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TERMS OF USE

(Last Modified: 1 July 2024) 

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  1. Introduction

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  1. These Terms of Use (“Terms”) form a contract between you (“your” or “User(s)”) and Solutions Lab Pte. Ltd. (the “Company”, “us”, “we” or “our”), a company incorporated in Singapore, and governs your access to and use of the Blockchainspace Website (“Website”). The Website includes the website (www.blockchainspace.asia), the browser plug-in, mobile applications, APIs, documentation, software, updates, features, tools, and any materials made available from time to time by us. 

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  1. By using, visiting or accessing the Website (where applicable), you agree to accept and be bound by the terms and conditions set out in these Terms and the policies referenced herein and/or available by hyperlink. Please read these Terms carefully and in its entirety. You acknowledge and agree that our provision of the Website and related services to you is conditional on your agreement to these Terms. 

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  1. You agree that you have accepted our Terms and Privacy Policy, and other terms that may be displayed to you at the time you access the Website.  

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  1. Definitions and Interpretation 

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  1. In these Terms, unless the context otherwise requires, the following words and expressions shall have the following meanings:

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“Intellectual Property Rights” includes all the worldwide rights, titles and interests including but not limited to copyright and related rights, trade marks, business names and domain names, rights in get-up, goodwill and the right to sue for passing off, rights in designs, rights in software, database rights, rights in confidential information (including know-how), patents, rights to inventions, trade secrets, and all other intellectual property and similar rights which subsist or will subsist now or in the future in any part of the world;

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“Personal Data” means 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;

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“Privacy Policy” means our privacy policy located at [insert link];

“Third Party Service Provider(s)” means any third party service provider which provides services which are necessary in order for us to operate the Website and/or provide any associated services to you and any third party service provider which we engage in relation to the storage and/or processing of content and Personal Data;

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“Third Party Services” means any services provided to you by Third Party Service Providers;

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“User” means any person that uses the Website; and

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“User Content” means all content that the relevant User may submit to the Website or otherwise transmit via the Website.

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  1. Eligibility, Personal Data and Security

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  1. Eligibility

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You confirm that:

  1. you are at least 18 years old, and have the legal age of majority in your jurisdiction as is required to access our Website; 
  2. you have not been restricted by us in using the Website; and 
  3. you are otherwise fully able and competent to accept, abide and comply with these Terms of Use.

 

  1. Personal Data 

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Save that we will comply with all applicable law relating to data privacy (including the Personal Data Protection Act 2012 of Singapore), nothing in these Terms shall be deemed to impute an obligation of confidentiality on us with respect to your registration information. If required by law (including a court order and a government or regulatory demand or requirement having the force of law), we will disclose such information, including but not limited to your registration information, as so ordered.

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  1. Security

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For security purposes, including the investigation of whether any User is using the Website for fraud, money laundering, insider trading and/or other unlawful activity, we have the right, and sole discretion, to immediately:

  1. restrict your access to the entire Website or parts thereof;
  2. report your activity to the relevant law enforcement officials and provide evidence in support for such officials to conduct their investigations; and/or
  3. take any action which we deem appropriate to the circumstances.

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  1. Anti-Money Laundering Provisions

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  1. We reserve the right, at any time to: 

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  1. require you to provide additional information and documents at the request of any competent authority or in accordance with any applicable laws and regulations in relation to anti-money laundering or combating the financing of terrorism;

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  1. share submitted information and documentation with third parties to verify the authenticity of the submitted information and you agree to this by using the Website; and

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  1. withhold, suspend, restrict or terminate your access to the Website or any transactions carried out by you (whether partially or fully completed) on the Website, if you do not promptly provide us with the requested information or upon our discovery of any actual or suspected fraudulent activity, money laundering, criminal activity, and/or acts that are contrary to these Terms.

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  1. You have the sole responsibility of ensuring that you have the legal rights in accordance with applicable laws to engage in any and all transactions carried out on this Website. To make sure all transactions (where applicable) are legally compliant, we may, but we are not obliged to, review the legality of the transactions carried out by you and take necessary actions in accordance with applicable laws and regulations.

