B. In order to maximize your utility of our Website, our Content, our Site Services, App, our products, our other services, and respective content thereto, request information from us (whether online or offline, via App, the telephone, exhibitions, roadshows or other events), use our CoinAdBank API, list your Activity Post on our Website, take-part in our promotions (online or offline), subscribe and/or receive our Updates, and other related matters, your Personal Data (as defined in clause 1.2 below) has to be provided to us, and we will need to keep and use your Personal Data in order to fulfill the purpose for which you have contacted us, subscribed to our Updates and/or other services.
1. Types of Data Collected
1.1 When you visit, access or use our Website, App, Content, Site Services, and/or associated platforms, request for any Activity Post, register for any account, sign-up for any of our Updates, enter into a subscription, email us, call us, or take part in our promotions (offline or online), we collect Personal Data and Anonymised Data.
1.2 “Personal Data” refers to information, whether true or otherwise, with personal identifiers that can be used separately or collectively with other available (or accessible) information to identify an individual, such as name, address, NRIC number, mobile number, email address, birthdate, gender, income range, residency status, bank account details, and credit card details.
1.3 "Anonymised Data" refers to information that is not associated with or linked to your Personal Data and cannot be used to identify individual persons.
2. Collection of Anonymised Data
2.1 When you access our Website, Site Services, Content, App, and/or any of our online advertisements and banners, we collect Anonymised Data about you via the application of generally acceptable web technologies including but not limited to "web beacons", "cookies", "clear GIFs", "widgets", "online evaluations", "surveys", “HTML5”, “dynamic device identifiers”, and third-party web analytics such as "Google Analytics" (collectively, “Acceptable Technologies”). This automatic collection of non-personal information includes (without limitation) the collection of your IP Address, the web browser software that you used, the type of smartphone or tablet that you may be using, the operating software/platform of your device, your sign-up(s) for any Updates or information via our Website and/or Site Services, your general interest as indicated by the banners or advertisements that you click on, the specific pages of our Website viewed by you, the specific categories or features in our Website accessed by you, the sharing of any information by you via our Website, any third-party application used in conjunction with our Website or Site Services, your downloading of our App and APIs, and third-party websites that you may have visited prior to our Website. Our purpose for the aforesaid collection of information is for us to understand the preference of our visitors and users so as to enhance and facilitate the ease with which you are able to access or use our Website and our Site Services.
2.2 As part of the Anonymised Data that we collect, when you access our Website via your mobile device or tablet, we will also collect information regarding the type of mobile device or tablet that you are utilizing so that our Website, App, and/or Site Services can provide you with the version of our Website and/or App best suited for access on your mobile device or tablet.
2.3 If you do not consent to our collection of Anonymised Data, please adjust the settings on your computer, tablet, and mobile device to block or disable our use of the Acceptable Technologies. In the event that you choose to access our Website or our Site Services without blocking or disabling or opting out of the Acceptable Technologies, such access by you will constitute your consent to our use of the Acceptable Technologies and our collection of information thereto.
2.4 To better assist you in understanding the generally Accepted Technologies used in our collection of Anonymised Data include:-
2.4.1 “IP Address” refers to a number that is automatically assigned to your computer when you access the Internet. Under certain circumstances, your IP Address remains the same from browser session to browser session. However, in the event that a consumer Internet access provider is utilized your IP Address will likely vary from session to session. We track IP Addresses solely in conjunction with session cookies to analyze the flow of web pages on our Website.
2.4.2 “Cookies” refer to small pieces of data that a website sends to your computer’s hard drive or mobile device’s internal storage while you are viewing the said website. Our Website utilizes both session cookies (they expire the moment your Internet browser is closed) and persistent cookies (they will remain in your computer until you actively take steps to delete them) so as to provide you with a more personalized and interactive experience on our Website. By changing the options on your Internet browser and adjusting the settings in your mobile device (subject to your version of the operating system and your device’s features), you can control whether to accept or decline cookies.
2.4.3 “Clear GIFs” refer to clear electronic images that are used to track your opening of webpages on our Website and your pattern of browsing our webpages as well as your access of our Website, for the purpose of allowing us to assess the attractiveness of the content on our Website, and the flow of webpages and layouts that appeal to you. Clear GIFs are also commonly known as "web beacons" and may be included on our Website, and generally works in conjunction with cookies to identify users and user behavior. Some of our HTML-based emails also utilize Clear GIFs in order for us to assess what are the emails we sent that have been opened and acted upon. Clear GIFs collect only limited data, such as a cookie number, the time and date of when a particular webpage, feature, or service on our Website is accessed, and a description of the webpage, feature or service on our Website in which the clear GIF resides. Such collected Anonymised Data helps us to determine the effectiveness of the way our webpages, features, and services are arranged on our Website, our modes of communications, and promotional campaigns.
