website and/or notify you by email advance details of any unavailability.
Through the use of web services and APIs, the Service interoperates with a range of third party service features. We do not make any warranty or representation on the availability of those features. Without limiting the previous sentence, if a third party feature provider ceases to provide that feature or ceases to make that feature available on reasonable terms, we may cease to make available that feature to you. To avoid doubt, if we exercise our right to cease the availability of a third party feature, you are not entitled to any refund, discount or other compensation.
You and your personnel must:
When accessing the Service, you and your personnel must:
You may authorise any member of your personnel to be a Permitted User and may, at any time, restrict Permitted Users' access to certain features.
You are responsible for determining the level of access granted to a Permitted User, for amending access rights as necessary from time to time, and for the deletion of any Permitted Users' account that you no longer wish to have access (e.g. where an employee ceases working for you). We take no responsibility for the level of access granted to a Permitted User, or for the deletion of Permitted Users' accounts.
You must procure each Permitted User's compliance with clauses 5.1 and 5.2 and any other reasonable condition notified by us to you.
A breach of any of these Terms by your personnel (including, to avoid doubt, a Permitted User) is deemed to be a breach of these Terms by you.
You are responsible for procuring all licences, authorisations and consents required for you and your personnel to use the Service, including to use, store and input Data into, and process and distribute Data through, the Service.
You acknowledge that:
You must arrange all consents and approvals that are necessary for us to access the Data as described in clause 6.1.
You acknowledge and agree that:
You acknowledge and agree that to the extent Data contains personal information, in collecting, holding and processing that information through the Service, we are acting as your agent and/or as a data processor for the purposes of applicable privacy and data protection laws. If the GDPR applies, the additional terms in the Data Processing Addendum attached to these Terms also form part of these Terms. You must obtain all necessary consents from the relevant individual to enable us to collect, use, hold and process that information in accordance with these Terms and, if applicable, the Data Processing Addendum.
While we will take standard industry measures to back up all Data stored using the Service, you agree to keep a separate back-up copy of all Data uploaded by you onto the Service.
You agree that we may store Data (including any personal information) in secure servers in Singapore and may access that Data (including any personal information) in Singapore from time to time.
Data submitted as part of Tuu Verified, including operational, energy, water, waste, food and training data, is collected for the purposes of independent verification, benchmarking sustainability performance and the production of an Evidence Pack.
This data will be anonymised and aggregated for trend analysis and industry reporting, following industry-standard anonymisation protocols to ensure privacy. The Record ID and the property-level verification outcome associated with an Evidence Pack are published by design on the Blockmark Registry; underlying operational data is not published on the Registry.
Data submitted as part of Tuu Verified will be stored securely and will be reviewed by HLB, our independent verification partner, to ensure the accuracy of the Evidence Pack.
As part of Tuu Verified, submitted operational data and supporting documentation are reviewed by HLB as our independent verification partner.
The verification review involves checking submitted data against supporting documentation and the declared scope, and may require further documentation, virtual site inspections or other evidence to verify accuracy.
This review supports the integrity of the Evidence Pack and the credibility of the verified KPIs that flow from it.
By submitting data as part of Tuu Verified, you grant Tuu Pte. Limited a non-exclusive, worldwide licence to use the submitted data for the purposes of independent verification, benchmarking, the production of the Evidence Pack and the registration of the Record ID and property-level verification outcome on the Blockmark Registry.
Underlying operational data may be aggregated and anonymised for broader industry reports but will not be publicly attributed to your property without explicit consent. The Record ID and the property-level verification outcome are public by design on the Blockmark Registry and form part of the permanent verification record.
You have the right to withdraw your consent for non-public uses of your data at any time by contacting hello@tuu.eco. The publication of the Record ID and the property-level verification outcome on the Blockmark Registry is part of the permanent verification record; revocation of a verification outcome follows the process described in our methodology.
You indemnify us against any liability, claim, proceeding, cost, expense (including the actual legal fees charged by our solicitors) and loss of any kind arising from any actual or alleged claim by a third party that any Data infringes the rights of that third party (including Intellectual Property Rights and privacy rights) or that the Data is Objectionable, incorrect or misleading.
You must pay us the Fees.
We will provide you with invoices on a monthly basis prior to the due date for payment.
The Fees exclude any applicable goods and services, value-added, sales or other similar tax, which you may be required to pay on taxable supplies.
