1. Our statement of privacy practice
We are not in the business of selling personal information collected by Us from You. We use Your information to service Your requests; process payments; communicate with you regarding the Services; generally maintain Your Accounts with us; and try to enhance Your overall experience on the Platform.
2. Types of information collected
(i) Information shared during account creation : This refers to information that You provide to Us, voluntarily, while registering on Our Platform and/or for signing up for a subscription plan. This includes the information that the Company collects from You when You register on the Platform to create an Account, such as Your name, electronic mail address, phone number, location and other similar details. You may also set an account name at the time of integration, which will also be collected by Us.
(ii) Information automatically collected : The Company shall automatically receive and record on its server logs details relating to Your access or use of the Platform, including but not limited to, Your location, information about Your internet connection and mobile device, Internet Protocol address, cookie information, web beacon information, etc. Further, the Company may also collect information about Your preferences and settings such as time zone and language, Your searches and the results You selected from the search and Your transactional information.
(iii) Information shared during integration with Cryptocurrency Exchanges : For integration of the Platform with the Cryptocurrency Exchanges with whom You have accounts, You are required to obtain from the exchange and key in an API key (public key), a secret key (private key) and an API passphrase. Upon such integration, the Company shall collect, retain and use for providing the Services information which can be obtained from the relevant Cryptocurrency Exchanges, including but not limited to Your holdings of different instruments, transaction history and trading account details. You have control over the kind of information that We can obtain upon integration with the Cryptocurrency Exchanges and We can only receive the information that Your API key set authorizes Us to access.
(iv) User communications : When You send emails or other communications to Us, We will retain those communications in order to process Your inquiries, respond to Your requests and improve Our Services and/or Platform.
4. Use of information collected
Our primary purpose in collecting personal information is to provide You with a secure, smooth, efficient, and customised experience. In general, We use personal information to create, develop, operate, deliver, and improve the Platform and Services. We shall use this information in the following ways:
(i) to provide, maintain, develop, protect and improve the Services, manage Your Account, etc.; (ii) to understand Your preferences and to enhance and customize Your experience of using the Platform; (iii) to respond to Your comments, reviews and questions and provide better service; (iv) to carry out the Company’s obligations and enforce the Company’s rights arising from any contracts entered into between You and the Company, including for billing and collection of amounts; (v) to communicate important notices or changes in the Services provided by the Company, use of the Platform and the terms/policies which govern the relationship between You and the Company; (vi) for internal purposes such as auditing, data analysis and research relating to the Platform or Services; (vii) for promotion and marketing purposes; (viii) to maintain legal and regulatory compliance; (viiii) for sharing such information with any third party, including any service providers and any group companies of the Company, in the course of providing or enabling provision of the Services through the Platform; and (ix) for any other purpose with Your consent.
5. Transparency and Choice
Your acknowledgement: All information disclosed by You shall be deemed to be disclosed willingly and without any coercion. No liability pertaining to the authenticity/ genuineness/ misrepresentation/ fraud/ negligence, etc. of the information disclosed shall lie on the Company nor will the Company in any way be responsible to verify any information obtained from You. You shall ensure and confirm that the Account information provided by You is complete, accurate and up-to-date. If there is any change in the Account information, You shall promptly update Your Account information on the Platform. If You provide any information that is untrue, inaccurate, not current or incomplete (or becomes untrue, inaccurate, not current or incomplete), or if the Company has reasonable grounds to suspect that such information is untrue, inaccurate, not current or incomplete, the Company has the right to suspend or terminate Your Account and refuse any and all current or future use of the Platform (or any portion thereof) at its discretion, in addition to any right that the Company may have against You at law or in equity, for any misrepresentation of information provided by You.
Cookies: You may also set Your browser to block all cookies, including cookies associated with Our Services, or to indicate when a cookie is being set by us. However, it is important to remember that many of Our Services will not function properly if Your cookies are disabled.