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  1. Third Party Service Providers

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  1. You acknowledge that we may incorporate the services of Third Party Service Providers to assist in providing any services to you on the Website and/or to enhance the Website. You hereby consent and authorise us to delegate the authorisations you provide to us to such Third Party Service Providers as we deem necessary to provide any services to you and/or to operate the Website. 

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  1. You acknowledge that your use of Third Party Services will require your agreement to certain additional terms and conditions provided by the applicable Third Party Service Provider. By using such Third Party Services (whether linked from our website, or otherwise presented to you for your use via our Website), you hereby agree to the applicable terms of service and privacy policies (as the case may be) of such Third Party Service Providers, including without limitation, any fees that may be charged by such Third Party Service Providers for such use.

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  1. You agree that we are not in any way responsible or liable for the services and content offered by them or for anything in connection with such Third Party Services. Notwithstanding the fact that such Third Party Services may be accessible via our Website, we do not endorse or approve and make no warranties, representations or undertakings relating to the service or content of any Third Party Services. You acknowledge and agree that we may earn fees from Third Party Service Providers in connection with your use of such Third Party Services. 

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  1. You acknowledge and agree that we shall not be responsible or liable, directly or indirectly, for any damage or loss suffered by you caused or alleged to be caused by or in connection with your use of or reliance on any Third Party Service Providers and/or Third Party Services including without limitation, any damage or loss arising in relation to: 

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  1. your use or access of Third Party Services (whether incorporated into our services, accessed via our Website or otherwise);
  2. any information that you may provide to such Third Party Service Providers;
  3. any transaction conducted with or through the Third Party Services;
  4. any failure of any information, software or services posted or offered by such Third Party Service Providers; 
  5. any error, omission or misrepresentation by such Third Party Service Providers; or
  6. any computer virus arising from or system failure associated with the Third Party Services.

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  1. Further, you hereby expressly waive and release any and all claims, actions or otherwise which you have or may in the future have against the Company, its affiliates, and their respective directors, officers, employees, agents, representatives, shareholders, successors and assigns which may arise from your use of or reliance on any Third Party Service Providers and/or Third Party Services, including any of the circumstances set out in Clause ‎6.4, sub-paragraphs ‎6.4.1 to ‎6.4.6 (inclusive).

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  1. Our Intellectual Property Rights

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  1. We, or our licensors (as the case may be), own all Intellectual Property Rights in our content on/ used in relation to the Website. You can only use our Intellectual Property Rights for the specific purpose of using the Website.

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  1. You acknowledge that the Website, our content are protected by copyright, trademark, and other applicable laws. You agree not to remove, alter or obscure any copyright, trademark, service mark or other proprietary rights notices incorporated in or accompanying the Website, our content.

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  1. These Terms do not convey any proprietary interest in or to our Intellectual Property Rights.

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  1. User Content. You may provide, submit, upload, make available or transmit your User Content to us for the purpose of it being used on the Website, or for use by any Third Party Service Providers. This may arise, for example, when you submit your feedback to us. You have and will retain sole ownership rights to all of your User Content. However, notwithstanding the termination of these Terms, when you submit your User Content to us, you hereby grant us a perpetual, non-exclusive, worldwide, royalty-free, sub-licensable, transferable right and license to use, access, host, store, cache, reproduce, publish, display, distribute, perform, transmit, modify, adapt, and create derivative works of your User Content, without any further consent, notice and/or compensation to you or others, subject to the relevant legislations and the Privacy Policy.

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  1. User Conduct 

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  1. You warrant that you will comply with any and all rules, regulations and/or applicable laws and regulations governing the practice of law in your jurisdiction in connection with the use of the Website. 

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  1. You agree not to: 

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  1. impersonate another person or User;

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  1. use the Website other than as authorised and in accordance with these Terms;

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  1. copy our content for any purpose that is not envisaged within these Terms;

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  1. copy, modify, translate or create derivative works of our content or the Website or any part thereof; 

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  1. where applicable, send spam, unwelcomed communications, or material that is against public interest, order, national harmony or offends good taste and decency, to others, or act in an unlawful, defamatory, libelous, abusive, discriminatory or otherwise objectionable manner as determined by us, through the use of our Website;

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  1. use any device, software, routine or use the Website in any way that interferes with any application, function, or use of the Website, that is intended to damage, detrimentally interfere with, surreptitiously intercept, or expropriate any system, data, or communication, including but not limited to our security mechanisms of the Website; 