You must pay the Fees:
We may charge interest on overdue amounts. Interest will be calculated from the due date to the date of payment (both inclusive) at an annual percentage rate equal to the corporate overdraft reference rate (monthly charging cycle) applied by our primary trading bank as at the due date (or, if our primary trading bank ceases to quote that rate, then the rate which in the opinion of the bank is equivalent to that rate in respect of similar overdraft accommodation expressed as a percentage) plus 2% per annum.
We may increase the Fees by giving at least 30 days' notice. If you do not wish to pay the increased Fees, you may terminate these Terms and your right to access and use the Service on no less than 10 days' notice, provided the notice is received by us before the effective date of the Fee increase. If you do not terminate these Terms and your right to access and use the Service in accordance with this clause, you are deemed to have accepted the increased Fees.
Subject to clause 8.2, title to, and all Intellectual Property Rights in, the Service, the Website, and all Underlying Systems is and remains our property (and our licensors' property). You must not contest or dispute that ownership, or the validity of those Intellectual Property Rights.
Title to, and all Intellectual Property Rights in, the Data (as between the parties) remains your property. Subject to the Data Processing Addendum attached to these Terms (if applicable), you grant us a worldwide, non-exclusive, fully paid-up, transferable, irrevocable licence to use, store, copy, modify, make available, and communicate the Data for any purpose in connection with the exercise of our rights and performance of our obligations in accordance with these Terms. This includes the right to use the Data for purposes related to Tuu Verified, including independent verification, benchmarking, reporting and the production of the Evidence Pack and the registration of the Record ID on the Blockmark Registry. Submitted Data will be anonymised and aggregated for broader industry reports unless explicit consent has been provided by you.
To the extent not owned by us, you grant us a royalty-free, transferable, irrevocable and perpetual licence to use for our own business purposes any know-how, techniques, ideas, methodologies, and similar Intellectual Property used by us in the provision of the Service.
If you provide us with ideas, comments or suggestions relating to the Service or Underlying Systems (together feedback):
You acknowledge that the Service may link to third party websites or feeds that are connected or relevant to the Service. Any link from the Service does not imply that we endorse, approve or recommend, or have responsibility for, those websites or feeds or their content or operators. To the maximum extent permitted by law, we exclude all responsibility or liability for those websites or feeds.
Each party must, unless it has the prior written consent of the other party:
The obligation of confidentiality in clause 9.1 does not apply to any disclosure or use of Confidential Information:
Data handling
Any operational, energy, water, waste, food or training data submitted as part of Tuu Verified will be treated as confidential and used solely for the purposes of independent verification, benchmarking, the production of the Evidence Pack, the registration of the Record ID on the Blockmark Registry, and industry reporting in anonymised and aggregated form.
Underlying operational data will be anonymised and aggregated before being shared for external reports or trend analysis. The Record ID and the property-level verification outcome are public by design on the Blockmark Registry.
Data security
Verification procedures
Compliance and updates
Each party warrants that it has full power and authority to enter into, and perform its obligations under, these Terms.
To the maximum extent permitted by law:
You agree and represent that you are acquiring the Service, and accepting these Terms, for the purpose of trade. The parties agree that to the maximum extent permissible by law, any applicable consumer protection law does not apply to the supply of the Service or these Terms, and that it is fair and reasonable that the parties are bound by this clause 10.3.
Where legislation or rule of law implies into these Terms a condition or warranty that cannot be excluded or modified by contract, the condition or warranty is deemed to be included in these Terms. However, our liability for any breach of that condition or warranty is limited, at our option, to supplying the Service again, and/or paying the costs of having the Service supplied again.
Our maximum aggregate liability under or in connection with these Terms or relating to the Service, whether in contract, tort (including negligence), breach of statutory duty or otherwise, must not in any Year exceed an amount equal to the Fees paid by you relating to the Service in the 6 month period prior to the date of the first event giving rise to liability.
Neither party is liable to the other under or in connection with these Terms or the Service for any:
Clauses 11.1 and 11.2 do not apply to limit our liability under or in connection with these Terms for:
Clause 11.2 does not apply to limit your liability:
Neither party will be responsible, liable, or held to be in breach of these Terms for any failure to perform its obligations under these Terms or otherwise, to the extent that the failure is caused by the other party failing to comply with its obligations under these Terms, or by the negligence or misconduct of the other party or its personnel.