2.4.4 "Third-party web analytics" refers to services provided by third-party service providers for the assessment, analysis, measurement, and reporting of the behavior of visitors to a website in order to assess and improve the effectiveness of the website. One of the most well-known third-party analytics services is "Google Analytics".
2.4.5 “HTML5 local storage” refer to caching services utilizing primarily a cache manifest file, which allows for storage of your preferences offline which will then be updated and synchronized when you go online.
2.4.6 “Dynamic device identifiers” refer to “identifier for advertisers” or “IFA”, which is a random, anonymous number assigned to an end-user of the iPhone or iPad and is temporary, allowing it to be blocked like a cookie. When an end-user views an application or browses the internet, the end user's presence generates a call for an advertisement as the publisher’s site that the end-user is viewing will pass the IFA to the ad server and the advertiser is then able to serve the end-user with an advertisement relevant to the topic being viewed. IFA can also be used to identify whether the advertisements resulted in end-users downloading applications or purchasing products that were advertised. The IFA does not identify the end-user personally, it provides an aggregated audience data that advertisers can target with advertisements. IFA can be opted out of via the settings in the end user's device (by default, the IFA is enabled), subject to the availability of such options in the version of your operating system and the features of your device.
2.5 In the event that you decide at your sole discretion and risk to use any of the token swap functions made available via hyperlinks on our Site, your ETH Address will be exposed. If you do not accept the potential risk, please do not use any swap functions or perform any token swaps on our Site. For the avoidance of doubt, “ETH Address” refers to the address of your Ethereum wallet.
3. Your Consent to our Collection, Retention and Use of Personal Data
3.1 In order for our Company to provide you with our Site Services as well as information via our Website, App and other channels regarding our Site Services, Content, App, APIs, and other products and services, including but not limited to our updating you on the latest cryptocurrency related news and trading data or other information based on your request or online subscription with us, enabling you to sign up with us online, submit your form online to list your Activity Post, you're receiving our updates based on your indicated preferred channel and allowing you to contact us via our Website, App, email or telephone, you agree and consent to our Company collecting, using and retaining your Personal Data as follows:-
(i) When you submit a request for a listing of your Activity Post, sign up for our Updates, request to use our APIs, download and/or use our App, access our Website for information, register an account with us, subscribe to any of our Site Services, or your email or call us with any queries, you will be required to provide us with your Personal Data in order for us to register you for the uploading of your Activity Post to our Website, grant you permission to use our APIs, add you to our mailing list, enroll you for our Updates, services or events that you requested for, grant you permission to access certain restricted portions of our Website, to revert to your queries and/or to liaise with you in relation to your requests.
(ii) When you download our App, use any of our Site Services (including the CoinAdBank API and CoinAdBank videos on YouTube), access our Website, make any purchases via our Site, engage in token swaps, participate in our loyalty rewards program, redeem any loyalty points, register for any program, webinar, seminar, exhibition or other events, apply to upload your Activity Post(s) onto our Website, enroll for any services, loyalty program or Updates, enter into a subscription plan, or participate in promotions (offline and online) that we (or our other business partners) provide, we will require your Personal Data in order to keep a record of and provide you with the benefits that accompany your registration, usage of our Website, our Site Services, our APIs, any events, upload of your Activity Post onto our Website, subscription, service engagement, participation in the loyalty program and/or promotional campaigns (whether online or offline). Unless you withdraw your registration, subscription or enrolment, cancel your Activity Post listing with us, cancel your account with us, terminate any engagement of our Site Services, cancel your subscription for updates, withdraw from events that you have signed up for, cancel your access to our Website, cease all use of our Site and Site Services, cease all utilization of App and APIs, withdraw from our loyalty program or promotional campaigns, or our relevant promotional campaign ends, we will keep your Personal Data for as long as you still use our App, our APIs, access our Website or any of our Content, your Activity Post(s) is still listed on our Website, you are still a user of any of our Site Services, a participant of any of our events, a subscriber to or recipient of our Updates, our loyalty program and/or promotional campaigns (whichever is later) so that we can provide you with the relevant benefits. Accordingly, we will retain your Personal Data for as long as we are of the reasonable opinion that you may still be interested in any of our Site Services, APIs, Content, events, maintaining your Activity Post listing on our Website, our new products, and/or services so that our Company can be expeditious in the provision of information, our services or products whenever you should require information or seek to engage any of our services, use any of our products, request delivery of any of our products or our assistance. In the event that you notify us that you wish to terminate all access to our Website, App, Content, Activity Post listing, and events as well as ceasing all communications to and from our Company and terminating all engagement of our services (including all use of our APIs), we will keep your Personal Data only for as long as is necessary to fulfill legitimate business, legal, accounting and audit purposes, in relation to the Website and our operation of the associated business thereto. Thereafter, we will destroy your Personal Data.
