1. Personal Data Collected by Company (hereinafter the “Personal Data”)
When you access any of the Services, the Company may collect the following categories of data from you or about you (which may be personal data as defined in section 2 of the PDPA):
- Contact information, such as name, email address, telephone and/or mobile phone number;
- Identification information, such as nationality, identification number and date of birth;
- Image information, such as selfie, photo of national ID card;
- Transaction information relating to his/her use of the Services including, without limitation, the User's transaction(s) with other Users, deposit and withdrawal;
- Device information, in particular as to the computer, device, or browser that you rely on in order to access or use the Services, operating system name and version, device manufacturer and model, language, Internet browser type and version, and the name and version of the Services you are using;
- Your IP address: The Company automatically logs your IP address (a number that is assigned to the computer that you use to access the Internet) in its server log files whenever you access or use the Services, along with the time of your visit and the page(s) that you visited;
- Account information, being information that is generated by your account activity including, but not limited to, trading activity, order activity, deposit, withdrawal, and account balances;
- Correspondence, being information that you provide to use in correspondence, including during the opening the account, and ongoing customer support; and
- Cryptocurrency wallet address.
In addition to the foregoing, you may also be required to provide additional Personal Data when you, amongst others, require support, send us information for troubleshooting or other analysis, participate in a survey or other promotional activities of the Company or solicit any other communication from the Company.
The User may decide whether or not to submit any Personal Data required by the Company. The User should ensure that all Personal Data submitted to us is complete, accurate, true and correct. Failure on the User’s part to do so may result in our inability to provide the User with the Services the User has requested.
Additionally, the Company may also be provided User’s Personal Data by LINE Affiliates to the extent necessary for the provision of Services by the Company.
2. Cookies and Similar Technology
Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site.
The service providers of the Company may also place cookies on the hard drive of your device with a view to receive information that will educate the Company and the Company’s service providers on different aspects, such as how you use the Services. The Company’s service providers may analyse these data with a view to allow us to better understand your interests in the Services and to better serve those interests.
You can choose to deactivate cookies, however in such circumstances you will not be able to use parts of the Services which require cookies to be active.
3. Use of Google Analytics
The Company may also use a tool called “Google Analytics” to collect information about use of the Services. Google Analytics collects information such as how often users visit the Services, what pages they visit when they do so, and what other sites they used prior to coming to the Services. We use the information we get from Google Analytics only to improve our Services. Google Analytics collects only the IP address assigned to you on the date you visit the Services, rather than your name or other identifying information. We do not combine the information collected through the use of Google Analytics with personally identifiable information.
4. Purpose for Collection, Use and Disclosure of User Information
The Company may collect, use and disclose the User’s Personal Data for the following purposes, including but not limited to:
- To provide better Services:
- to offer undisturbed and smooth Services to the User (including, without limitation, software upgrades and improvements of the Services);
- to ensure that the Services are functioning properly;
- to administer the Company Website and Company App and to track user movement;
- to test, assess, or otherwise evaluate the effectiveness of the technical and organizational measures (which ensure the security of the processing of your Personal Data) put into place by the Company or by the Company’s outsourced contractors;
- to personalize your experience by presenting content tailored to your interests;
- to allow you to participate in usability studies, surveys and product tests;
- to aggregate statistical data regarding the Services;
- to conduct research and analysis aimed at reviewing and improving Services;
- for troubleshooting purposes;
- for the Company’s business purposes, such as performing data analysis and audits, improving or developing new features or services relating to the Services or for the business purposes of the Company undertaking;
- to develop new features to the Services or other products offered by the Company undertaking; and/or
- to provide Customer Services to the User (including, without limitation, processing claims relating to purchased items and the Services);
To protect your rights and data:
- to prevent any unauthorized/fraudulent use of the Services;