Each party must take reasonable steps to mitigate any loss or damage, cost or expense it may suffer or incur arising out of anything done or not done by the other party under or in connection with these Terms or the Service.
Unless terminated under this clause 12, these Terms and your right to access and use the Service:
Subject to clause 7.6, if the subscription option you have selected includes a minimum initial term, the earliest date for termination under clause 12.1 will be the expiry of that initial term.
Either party may, by notice to the other party, immediately terminate these Terms and your right to access and use the Service if the other party:
You may terminate these Terms and your right to access and use the Service in accordance with clause 7.6.
Termination of these Terms does not affect either party's rights and obligations that accrued before that termination.
On termination of these Terms, you must pay all Fees for the provision of the Service prior to that termination.
No compensation is payable by us to you as a result of termination of these Terms for whatever reason, and you will not be entitled to a refund of any Fees that you have already paid.
Except to the extent that a party has ongoing rights to use Confidential Information, at the other party's request following termination of these Terms but subject to clause 12.9, a party must promptly return to the other party or destroy all Confidential Information of the other party that is in the first party's possession or control.
At any time prior to one month after the date of termination, you may request:
To avoid doubt, we are not required to comply with clause 12.9.1 to the extent that you have previously requested deletion of the Data.
Without limiting any other right or remedy available to us, we may restrict or suspend your access to and use of the Service and/or delete, edit or remove the relevant Data if we consider that you or any of your personnel have:
Neither party is liable to the other for any failure to perform its obligations under these Terms to the extent caused by Force Majeure.
No person other than you and us has any right to a benefit under, or to enforce, these Terms.
For us to waive a right under these Terms, that waiver must be in writing and signed by us.
Subject to clause 6.4, we are your independent contractor, and no other relationship (e.g. joint venture, agency, trust or partnership) exists under these Terms.
If we need to contact you, we may do so by email or by posting a notice on the Website. You agree that this satisfies all legal requirements in relation to written communications. You may give notice to us under or in connection with these Terms by emailing hello@tuu.eco.
These Terms, and any dispute relating to these Terms or the Service, are governed by and must be interpreted in accordance with the law of Singapore. Each party submits to the non-exclusive jurisdiction of the Courts of Singapore in relation to any dispute connected with these Terms or the Service.
Clauses which, by their nature, are intended to survive termination of these Terms, including clauses 6.10, 8, 9, 11, 12.5 to 12.9 and 13.6, continue in force.
If any part or provision of these Terms is or becomes illegal, unenforceable, or invalid, that part or provision is deemed to be modified to the extent required to remedy the illegality, unenforceability or invalidity. If modification is not possible, the part or provision must be treated for all purposes as severed from these Terms. The remainder of these Terms will be binding on you.
Subject to clauses 2.1 and 7.6, any variation to these Terms must be in writing and signed by both parties.
These Terms set out everything agreed by the parties relating to the Service, and supersede and cancel anything discussed, exchanged or agreed prior to the Start Date. The parties have not relied on any representation, warranty or agreement relating to the Service that is not expressly set out in these Terms, and no such representation, warranty or agreement has any effect from the Start Date. The parties agree that it is fair and reasonable that the parties are bound by this clause 13.10.
You may not assign, novate, subcontract or transfer any right or obligation under these Terms without our prior written consent, that consent not to be unreasonably withheld. You remain liable for your obligations under these Terms despite any approved assignment, subcontracting or transfer.
This Data Processing Addendum, including its Schedules (Addendum), applies if the Processing (as defined below) of Data is governed by the GDPR (as defined below).
If this Addendum applies, this Addendum forms part of the Terms between us and you (as defined in the Terms) and sets out the parties' agreement in relation to the processing of Data in accordance with the requirements of European Union and United Kingdom data protection laws and regulations.
This Addendum incorporates by reference the 2021 EU Standard Contractual Clauses (as defined below), Module 2, which are pre-signed by us and form part of this Addendum. If you would like to counter-sign the Standard Contractual Clauses, please complete the necessary details, countersign the Standard Contractual Clauses, and return a counter-signed copy to us at hello@tuu.eco.
Except as varied in this Addendum (including the Standard Contractual Clauses, if applicable) all terms and conditions set out in the Terms continue to apply.
