- 1.Definitions of Personal Data
- “Personal Data” refers to any data, whether true or not, about an individual who can be identified (a) from that data; or (b) from that data and other information to which we have or are likely to have access, including data in our records as may be updated from time to time.
- Examples of such Personal Data you may provide to us include (depending on the nature of your interaction with us) your name, passport or identification number, location data, telephone number(s), email address and any other information relating to any individuals which you have provided us in any forms you may have submitted to us (including in the form of biometric data), or via other forms of interaction with you.
- 2. Personal Data We Collect
- Generally we collect Personal Data collected for you via your use of Service on the Site.
a) when you establish an account on the Site in order to get access to the Platform;
b) when you use our electronic services, or interact with us via the Site or use services on the Site;
c) when you submit any form, including but not limited to application, declaration, proposal or referral forms;
d) when you enter into any agreement or provide other documentation or information in respect of your interactions with or transactions on the Platform;
e) when you interact with our staff, including customer service officers, relationship managers and other representatives, for example, via telephone calls (which may be recorded), letters, fax, face-to-face meetings and email;
f) when you request that we contact you, be included in an email or other mailing list; or when you respond to our request for additional Personal Data, our promotions and other initiatives;
g) when you are contacted by, and respond to, our marketing representatives and agents and other service providers;
h) when you submit an employment application or when you provide documents or information including your resume and/or curriculum vitae in connection with any appointment as an officer, director, representative or any other position;
i) when we seek information about you and receive your Personal Data in connection with your relationship with us, including for banking products, insurance policies or job applications, for example, from business partners, public agencies, your ex-employer and the relevant authorities; and/or
j) when you submit your Personal Data to us for any other reason.
- When you browse our website, you generally do so anonymously but please see the section below on cookies.
- If you provide us with any Personal Data relating to a third party (e.g. information on your customers, spouse, children, parents, and/or employees), by submitting such information to us, you represent to us that you have obtained the consent of such third party to you providing us with their Personal Data for the respective purposes.
- You should ensure that all Personal Data submitted to us is complete, accurate, true and correct. Failure on your part to do so may result in our inability to provide you with products and services you have requested, including termination of your access to the Site and the Platform
- 3. Purposes For Information Processing
- We use and process Personal Data and information to create, develop, operate, deliver, and improve our Services, Content and advertising, for loss prevention and mitigating against the risk of fraud and Losses. Subject to the specific consent of the Applicants / Users in circumstances where the Company has no other lawful basis for processing the relevant Personal Data under Applicable Law, the Company shall process and use Applicants' / Users' and applicable Related Third Parties' Personal Data for the purposes described below:
1.Compliance with Applicable Law and Regulatory requirements:
Some of the Services are subject to Applicable Laws and regulations requiring us to collect and use your Personal Data, including your identification information, formal identifying document, financial, transactional and employment information, online identifiers, or the usage of data for certain purpose. For example, the Company is required to identify and verify the Applicants' / Users' identity (and where applicable, the identity of Relevant Third Parties) to comply with and mitigate risks against money laundering and terrorist financing laws across jurisdictions. Accordingly, the Company conducts know your customer (KYC), anti-money laundering (AML), countering the financing of terrorism (CFT) and any other applicable fiscal and tax requirements and controls, including using third parties to verify Applicants' / Users' identity (and where applicable, the identity of Relevant Third Parties) by comparing the Personal Data provided against third-party databases and public records. The Company handles personal and sensitive information, such as your identification and financial data, so it is vital for all our Users and us that we conduct surveillance, investigation, prevention and mitigation of risks against any prohibited or illegal activities. In other instances, we need to establish the User's basic competency when using the Services (such as legal age, nationality, existing sanctions) and to prevent the use of Services by illegitimate users. To provide you with the Services, we will need to comply with Applicable Laws and regulatory requirements, which require us to process your Personal Data in the manner set out above.