- to allow you to manage your account;
- to perform identity verification when a User makes an inquiry or gives an instruction to the Company;
- to respond to your inquiries and support needs and to fulfil any other request you may have sent to the Company;
- to notify the User of any other important information regarding the Services and to contact the User where necessary;
- to prevent, detect and investigate crime and analyze and manage commercial risks and conducting investigations relating to disputes, billing or fraud;
- to detect, prevent, investigate or report actual or potential violations of the Policies or any suspected illegal activities;
- to prevent physical harm or financial loss or any other risk for the Company, any of the Company’s service providers or any other individual involved in the provision of the Services;
- to prevent any data breach or circumvention of the Company’s security measures or to mitigate any possible adverse effects from such activities;
- to protect rights, privacy, safety and property of you; and/or
- to enforce the Policies;
To protect Company’s assets:
- in connection with any claims, actions or proceedings (including but not limited to drafting and reviewing documents, transaction documentation, obtaining legal advice, and facilitating dispute resolution), and/or protecting and enforcing the Company’s contractual and legal rights and obligations;
- to protect the Company and its operations or those of the Company service providers;
- to protect the rights, privacy, safety and property of the Company, the Company’s service providers; and/or
- to allow the Company to pursue available remedies or limit the damages that the Company or its service providers may sustain;
To comply with legal requirements:
- to respond to a verified request relating to a criminal investigation (e.g. subpoena, court order or substantially similar legal procedure) or alleged illegal activity or any other activity that may expose the Company or any of the Company’s service providers or you to any legal proceeding or legal liability;
- to meet or comply with any applicable rules, laws, regulations, codes of practice or guidelines issued by any legal or regulatory bodies which are binding on the Company (including but not limited to responding to regulatory complaints, disclosing to regulatory bodies and conducting audit checks, due diligence and investigations); and/or
- to respond to requests from public and government authorities, including public and government authorities outside your country of residence; and
- To conduct any other activities that are required to provide the Services.
- To provide better Services:
5. Information Delegation
- it is necessary for the conclusion or the performance of a contract or for the provision of the Services;
- it is required by law or by virtue of public interest;
- it is required by virtue of your vital interest;
- it is necessary to pursue the Company’s legitimate purposes;
- you have given your consent (e.g. when exercising your right to data portability);
- so allowed to by other legal bases.
The User acknowledges and agrees that the Company may conduct a merger, spin-off, business transfer or any other transaction, whereby the Personal Data that the Company collected from the User may be transferred to a third party.
6. Shared Use of Information
During the period when the User uses the Services, the User's Personal Data may be processed and used in the form(s) of printed documents and/or electronic files or otherwise by the Company, the LINE Affiliates and other third party service providers within and/or outside Singapore.
7. User's Rights
The User may, at any time, confirm, supplement or correct his or her registered Personal Data on the Services. The User can also deactivate his or her accounts for the Company.
When the User requests access to his or her Personal Data (including copies of his or her Personal Data) that the User is unable to confirm/access through the Services, the Company may charge the User a fee for the disclosure procedures.
The User can choose freely whether or not they will provide the Company with his or her Personal Data, however the User may be unable to use a part of the Services until they have provided the Company with the necessary information.
8. Withdrawal from the Services
If the User withdraws his or her consent to any or all use of his or her Personal Data, depending on the nature of the request, the Company may not be in a position to continue to provide its Services to the User or administer any contractual relationship in place, which in turn may also result in the termination of any agreements with the Company, and the User being in breach of his or her contractual obligations or undertakings. The Company’s legal rights and remedies in such event are expressly reserved.
9. A Special Note about Personal Data of Minors
Minors who lack the legal capacity to contract under any applicable laws shall not use the Services.
The Company will take stringent measures to protect Personal Data from outside attacks or threats, but Personal Data is always at risk from such attacks and threats. The Company does not provide any guarantee regarding the effectiveness of these protective measures or our ability to prevent other parties, acting unlawfully, from gaining access to information.
14. Applicable law & jurisdiction