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  1. reformat, frame or mirror the Website;

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  1. decompile, disassemble or reverse-engineer the underlying software or application that is part of the Website or otherwise attempt to derive its source code; 

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  1. use the Website either directly or indirectly to support any activity that is illegal, fraudulent, abusive and/or amoral including but not limited to violating our Intellectual Property Rights or that of others; 

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  1. use the Website in such a way or attempt to commercially exploit any part of the Website without our permission, including without limitation, to modify any of the Website’s content in any way, or copy, reproduce, publicly display, distribute or otherwise use or communicate them for any public or commercial purpose without our permission;

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  1. access and/or use the Website for the purposes of monitoring its availability, performance or functionality, or for any other benchmarking or competitive purposes; and 

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  1. authorise any third parties to do any of the above.

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  1. Indemnification by the User 

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  1. To the fullest extent permitted by applicable law, you agree to indemnify, defend and hold harmless the Company from and against all actual or alleged third party claims, damages, awards, judgments, losses, liabilities, obligations, penalties, interest, fees, expenses (including, without limitation, attorneys’ fees and expenses) and costs (including, without limitation, court costs, costs of settlement and costs of pursuing indemnification and insurance), of every kind and nature whatsoever, whether known or unknown, foreseen or unforeseen, matured or unmatured, or suspected or  unsuspected, in law or equity, whether in tort, contract or otherwise (collectively, “Claims”), including, but not limited to, damages to property or personal injury, that are caused by, arise out of or are related to:

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  1. your use or misuse of the Website or the content on the Website,
  2. your violation of these Terms; 
  3. your violation of the rights of a third party (including their Intellectual Property Rights); and/or 
  4. your violation of any terms and conditions of Third Party Service Provider that you have agreed to or whose services you have used or accessed. 

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  1. You agree to promptly notify the Company of any third party Claims and cooperate with the Company in defending such Claims. You further agree that the Company shall have control of the defense or settlement of any third party Claims. This indemnity is in addition to, and not in lieu of, any other indemnities set forth in a written agreement between you and the Company.

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  1. Except where otherwise provided in these Terms, where you have incurred any liability to us, whether arising from or under these Terms or otherwise, howsoever arising, we may without notice to you, set-off the amount of such liability against any liability of us to you arising from or under these Terms, whether either such liability is liquidated or unliquidated, present or future, accrued or contingent.  

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  1. Disclaimers

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  1. Unless expressly provided for in writing by the Company, the Website is provided by us on an ‘as is’ and ‘as available’ basis without warranties or conditions of any kind, either express or implied. Your reliance on any information provided to you via the Website is entirely at your own risk and we reserve the right to remove any content from the Website at any time, for any reason, without notice. You acknowledge and agree that the Company shall not be liable for any damages arising from such removal.

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  1. Access to the Website

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  1. We will endeavour to the best of our abilities, within commercially reasonable means, to ensure that the Website is available at all times. 

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  1. Notwithstanding the foregoing, we: some text
    1. do not warrant that your use of the Website will be uninterrupted, error-free or bug-free or that the Website will meet your requirements; 
    2. are not responsible for any delays, delivery failures, or any other loss or damage resulting from the transfer of data over communications networks and facilities, including the internet; 
    3. shall not be responsible for non-performance of the Website caused by any use that is contrary to our Terms, instructions, or modification or alteration by any party other than us or our representatives, and will only provide support to correct such non-performance at our sole discretion; and 
    4. shall not be responsible for any loss or damage arising from your failure to keep your passwords or other applicable seed phrases or keys secure and confidential.

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  1. You acknowledge that the Website may be subject to limitations, delays and other problems inherent in the use of such facilities.

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  1. Assumption of Risk

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  1. You acknowledge and accept that the risk of lack of market acceptance and adoption, market volatility, lack of a secondary market for trading and/or restrictions on trading in a secondary market, unforeseen software bugs, volatile price fluctuations of the resources used, cybersecurity issues or disruptions remain, and the Company shall not be liable to you for any loss, damage or delay caused by the delay or failure of the Website, cyber hacking, fraud or any form of cybercrimes committed against the Company, the Website or you in respect of all matters.  