(iii)When you click on any of our Company’s Google ads or other internet-based advertisements for more information regarding our Website, our App, our APIs, our Activity Post listing service, or our other Site Services, available Content, Updates, services, or products, we collect the Personal Data that you provide in order to follow up with you pertaining to your interest in the aforegoing.
3.2 In addition, we will retain your Personal Data where necessary and for such duration, as may be required in order for our Company to comply with applicable laws and regulations, assist in any legal investigations, meet the demands from any regulatory or law enforcement bodies, for utilization in legal proceedings, minimizing fraud, collection of debts, repayment of loans, resolving disputes, identifying issues, enforcing contractual breaches and/or claiming for damages.
4. Disclosure of Personal Data
4.1 We may need to disclose your Personal Data to:-
(i) third party service providers in order for us to facilitate your access to and use of our Website, our Site Services, our App, our APIs, token swap functionalities provided by third parties as made available on our Site, download Content, register for our events, list your Activity Post, participate in our promotions, participate in our loyalty points program, redeem your loyalty points for rewards, for us to contact you as you may have requested via our Website, email or telephone, for us to schedule and send on a regular basis to you our Updates, for us to maintain and update your records to ensure that you receive our replies to your queries, for us to follow up on any delivery of products or services that you may have requested for, and to provide you with any other updates and perks accompanying your registration to list your Activity Post, use our APIs, use or attend our events, engagement for our Site Services, participation in any loyalty programme and/or promotional campaigns. The aforesaid third-party service providers have a contract with us to perform the services necessary for you to use our Website, our Site Services, our APIs, list your Activity Post, receive Updates and/or our services or products that you might have requested, and such third-party service providers, therefore, include but are not limited to web hosts companies, website maintenance companies, database storage companies, cloud solutions providers, loyalty program service providers, app stores, platform maintenance providers, credit bureaus, payment solutions companies, credit card associations, financial institutions, companies that assist to perform mass mailing and/or mass messaging on our behalf, courier and logistics companies, etc.;
(ii) our third-party business partners who are providing discounts, vouchers, redemption items, and other privileges thereunder our loyalty rewards program/loyalty points scheme;
(iii) our book-keepers, accounting firms, audit firms, corporate secretarial firms, law firms, and/or other professional advisory firms who are maintaining our records in accordance with legal requirements;
(iv) governmental, regulatory, or law enforcement bodies who have a legal right to demand your Personal Data;
(v) credit bureaus, credit rating agencies, and fraud preventing companies for the purpose of minimizing fraudulent activities via your Personal Data; and
(vi) our affiliated or related companies and/or third parties to whom we may sell, divest, transfer, assign, share, or otherwise engage in a transaction that involves, some or all of our Company’s assets (which may include your Personal Data), in the course of a corporate divestiture, corporate restructuring, merger, acquisition, joint venture, trade sale, bankruptcy, dissolution, reorganization, or any other similar transaction or proceeding;
5. Transferring Personal Data out of Singapore
5.1 Pursuant to the purposes and activities as set out in sections 3 and 4 above, it may be necessary for us to transfer your Personal Data out of Singapore. You hereby agree and consent to the aforesaid transfer, on the understanding that the recipients of such Personal Data are also subject to applicable laws or contractual obligations similar to the obligations as set out in the Personal Data Protection Act 2012.
6. Accurate and Complete Personal Data
6.1 In order for us to provide you with access to our Website, our App, our APIs, our Site Services, our Content, our Updates, and all their respective associated functions, our services, and our products, and to perform the activities as set out in sections 3, 4 and 5 above, you warrant that the Personal Data that you provide to us is accurate and that all Personal Data as may be relevant for that particular purpose/circumstance has been provided. In the event of any changes or updates to your Personal Data, you undertake to promptly inform us in writing of such changes, failing which we shall not be responsible for any consequences thereto (including but not limited to your non-receipt of communications sent by us, non-completion of any transactions performed via our Website, inaccuracy of your listed Activity Post, inability to redeem your loyalty points, and/or your inability to access our Website).
7. Do-Not-Call ("DNC") Provisions and Registries
7.1 We respect your selections in relation to the channels via which you wish to receive our Updates. Therefore, if you have registered your telephone and/or fax number with the Do-Not-Call Registries in relation to telephone calls, text, or fax messages, we will not send you any Updates via the channels that you have opted out of by registering with the Do-Not-Call Registries. However, if you have previously consented to our sending you Updates via your telephone number (calls or text messages) and/or facsimile number, we will continue doing so until you withdraw your consent by contacting our Data Protection Officer at [email protected]
8. Withdrawal of Consent