Unless the context requires otherwise, capitalised terms used but not defined in this Addendum will have the meanings given to them in the Applicable Data Protection Laws (or, if not defined in the Applicable Data Protection Laws, the Terms); the rules of interpretation set out in the Terms apply to this Addendum; and references to clauses are references to the clauses in this Addendum.
In this Addendum:
Applicable Data Protection Laws means EU/UK Data Protection Laws and any applicable data protection or privacy laws of any other country.
EU/UK Data Protection Laws means all laws and regulations, including laws and regulations of the European Union, its member states and the United Kingdom, that apply to the Processing of Data under the Terms, including (where applicable) the GDPR and the equivalent legislation of the United Kingdom.
Instruction means the instructions set out in clause 3.3 or agreed under clause 3.4.
Personal Data means all Data which is personal data, personally identifiable information or personal information under Applicable Data Protection Laws (as applicable under those laws).
Processing means any operation or set of operations which is performed upon Personal Data, whether or not by automated means, such as collection, recording, organisation, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, blocking, erasure or destruction. Process has a consistent meaning.
Standard Contractual Clauses means the standard contractual clauses adopted by the European Commission in Commission Implementing Decision (EU) 2021/914 of 4 June 2021 on standard contractual clauses for the transfer of personal data to third countries pursuant to Regulation (EU) 2016/679 (the "2021 EU SCCs"), Module 2 (controller-to-processor transfers), as summarised in Schedule 3 of this Addendum and available in full at the official EU Commission text.
Sub-Processor means any person appointed by us or on our behalf to Process Personal Data on your behalf in connection with the Terms.
If there is any conflict between any of the following, they will have precedence in the descending order of priority set out below: the Standard Contractual Clauses; this Addendum; and the Terms.
With respect to the Processing of Personal Data under the Terms: you act as the Data Controller; we act as the Data Processor; and subject to clause 6, we may engage the Sub-Processors listed in Schedule 2.
We will comply with all Applicable Data Protection Laws that apply to our Processing of Personal Data on your behalf, including all EU/UK Data Protection Laws that apply to Data Processors.
You must, when using the Service, comply with all Applicable Data Protection Laws that apply to your Processing of Personal Data, including all EU/UK Data Protection Laws that apply to Data Controllers.
You instruct us to Process Personal Data and, in particular, subject to clause 6, transfer Personal Data to any country or territory:
This Addendum and the Terms are your complete and final instructions for the Processing of Personal Data as at the time this Addendum takes effect. Any additional or alternate instructions must be agreed between us and you separately in writing.
We will not Process Personal Data other than on your Instructions unless required by any law to which we are subject, in which case we will to the extent permitted by applicable law inform you of that legal requirement before we Process that Personal Data.
As required by Article 28(3) of the GDPR (and, if applicable, equivalent requirements of other Applicable Data Protection Laws), the nature and purpose of the Processing, the types of Personal Data and categories of Data Subjects Processed under this Addendum are set out in Schedule 1. We may amend Schedule 1 from time to time on written notice to you as we reasonably consider necessary to meet the requirements of the GDPR (and applicable equivalent requirements of other Applicable Data Protection Laws).
The duration of Processing is limited to the duration of the Terms. Our obligations in relation to Processing will continue until the Personal Data has been properly deleted or returned to you in accordance with clause 11 of this Addendum.
You are solely responsible for ensuring that your Instructions comply with Applicable Data Protection Laws. It is also your responsibility to enter into data processing agreements with other relevant Data Controllers in order to allow us and our Sub-Processors to Process Personal Data in accordance with this Addendum.
If, in our reasonable opinion, an Instruction infringes Applicable Data Protection Laws, we will notify you as soon as reasonably practicable.
To the extent permitted by law, we will notify you promptly if we receive a request from a Data Subject to exercise the Data Subject's rights under Applicable Data Protection Laws relating to any Personal Data (Data Subject Request).
Taking into account the nature of the Processing, we will assist you by implementing appropriate technical and organisational measures, to the extent possible, to fulfil your obligation to respond to a Data Subject Request under Applicable Data Protection Laws.
To the extent you do not have the ability to address a Data Subject Request, we will, on your written request, provide reasonable assistance in accordance with Applicable Data Protection Laws to facilitate that Data Subject Request. You will reimburse us for the costs arising from this assistance.