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  1. The regulatory status of blockchain technology is unclear or unsettled in many jurisdictions. In the event that any relevant authority makes changes to existing laws, regulations and/or rules or financial institutions make commercial decisions and such changes/decisions negatively impact the provision of the Website in various ways, the Company shall be entitled to cease providing access to the Website in any jurisdiction without incurring any liability whatsoever to you.

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  1. You acknowledge and accept the risks of dealing with smart contracts and/or losing money due to fluctuations in the price of cryptographic digital assets (where applicable). 

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  1. You acknowledge and accept that we are not licensed or regulated under the laws or regulations of any jurisdiction (including that of the Republic of Singapore). You represent and warrant that your use of the Website does not violate any law of your relevant place of domicile and jurisdiction, and no further consent or approval from any governmental authority is required in connection with such use of the Website, and even if there are additional requirements or restrictions related to such use of the Website, you agree to comply with, and shall be solely responsible for complying with, any such laws or regulations. You represent and warrant that your use of the Website does not implicate or otherwise give rise to any legal or regulatory obligations on our part in respect of the laws of your relevant place of domicile and jurisdiction.

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  1. Limitation of Liability

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  1. Nothing in these Terms of Use excludes or limits our liability for death or personal injury arising from our negligence, or our fraud or fraudulent misrepresentation, or any other liability that cannot be excluded or limited by law. 

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  1. We shall not be liable whether in contract, tort (including for negligence or breach of statutory duty), misrepresentation (whether innocent or negligent), restitution or otherwise for:

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  1. any loss of profits, sales, revenue, business, data, use, goodwill or other intangible losses, or pure economic loss; 

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  1. any indirect, incidental, exemplary, punitive, special or consequential loss, costs, damages, charges or expenses; 

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  1. any actions taken by us in good faith in accordance with the information and instructions you have provided to us via the Website or otherwise (where applicable); 

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  1. any loss or damage caused by malware, distributed denial-of-service attack, or other harmful material that may infect your device, programs, data or other proprietary material due to your use of the Website;

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  1. any damages relating to your access to, use of, or inability to access or use the Website;

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  1. any damages relating to any conduct or content of any third party or another User, including without limitation, inaccurate, defamatory, offensive, unlawful or illegal conduct (where applicable); 

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  1. any content, services or goods provided by any Third Party Service Provider, including the quality of such services or goods; or

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  1. any consequences arising in connection with any event which occurs by reason of forces outside of our control. This includes any event, or a series of related events, that is outside of our reasonable control, including but not limited to acts of God, acts of civil or military authority, acts of customs authorities, national emergencies, industrial action, fire, abnormally adverse weather conditions, earthquakes, catastrophes, wars, insurrections, riots, security threats, pandemics and/or material network or other material telecommunications failures and material delay by common carriers.

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  1. Subject to the limitations on our liability set out herein, our total aggregate liability whether in contract, tort (including negligence or breach of statutory duty), misrepresentation (whether innocent or negligent), restitution or otherwise, including any professional and legal costs, arising in connection with these Terms, the access to and use of the Website and content, or the sale or purchase of any products on this Website, shall be limited to USD 100.

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  1. For the avoidance of doubt, the foregoing sets out our total financial liability to you in respect of any breach of these Terms, including but not limited to any Personal Data or data security breach.

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  1. Modification to the Website

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  1. To the maximum extent permitted by the applicable law, we reserve the right in our sole and absolute discretion, to amend, modify, alter or supplement these Terms and the Website from time to time, without prior notice to you. 

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  1. You should check back on the Website often to confirm that your copy and understanding of these Terms is current and correct. Your non-termination or continued use of the Website after the effective date of any amendments, changes, or updates constitutes your acceptance of these Terms, as modified by such amendments, changes, or updates.

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  1. Termination

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  1. The Company may, without notice and in its sole discretion, terminate these Terms and your right to access or use the Website at any time, and for any or no reason. You acknowledge and agree that we shall have no liability or obligation to you in such event and that you will not be entitled to a refund of any amounts that you have already paid to us, to the fullest extent permitted by applicable law.

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  1. Termination of these Terms shall not affect the effect of Clauses  ‎6, ‎11, ‎12, this 13.2, ‎14 to 18.