2.To fulfil our contractual obligations (including enforcing terms in User Agreement)
In addition to process application for registration of a User Account and the use of Services, we may also need to collect fees, charges and taxes (including GST) based on your use of our Services. We receive information about your account usage and closely monitor your interactions with our Services. We may use any of your Personal Data and information collected on our Services for these purposes. To facilitate the provision of the Services, including when Users want to buy or sell Crypto Assets, conduct settlement of the Transactions and payments of the Crypto Assets or carry out acts that are necessary or incidental to the Services, we require to process specific information such as your identification, contact information, payment information and verification checks. To provide you with the Services and comply with our contractual obligations and enforce our agreements with third parties, we need to process your Personal Data in the manner set out above.
3.Communications relating to Services
To keep you updated about our Services, any security matters, Account-related information, Transactions executed, we process your Personal Data and communicate to you on such issues, so you may be aware of significant developments relating to your Account that may affect how you can use our Services. Additionally, we are required under the User Agreement to provide notification, announcements and other communications to the Applicants/Users. We cannot perform our Services and comply with our terms and operational requirements without processing your Personal Data in the manner set out above.
4.Providing User or Customer Support services
We need to access your Personal Data when you contact us to resolve any inquiry, questions or complaints, deal with disputes, collect fees, or to troubleshoot problems. We may also process your information in response to another User's request, if directly relevant. We cannot respond to your requests and ensure your uninterrupted use of the Services without processing your Personal Data.
5.Quality control for Services
We process your Personal Data or information for quality control and staff training to make sure we continue to provide you with current, updated and accurate information. The basis for processing your Personal Data and information is to perform our contractual obligations to you. If we do not process Personal Data or information for quality control purposes, you may experience issues on the Services such as inaccurate transaction records or other interruptions.
6.Network and Information Security
Considering cyber and internet related IT security risks, we process your Personal Data or information to enhance security, monitor and verify identity or service access, combat spam or other malware or security risks and to comply with Applicable Laws and regulations relating to Information Technology security. The threat in the digital landscape and the internet is considerable and continually evolving, which makes it even more important, that we have complete, accurate and up-to-date information about you and your use of our Services. Without processing your Personal Data, we may not be able to ensure that your use of our Services is as safe and secure, as it needs to be. Accordingly, we analyze service use logs, access frequency, and statistics on the use of Services by Users and develop a service environment to protect Applicants' / Users' privacy better and also offer tailor-made Services.
7.Research & Development
We may process your Personal Data to understand better the way you engage, use and interact with the Services. We use such information to customize, measure, improve our Services and to improve the Content, user interface and experience of chainb Site and its applications. We are also continually working on improving and developing new products and services, to better serve our Users. We process Personal Data based on our legitimate interests in promoting the Services towards your legitimate interests and continuing use of our Services.
8.Enhancing chainb Site‘s User Experience
We process your Personal Data or information to provide a tailor-made, personalized experience, and implement the preferences you request. For example, you may choose to give us access to certain Personal Data and information concerning your Related Third Parties. Without such processing, we may not be able to ensure your continued enjoyment and use of part or all of our Services.
9.Facilitating Corporate Acquisitions, Mergers, or Re-Organizations
In the event the Company were to be involved in corporate acquisitions, mergers, or reorganizations, we may process Users' Personal Data to the extent necessary to facilitate the transaction according to our legitimate interest.
10.Engaging in marketing activities
Based on your communication preferences and consent provided, we may use your Personal Data (information about your usage of our Services and your contact information) to deliver targeted marketing and promotional offers and send you marketing communications about our promotional events and partners' marketing events. If you do not wish to receive such marketing communications about our or our partner's marketing events, you can opt-out of our marketing communications at any time by withholding your consent when requested or contacted by our Customer Support to withdraw any prior consent provided.