6. Collection of Information by Cryptocurrency Exchanges, Third-Party Sites and Advertisers
The Company hereby expressly disclaims all liabilities with respect to the manner in which the Third Party Site or Cryptocurrency Exchanges collects and/or uses Your information. On Our Platform, there may be third parties who advertise their products and/or services. Such third parties may place or recognize a unique “cookie” on Your browser and may use information about Your visits to Our Platform and other websites in order to provide advertisements about goods and services of interest to You. We shall, in no event, be liable for any unauthorized or unlawful disclosures of Your personal information made by advertisers, who are not subject to Our control.
6. Disclosure to Third Parties
We may share personal information with third-parties including vendors, consultants, and other service providers who work for the Company, who are bound by contractual obligations to keep the information confidential and use it only for the purposes for which We disclose it to them.
Any content or personal information that You share or upload on the publicly viewable portion of the Platform will be publicly available, and can be viewed by other users. Any information that You post in the publicly viewable portion of the Platform will be visible to the others users as posted by You along with some basic personal details like Your name and not in an anonymized manner.
The Company may store the information that You provide at data centres or servers, whether owned, leased, licensed or used by the Company, at a jurisdiction different to where You reside. You hereby agree that such transfer of information to data centres or servers are necessary for the Company to provide You access to the Platform and for providing the Services. Accordingly, You hereby provide Your consent to the Company to transfer the information to any third party jurisdiction.
The Company shall take reasonable steps to help protect Your rights of privacy and Your information in an effort to prevent loss, misuse, unauthorized access, disclosure, alteration, or destruction of such information, in compliance with the applicable laws. The technical and organizational measures adopted to protect the information have been determined after taking into account state of the art, the cost of implementation and the nature, scope, context and purposes of processing as well as the risks of varying likelihood and severity for rights and freedoms of natural persons posed by the processing, both at the time of the determination of the means for processing and at the time of the processing itself. We have implemented measures that ensure that only personal data which are necessary for each specific purpose of the processing are processed.
When payment card account information is being transmitted on or through the Platform, it will be protected by encryption technology. You expressly consent to the collection or sharing of Your information with third party service providers, including payment gateways, to process payments and manage payment card information. The Company does not itself store Your payment card account information, and does not have direct control over or responsibility for Your payment card account information. Hence, the Company cannot guarantee that transmissions of Your payment card account information or personal information will always be secure or that unauthorized third parties will never be able to defeat the security measures taken by the Company or the Company’s third party service providers. The Company assumes no liability or responsibility for disclosure of Your information due to errors in transmission, unauthorized third party access, or other causes beyond its control. You play an important role in keeping Your personal information secure. You shall not share Your user name, password, or other security information for Your Account with anyone.
8. User Discretion
(i) You may opt out of receiving promotional emails from the Company by following the instructions in those emails. If You opt out, the Company may still send You non-promotional emails, such as emails about the Services and Your Account.
(ii) Should You desire to opt out of disclosing Your information to the Company, the Company requests You to close Your Account and stop accessing the Platform and availing Platform Services. Thereafter, the Company shall delete Your information (personal or otherwise) or de-identify it so that it is anonymous and not attributable to You (except to the extent, as detailed in Paragraph 4 above).
(iii) Right of access. You shall have the right to access the information concerning You that is held by the Company and such information may be provided in a commonly used electronic form.
(iv) Right to rectification. Along with the right to access the information concerning You, You shall have the right to rectify any inaccurate or deficient information concerning You. You may also add information to any incomplete information, including by means of providing a supplementary statement.
Your acknowledgement: All information disclosed by You shall be deemed to be disclosed willingly and without any coercion. No liability pertaining to the authenticity/ genuineness/ misrepresentation/ fraud/ negligence, etc. of the information disclosed shall lie on the Company nor will the Company in any way be responsible to verify any information obtained from You.
Additional rights and obligations for users located in European Union:
If You are a resident of the European Union (EU) and You use the Platform and/or the Services, for the purposes of applicable data protection law (in particular, the General Data Protection Regulation (EU) 2016/679 (the “GDPR”)), please note that the Company shall be the data controller in relation to Your information processed. In addition to the terms set out above, the following terms shall also be applicable to You. To the extent of conflict, the following terms shall prevail.