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  1. No termination shall release you from any liability which at any time of such termination has already accrued to the Company or which may accrue thereafter in respect of any act, omission or breach prior to such termination.

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  1. Governing Law and Dispute Resolution 

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  1. These Terms of Use and any dispute or claim arising out of or in connection with it or its subject matter or formation (including non-contractual disputes or claims) shall be governed by and construed in accordance with the law of the Republic of Singapore.

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  1. Any dispute arising out of or in connection with this Agreement, including any question regarding its existence, validity or termination, shall be referred to and finally resolved by arbitration in Singapore, administered by the Singapore International Arbitration Centre (“SIAC”) in accordance with the Arbitration Rules of SIAC (“SIAC Rules”) for the time being in force, which rules are deemed to be incorporated by reference in this clause. The seat of the arbitration shall be Singapore. The Tribunal shall consist of one arbitrator. The language of the arbitration shall be English. 

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  1. Waiver

No failure or delay by a party to exercise any right or remedy provided under these Terms or by law shall constitute a waiver of that or any other right or remedy, nor shall it preclude or restrict the further exercise of that or any other right or remedy. No single or partial exercise of such right or remedy shall preclude or restrict the further exercise of that or any other right or remedy. 

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  1. Severability

If any provision or part-provision of these Terms of Use is or becomes invalid, illegal or unenforceable, it shall be deemed modified to the minimum extent necessary to make it valid, legal and enforceable. If such modification is not possible, the relevant provision or part-provision shall be deemed deleted. Any modification to or deletion of a provision or part-provision under this clause shall not affect the validity and enforceability of the rest of these Terms.

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  1. Entire Agreement 

Unless explicitly agreed between parties in writing, these Terms of Use constitute the entire agreement between the parties and supersedes all previous discussions, correspondence, negotiations, arrangements, understandings and agreements between them relating to its subject matter.

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  1. Third Party Rights

No one other than a party to these Terms, their successors and permitted assignees, shall have any right to enforce any of its Terms.

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PRIVACY POLICY


This Privacy Policy is provided to you by Solutions Lab Pte. Ltd. (hereafter referred to as “we”, “us” or “our”), and sets out the basis on which we collect Personal Data from you and how we process such data.


By using, visiting, accessing or registering to use, logging into the platform found at our website at https://www.blockchainspace.asia/ (our "Website"), and/or accessing any of the products or services available on our Website or otherwise provided by us, you accept the practices described in this policy. The Website also includes the browser plug-in, mobile application, APIs, documentation, software, updates, features, tools, and any materials and services made available from time to time by us.


  1. DEFINITIONS


In this Privacy Policy, unless the context otherwise requires, “Personal Data” means (a) any data, in particular by reference to an identifier such as a name, address, email address, date of birth etc,

relating to a natural person, whether true or not, who can be identified directly or indirectly (i) from that data; or (ii) from that data and other information to which we have or are likely to have access, and (b) any other similar definition under any applicable Personal Data protection laws.


  1. COLLECTION OF PERSONAL DATA


  1. We may collect and process the following Personal Data about you:


  1. Information you give us - information that you provide us (which may include your first and last name, picture, address, e-mail address, telephone number, wallet address, social media handles and other personal descriptions as the case may be) by filling in forms or submitting your information on our Website, or by corresponding with us (by phone, email, via our services or otherwise), for example when you:


  1. register to find out more, join a waitlist, join a community or otherwise get involved;


  1. express interest in our project;


  1. register for an account with us on our Website or a third party website;


  1. report any problem to us;


  1. use certain features on our Website or provided by us;


  1. request any support from us;


  1. provide us with information via e-mail;


  1. complete any survey or questionnaire we send you;


  1. subscribe to our newsletters or mailing lists (if any);


  1. provide us with comments or suggestions;


  1. request for information about our platform or services; or


  1. contact us via phone, email or other forms of communication.


  1. Information we collect about you - information collected when you visit our Website, platform or access any of our services, for example:


  1. technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; and


  1. information about your visit, including the full Uniform Resource Locators (URLs), clickstream to, through and from our Website (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs) and methods used to browse away from the page.


  1. COOKIES


  1. Our Website uses cookies to distinguish you from other users of the Website. This helps us to provide you with a good experience when you browse our site and also allows us to improve our Website.