We will not respond to a Data Subject Request except on your written request or if required by applicable law.
You acknowledge and agree that we may engage third party Sub-Processors in connection with the provision of the Service.
We have entered into (and will, for any new Sub-Processor, enter into) written agreements with each Sub-Processor containing data protection obligations which offer at least the same level of protection for Personal Data as set out in this Addendum and that meet the requirements of Article 28(3) of the GDPR, as applicable to the nature of the services provided by that Sub-Processor.
You may request copies of our written agreements with Sub-Processors (which may be redacted to remove confidential information not relevant to this Addendum).
A list of current Sub-Processors for the Service as at May 2026 is set out in Schedule 2. We may update the list of Sub-Processors from time to time and, subject to clause 6.5, we will give at least 30 days' written notice of any new Sub-Processor (Change Notice).
We may engage Sub-Processors as needed to serve as an Emergency Replacement to maintain and support the Service. Emergency Replacement means a sudden replacement of a Sub-Processor where a change is outside our reasonable control. In this case, we will inform you of the replacement Sub-Processor as soon as reasonably practicable.
You may object to any new Sub-Processor on reasonable grounds by notifying us within 10 days of receipt of a Change Notice. Your notice of objection to any new Sub-Processor must explain the reasonable grounds for your objection. The parties must discuss your concerns about the new Sub-Processor in good faith with a view to resolve the objection to the use of the new Sub-Processor in a commercially reasonable manner. If it is not possible to resolve the objection, and we do not revoke the Change Notice before the date the Change Notice takes effect, you may, despite anything to the contrary in the Terms, terminate the applicable Service under the Terms that cannot be provided to you without that new Sub-Processor. If you do not terminate the relevant Service under the Terms in accordance with this clause, you are deemed to have agreed to the new Sub-Processor.
We are liable for the acts and omissions of our Sub-Processors to the same extent we would be liable if performing the services of each Sub-Processor directly under the terms of this Addendum, except as otherwise set out in this Addendum.
We will maintain technical and organisational measures to protect the confidentiality, integrity and security of Personal Data (including protection against unauthorised or unlawful Processing and against accidental or unlawful destruction, loss or alteration or damage, unauthorised disclosure of, or access to, Personal Data), and to manage data security incidents affecting Personal Data, in accordance with Annex II of the Standard Contractual Clauses summarised in Schedule 3.
We will comply with all applicable laws requiring notification to you of any accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to Personal Data Processed by us or our Sub-Processors of which we become aware (Breach Incident).
We will make reasonable efforts to identify the cause of that Breach Incident, notify you within a timely manner to allow you to meet your obligations to report a Breach Incident, and take steps we consider necessary and reasonable to remediate the cause of the Breach Incident, to the extent remediation is within our reasonable control.
Upon your written request, we will, at your cost, submit to your audits and inspections, and provide you all information necessary, to demonstrate that both you and we are complying with our respective obligations under Applicable Data Protection Laws (including our respective obligations under Article 28 of the GDPR).
Upon your written request, we will, at your cost, provide you with reasonable assistance needed to fulfil your obligation under Applicable Data Protection Laws to carry out a data protection impact assessment relating to your use of the Service, to the extent you do not otherwise have access to the relevant information.
Subject to clauses 11.2 and 11.3, following termination of the Terms we will delete all Personal Data within a reasonable period from termination of the Terms.
Subject to clause 11.3, you may submit a written request to us within 10 working days of the termination of the Terms requiring us, within 20 working days of your written request, to:
We, or each Sub-Processor, may retain Personal Data to the extent that it is required by applicable laws, provided that we ensure the confidentiality of all such Personal Data and ensure that such Data is only processed as necessary for the purposes required under applicable laws requiring its Processing and for no other purpose.
If we cannot delete all Personal Data due to technical reasons, we will inform you as soon as reasonably practicable and will take reasonably necessary steps to: come as close as possible to a complete and permanent deletion of the Personal Data; fully and effectively anonymise the remaining data; and make the remaining Personal Data which is not deleted or effectively anonymised unavailable for future Processing.
We may, on at least 30 days' written notice to you from time to time, make any variations to this Addendum (including to the Standard Contractual Clauses), which we consider (acting reasonably) are required as a result of any change in, or decision of a competent authority under, Applicable Data Protection Laws, to allow transfers and Processing of Personal Data to continue without breach of Applicable Data Protection Laws.