- 4. Disclosure of Personal Data
- chainb will take reasonable steps to protect your Personal Data against unauthorized disclosure. Subject to the provisions of any applicable law, your Personal Data may be provided, for the purposes listed above (where applicable), to the following entities or parties:
1.Chainb’s affiliates or related corporations;
2.counterparties and their respective banks in relation to fund transfers, payments, drawing of cheques, and other transactions;
3.agents, contractors or third party service providers who provide operational services to chainb such as courier services, telecommunications, information technology, payment, payroll, processing, training, market research, storage, archival, customer support investigation services or other services to chainb;
4.vendors or other third party service providers in connection with promotions and services offered by chainb;
5.credit reporting agencies;
6.any business partner, investor, assignee or transferee (actual or prospective) to facilitate business asset transactions (which may extend to any merger, acquisition or any debt or asset sale) involving chainb;
7.external banks, credit card companies and their respective service providers;
8.our co-brand and other business partners, to the extent applicable;
9.our professional advisers such as our auditors and lawyers;
10.relevant government regulators, government ministries, statutory boards or authorities and/or law enforcement agencies, whether local or overseas, including the Monetary Authority of Singapore, the Accounting and Corporate Regulatory Authority of Singapore, the Securities and Exchange Commission of the United States, and other applicable governmental agencies, to comply with any directions, laws, rules, guidelines, regulations or schemes issued or administered by any of them;
11.surveyors, auctioneers, valuers or other third parties in relation to loans and other credit facilities such as mortgages;
12.brokerage houses, Central Depository (Pte) Limited, fund houses, registrars, custodians, nominee banks, external banks and investment vehicles in relation to asset management and investment product settlement processing;
13.to the extent applicable, any swap repository, trade data repository, reporting agent, clearing house, centralized clearing party (including any clearing member of such clearing house or centralized clearing party), clearing broker, multilateral or other trading facility, system or platform or such other communication network or auction facility; and/or
14.any other party to whom you authorize us to disclose your Personal Data to.
- 5.Cookies Usage
• When you interact with us on the Site, we automatically receive and record information on our server logs from your browser.
We may employ cookies in order for our server to recognize a return visitor as a unique user including, without limitation,
monitoring information relating to how a visitor arrives at the website, what kind of browser a visitor is on, what operating
system a visitor is using, a visitor’s IP address, and a visitor’s click stream information and time stamp (for example,
which pages they have viewed, the time the pages were accessed and the time spent per web page).
• Cookies are small text files stored in your computing or other electronic devices which allow us to remember you or other data about you. The cookies placed by our server are readable only by us, and cookies cannot access, read or modify any other data on an electronic device. All web-browsers offer the option to refuse any cookie, and if you refuse our cookie then we do not gather any information on that visitor.
• Should you wish to disable the cookies associated with these technologies, you may do so by changing the setting on your browser. However, you may not be able to enter certain part(s) of the Site.
- 6.Data Security
• chainb will take reasonable efforts to protect Personal Data in its possession or its control by making reasonable security
arrangements to prevent unauthorized access, collection, use, disclosure, copying, modification, disposal or similar
risks. However, we cannot completely guarantee the security of any Personal Data we may have collected from or about
you, or that for example no harmful code will enter the Site (for example viruses, bugs, trojan horses, spyware or adware).
We are not responsible for the intentional or criminal acts of third parties such as hackers or “phishers.” You should
be aware of the risks associated with using the Site.
• While we strive to protect your Personal Data, we cannot ensure the security of the information you transmit to us via the Internet or when you access the Platform via mobile phones, and we urge you to take every precaution to protect your Personal Data when you use such platforms. We recommend that you change your passwords often, use a combination of letters and numbers, and ensure that you use a secure browser.
• If applicable, you undertake to keep your username and password secure and confidential and shall not disclose or permit it to be disclosed to any unauthorized person, and to inform us as soon as reasonably practicable if you know or suspect that someone else knows your username and password or believe the confidentiality of your username and password has been lost, stolen or compromised in any way or that actual or possible unauthorized transactions have taken place. We are not liable for any damages resulting from any security breaches, on unauthorized and/or fraudulent use of your username and password.
- 7.Third-Party Sites
- 8.Contacting Us - Feedback, Withdrawal of Consent, Access and Correction of your Personal Data
consent to any or all use of your Personal Data granted by you, you can email us at [email protected]
• If you withdraw your consent to any or all use of your Personal Data, depending on the nature of your request, chainb may not be in a position to continue to provide its products or services to you, administer any contractual relationship already in place. This may also result in the termination of any agreements you have with chainb, and your being in breach of your contractual obligations or undertakings. Chainb’s legal rights and remedies in such event are expressly reserved.
- 9.Governing Law and Arbitration
- 10.Effective Time