  1. A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree to the use of cookies. Cookies contain information that is transferred to your computer's hard drive.


  1. We use persistent cookies and session cookies. A persistent cookie stays in your browser and will be read by us when you return to our Website or a partner website that uses our services. Session cookies only last for as long as the session (usually the current visit to a website or a browser session).
  2. We use the following cookies:


  1. Strictly necessary cookies - These are cookies that are required for the operation of our Website. They include, for example, cookies that enable you to log into secure areas of our Website.


  1. Analytical/performance cookies - They allow us to recognise and count the number of visitors and to see how visitors move around our site when they are using it. This helps us to improve the way our Website works, for example, by ensuring that users are finding what they are looking for easily.


  1. Functionality cookies - These are used to recognise you when you return to our Website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).


  1. Cookies may be erased when you exit the Website or close the browser. Others are saved on your device for your next visit. You can delete all cookies placed by our Website on your device at any time. You can also set your browser to prevent all cookies from being placed by our Website or to provide you with a warning before a cookie is placed. However, please note that some functionalities of the platform may not work if all cookies are rejected. Please check your browser’s instructions or help screen to learn more about these functions.


  1. Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, which we do not have any control over. These cookies are likely to be analytical/performance cookies or targeting cookies.


  1. USE OF YOUR INFORMATION


  1. We may use your Personal Data for the following purposes:


  1. providing, operating and administering the Website, platform and/or services, which shall include the personalisation of your profile and/or account, maintenance, servicing and termination of any accounts registered with the Website;


  1. processing applications for the use of the Website, platform and/or services, including the facilitation, execution, or administration of any transaction(s) requested and/or authorised by you (such as requests to join waitlists and/or whitelists, if any);


  1. verifying your identity;


  1. improving, enhancing and developing our Website, platform and/or services;


  1. researching, designing and launching new tools, features or products;


  1. managing, administering or presenting content and information on our Website, platform and/or services in the most effective manner for you and for the device you use;


  1. providing you with alerts, updates, materials or information about our services or other types of information that you requested or signed up to;


  1. carrying out our contractual obligations arising from contracts entered into between you and us and for the enforcement of our legal or contractual rights;


  1. where applicable, for complying with applicable local and foreign laws and regulations applicable to us in or outside of Singapore that may include the conduct of due diligence procedures for opening of accounts and ongoing monitoring purposes;


  1. where applicable, for legal and compliance purposes under applicable local and foreign laws that include the monitoring and compliance procedures that is in line with the internal risk management procedures, audit/financial accounting and for management reporting purposes;


  1. to comply with any applicable legislation, law, regulations, codes of practice, rules, guidelines, including where information is to be disclosed to law enforcement agencies and other relevant authorities for investigations, crime prevention and detection purposes;


  1. to prevent and/or detect fraudulent behaviour or potential illegal or criminal activity as part of our efforts to keep our platform safe and secure;


  1. responding or taking part in legal proceedings, including seeking professional advice;


  1. for direct marketing purposes (please see further details in Clause ‎4.2 below);


  1. communicating with you and responding to your questions or requests;


  1. for internal operations, including troubleshooting and data analysis to learn about and understand the behaviour and preferences of users, testing, research, statistical and survey purposes to identify products or services which we might offer to existing and future users; and


  1. purposes directly related or incidental to the above.


  1. We may use your Personal Data in direct marketing (i.e. offering or advertising products or services by sending the relevant information directly to you). In relation to direct marketing, where we are required to do so, we will obtain your consent before using your Personal Data for this purpose. If you prefer not to receive our direct marketing communications and/or not to have your Personal Data shared among the members of our group or any third party for the purpose of marketing, you can have your name deleted from our direct marketing and/or shared information lists by clicking ‘unsubscribe’ at the footer of our emails or submit a request to us at legal@blockchainspace.asia.


  1. If we need to collect, use and/or disclose your Personal Data for additional purposes, unless excepted by law, we will inform you of the new purposes, and where necessary we will obtain your consent (or ensure that we have another lawful basis for such collection, use or disclosure) before such Personal Data will be collected, used and/or disclosed by us.