If you object to any variation under clause 12.1 on reasonable grounds, you may, despite anything to the contrary in the Terms, terminate these Terms and your right to access and use the Service without penalty on written notice, provided your notice of termination is received by us before the effective date of our notice. If you do not terminate these Terms and your right to access and use the Service in accordance with this clause, you are deemed to have agreed to the variation.
The liability of each party to the other party under or in connection with this Addendum is subject to the limitations and exclusions set out in the Terms, and any reference in the Terms to the liability of a party means the aggregate liability of that party under the Terms and this Addendum together.
If any provision of this Addendum is, or becomes unenforceable, illegal or invalid for any reason, the relevant provision is deemed to be varied to the extent necessary to remedy the unenforceability, illegality or invalidity. If variation is not possible, the provision must be treated as severed from this Addendum without affecting any other provisions of this Addendum.
Nature and purpose of processing. We will Process Personal Data as necessary to provide the Service in accordance with the Terms, as further specified in our online documentation relating to the Service, and as further instructed by you and your personnel and other end users you allow to use the Service through the use of the Service.
Duration of processing. Subject to clause 11 of this Addendum, we will Process Personal Data for the duration of the Terms, unless otherwise agreed upon in writing.
Categories of Data Subjects. You may submit Personal Data to the Service, the extent of which is determined and controlled by you in your sole discretion, and which may include, but is not limited to, Personal Data relating to the following categories of data subjects: customer personnel (employees, contractors and authorised users acting on behalf of the customer); property-level operational staff identified in supporting documentation; counterparties identified in operational records (e.g. waste contractors).
Type of Data. You may submit Personal Data to the Service, the extent of which is determined and controlled by you in your sole discretion, and which may include, but is not limited to, the following categories of personal data: name, business email address, business phone number, business address, job title, training records and operational data referencing identifiable individuals.
As of May 2026, our Sub-Processors are:
| Sub-Processor | Purpose | Location |
|---|---|---|
| Vercel Inc. | Marketing website hosting | United States |
| Microsoft Azure (Microsoft Corporation) | Platform infrastructure and data storage | Singapore region primary |
| HLB International | Independent verification of operational data | Global (HLB Thailand for Tuu engagements) |
| Blockmark Technology | Public registry recording of verification outcomes | United Kingdom |
| Google LLC (Google Analytics) | Marketing website traffic analytics | United States |
We will give at least 30 days' written notice of any new Sub-Processor in accordance with clause 6.4 of this Addendum.
The transfer of Personal Data from the data exporter (you) to the data importer (Tuu Pte. Limited) is governed by the 2021 EU Standard Contractual Clauses, adopted by the European Commission in Commission Implementing Decision (EU) 2021/914 of 4 June 2021, Module 2 (controller-to-processor transfers).
The full official text of the 2021 EU SCCs — including all clauses and the docking clause — is incorporated by reference and available at: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32021D0914.
Where the 2021 EU SCCs require party-specific information, the parties have completed the Annexes as set out below.
A. List of parties
Data exporter (controller). To be completed by the customer:
Data importer (processor). Pre-completed by Tuu Pte. Limited:
B. Description of transfer
C. Competent supervisory authority. The competent supervisory authority is the supervisory authority of the EU/EEA member state in which the data exporter is established, or, where the data exporter is established outside the EU/EEA, the supervisory authority of the EU/EEA member state in which the data exporter's representative is established.
The data importer implements the following technical and organisational measures to ensure the security of the Personal Data, in accordance with Article 32 of the GDPR:
As of May 2026, the authorised Sub-Processors are the same as those listed in Schedule 2 of this Addendum:
| Sub-Processor | Purpose | Location |
|---|---|---|
| Vercel Inc. | Marketing website hosting | United States |
| Microsoft Azure (Microsoft Corporation) | Platform infrastructure and data storage | Singapore region primary |
| HLB International | Independent verification of operational data | Global (HLB Thailand for Tuu engagements) |
| Blockmark Technology | Public registry recording of verification outcomes | United Kingdom |
| Google LLC (Google Analytics) | Marketing website traffic analytics | United States |
On behalf of the data importer (pre-signed):
On behalf of the data exporter (to be completed by the customer):
To counter-sign, please complete the data exporter details above and return a signed copy of these Schedules to hello@tuu.eco.