12. Lawful bases for processing of information
We process Your information based on the consent that You provide while accessing the Platform. You also agree and accept that such processing of the information provided by You is necessary for the performance of a contract between You and the Company.
13. Disclosure of information
The Company will, as required, share your information to the following entities or data processors under the specified circumstances:
(i) To deliver notifications/alerts: Google Cloud Messaging (GCM) by Google LLC, Google Asia Pacific Pte. Ltd., Google Ireland Limited, Google Cloud India Pvt Ltd, Apple Push Notifications (APN) by Apple Inc., Pushbots, Inc., Amazon Web Services, Amazon Internet Services Private Ltd, Amazon Web Services, Inc. or its affiliates);
(ii) To communicate with You via email and SMS: Google LLC, Walkover Web Solutions Private Limited, Amazon Internet Services Private Ltd, Amazon Web Services, Inc. or its affiliates, MailChimp c/o The Rocket Science Group, LLC));
(iii) To provide security and data analysis: Google LLC, Google Asia Pacific Pte. Ltd., Google Ireland Limited, Google Cloud India Pvt Ltd;
(iv) To avail storage and cloud services: Google LLC, Google Asia Pacific Pte. Ltd., Google Ireland Limited, Google Cloud India Pvt Ltd, Amazon Internet Services Private Ltd, Amazon Web Services, Inc. or its affiliates;
14. Transfers and location for storage of information
The information provided by You to the Company shall be transferred and/or stored in USA, China (Taiwan, Hong Kong), Tokyo, Singapore, Australia, Finland, Belgium, UK, Germany, Netherlands, Canada and Brazil. You recognize that some of the jurisdictions that We transfer Your information to do not provide the same level of data protection as the country in which you reside and are not recognized by the European Commission as providing adequate level of data protection. We only transfer Your information to these countries since it is necessary for the Services We provide to You. The transfer of information is considered necessary in light of the better data security provided by the entities or data processors handling data in these countries. You agree that You are aware of the risks involved and have accordingly provided Your consent to the transfer of Your information to these countries.
15. Storage period
The information that You provide to the Company would be stored until you have an Account with Us or until such time as We are required to store the information to resolve disputes, enforce our agreements, and as required under any applicable law.
16. Individual rights
(i) Right to erasure: You shall have the right to request erasure of information concerning You held by the Company by withdrawing consent or if the information is no longer necessary for the purpose collected or under such other grounds as may be available under applicable law.
(ii) Right to restriction of processing: You shall have the right to restrict the Company from using or processing the information concerning You where the accuracy of the information is contested (in which case We may require You to give written evidence to that effect), or processing is unlawful or where it is no longer necessary for the Company for the purpose of processing.
(iii) Notification of erasure, rectification and restriction: We will communicate any rectification or erasure of Your personal information or restriction of processing to each recipient to whom Your personal information has been disclosed, unless this proves impossible or involves disproportionate effort.
(iv) Right to data portability: You shall have the right to receive the information concerning You, which was provided to the Company, in a structured, commonly used and machine-readable format and shall have the right to transfer the same to another entity where technically feasible.
(v) Right to object to processing: You shall have the right to object at any time to processing of personal information concerning You if such information is used for direct marketing purposes, including profiling.
(vi) Right not to be subject to a decision based solely on automatic processing: You shall have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning You or similarly significantly affects You. This is subject to exceptions under applicable law. In such cases where exceptions apply, You shall have the right to obtain human intervention on the part of the Company, to express Your point of view and to contest the decision.
(vii) Right to lodge a complaint: If You believe that We have infringed Your rights, You have the right to complain about Our processing of Your personal information to the relevant data protection authority. You can complain in the EU member state where You live or work, or in the place where the alleged breach of data protection law has taken place. Alternatively, You can also first contact us first at firstname.lastname@example.org so that We can try to address the issue internally.
You can exercise any of the abovementioned rights by writing to us at email@example.com
17. Contract Details
The Company is located at 600 NORTH BRIDGE ROAD #23-01 PARKVIEW SQUARE SINGAPORE (188778) and can be contacted via email at firstname.lastname@example.org.