1. ETHEREUM SG AS THE DATA CONTROLLER
2. GENERAL DEFINITIONS
3. HOW WE COLLECT YOUR PERSONAL DATA
3.1 We receive your Personal Data when you:
3.2 In connection with the Services, and to the extent permitted by applicable laws (including Data Protection Laws), we may also be collecting from sources other than yourself, your Personal Data, for one or more of the Purposes, and thereafter using, disclosing and/or processing such Personal Data for one or more of the Purposes.
4. TYPES OF PERSONAL DATA WE COLLECT
4.1 In connection with your use of the Website(s) or the Services, we may collect the following Personal Data from you:
4.2 Note on collection of your national identification number (e.g. NRIC for Singapore Users): We are fully aware of the sensitive nature of your national identification number, and we only collect, use and disclose such information to the extent necessary under applicable laws and regulations, as well as in order to accurately establish and verify your identity to a high degree of fidelity. Please refer to the sections below for further information on how we use, disclose and maintain your Personal Data.
5. HOW WE PROCESS AND USE YOUR PERSONAL DATA
5.1 We may process and use your Personal Data for the following purposes:
5.2 Our legal basis to process and use the Personal Data of Users as the Data Controller is where:
5.4 Your Personal Data is processed at Ethereum SG’s operating offices and in any other places where the parties involved in the processing are located. Depending on the User’s location, transfers of Personal Data may involve transferring the User’s Personal Data to a country other than their own.
6. HOW WE DISCLOSE OR EXPORT YOUR PERSONAL DATA
6.1 We may need to disclose your Personal Data to trusted third-parties, whether located within or outside Singapore, for one or more of the Purposes, as such third-parties, would be processing your Personal Data for one or more of the above Purposes (“Third-Party Processors”). In this regard, you hereby acknowledge, agree and consent that we are permitted to disclose your Personal Data to such Third-Party Processors (whether located within or outside Singapore) for one or more of the above Purposes and for the Third-Party Processors to subsequently collect, use, disclose and/or process your Personal Data for one or more of the above Purposes. Without limiting the generality of the foregoing, such Third-Party Processors include:
6.2 Where we disclose your Personal Data, we will do so only in accordance with Data Protection Laws. This includes taking steps to ensure the security and privacy of your Personal Data, and where required, it will be subject to contractual terms ensuring the security and protection of any Personal Data under any sub-processor or data intermediary, whether within or outside of Singapore.
7. HOW WE MAINTAIN YOUR PERSONAL DATA
7.1 Security of your Personal Data is important to us. We will put in place reasonable security arrangements to ensure that your Personal Data is adequately protected and secured. Appropriate security arrangements will be taken to prevent any unauthorised access, collection, use, disclosure, copying, modification, leakage, loss, damage and/or alteration of your Personal Data. However, we cannot assume responsibility for any unauthorised use of your Personal Data by third-parties which are wholly attributable to factors beyond our control.
7.2 We will put in place measures such that your Personal Data in our possession or under our control is destroyed and/or anonymised as soon as it is reasonable to assume that (i) the purpose for which your Personal Data was collected is no longer being served by the retention of such Personal Data; and (ii) retention is no longer necessary for any other legal or business purposes.
8.1 We may also obtain information about your use of the Website(s) and the Services through the use of ‘cookies’ which enable us to make certain parts of the Website(s) easier to use and to improve the Website(s) and the Services generally.
8.2 A cookie is a small file which asks permission to be placed on your device’s hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular website or web-based application. Cookies allow web-based applications to respond to you as an individual. The website or web-based application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.
8.3 We may use traffic log cookies to identify which pages are being used. This helps us analyse data about web-based traffic and improve the Website(s) and the Services in order to tailor it to user needs. If we do use such cookies, we will only use this information for statistical analysis purposes and then the data is removed from the system thereafter.
8.4 Overall, cookies help us provide you with a better Website(s) and better Services, by enabling us to monitor which sections you find useful and which you do not. A cookie in no way gives us access to your device or any information about you, other than the data you choose to share with us.
8.5 You can generally choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. However, some cookies are essential and some websites or web-based applications (such as automatic user logins) won’t operate as expected without them and some features of the website or web-based application may not be available.
9. WHERE YOU PROVIDE US WITH THIRD-PARTY PERSONAL DATA
9.1 You should only provide us with Personal Data of third parties where expressly permitted under the Terms of Service. Should you provide us with Personal Data of any individual other than yourself, you represent, undertake and warrant to us that:
10. THIRD-PARTY LINKS
10.1 The Website(s) may contain links to third-party websites and applications whose data protection practices may differ from ours. We are not responsible for the content and privacy policies of these third-party websites and applications, and we encourage you to consult their privacy policies before accessing or using the third-party websites and applications.
11. YOUR RIGHTS IN RESPECT OF YOUR PERSONAL DATA
11.3 We may be prevented by law from complying with any request that you may make. We may also decline any request that you may make if the law permits us to do so.
11.5 We may charge you a fee for responding to your request for access to your Personal Data which we hold, or for information about the ways in which we have (or may have) used your Personal Data. If a fee is to be charged, we will inform you of the amount beforehand and respond to your request after payment is received.
12.2 Should the changes affect the processing activities performed on the basis of the User’s consent, Ethereum SG shall collect consent from the User, where required.
LIST OF THIRD PARTY PROCESSORS
Last updated: [26 July 2023]