  1. DISCLOSURE OF YOUR INFORMATION


  1. We will take steps to keep your Personal Data we hold confidential but you agree we may provide your Personal Data to:


  1. personnel, agents, advisers, auditors, contractors, financial institutions, and third party service providers in connection with our operations or services (for example staff engaged in the fulfilment of your transaction, the processing of your payment and the provision of support services);


  1. our overseas offices, affiliates, business partners and counterparts (on a need-to-know basis only);


  1. persons to whom we are required to make disclosure under applicable laws and regulations in or outside of Singapore; or


  1. actual or proposed transferees of our operations (or a substantial part thereof) in or outside of Singapore.


  1. We will also need to share your Personal Data if we are under a duty to disclose or share it to comply with a legal obligations, in which case we will share your information with law enforcement agencies in connection with any investigation to help prevent unlawful activity.


  1. We will also share your information with third parties in the event that:


  1. we sell or buy any business or assets, in which case we will disclose your Personal Data to the prospective seller or buyer of such business or assets (but only to the extent we need to, and always in accordance with data protection legislation); and/or


  1. if we or substantially all of our assets are acquired by a third party, in which case Personal Data held by us about our customers will be part of the assets transferred to such third party.


  1. We process your Personal Data for this purpose because we have a legitimate interest to ensure our business can be continued by the buyer. If you object to our use of your Personal Data in this way, the relevant buyer of our business may not be able to provide services to you.


  1. Where applicable, we will ensure that the Personal Data enjoys the same standards of protection as set out in this Privacy Policy.


  1. If we transfer any of your Personal Data to a country or territory outside Singapore, or to our group or affiliates companies located outside Singapore, or to a permitted third party located outside of Singapore, we will only do so if we ensure that the overseas receiving party is bound by legally enforceable obligations to afford the transferred data a standard of protection that is comparable to that under Singapore law. We will also ensure that any overseas recipient is able to provide appropriate technical and organisational measures to protect your Personal Data and its confidentiality.


  1. SECURITY


  1. We will use appropriate and adequate technical and organisational measures to safeguard your Personal Data, for example:


  1. all Personal Data you provide to us is stored on our secure servers;


  1. we restrict access to Personal Data to our employees, service providers and contractors on a strictly need-to-know basis and ensure that those persons are subject to contractual confidentiality obligations; and


  1. we review our Personal Data collection, storage and processing practices from time to time to guard against unauthorised access, processing or use.


  1. While we will use reasonable efforts to safeguard your Personal Data, you acknowledge that the transmission of information via the Internet is not completely secure and for this reason we cannot guarantee the security or integrity of any Personal Data that is transferred from you or to you via the internet; any transmission is at your own risk.


  1. In the event that there is a security breach involving your Personal Data, we will inform you of the incident in accordance with the relevant data protection laws.


  1. WHERE WE STORE YOUR DATA


  1. We may store the Personal Data that we collect from you on internal servers that belong to us and/or our affiliated companies, and/or with commercial cloud storage providers engaged by us and/or our affiliated companies. These servers may be located in or outside of Singapore. Therefore, your data may be transferred to and stored in different jurisdictions and may also be processed by staff operating within the various countries who work for us or for one of our contractors and/or our affiliated companies.


  1. By submitting your Personal Data, you agree to such transfer, storage or processing of your data. In such a case, we will ensure that the receiving organisations will provide a minimum standard of protection to your data that is comparable to the required protection under Singapore law.


  1. Unfortunately, the transmission of information via the internet is not completely secure. We will take commercially reasonable steps to ensure that your Personal Data is handled securely and in accordance with this Privacy Policy and the relevant privacy laws, but are unable to guarantee the secure transmission of information via the internet.


  1. YOUR RIGHTS


Depending on which Personal Data protection laws apply to the processing of your Personal Data, you may have one or more of the following rights in relation to the processing of your Personal Data:


  1. You may withdraw your consent and request us to stop using and/or disclosing your Personal Data for any or all of the purposes listed above by submitting your request via email to our Data Protection Officer at the contact details provided below. We will endeavour to process your request within thirty (30) from the day of receipt of your request, otherwise, we will provide you with the estimated time frame for us to carry out your request.


  1. If you have consented or signed up to receive marketing materials, you may withdraw your consent at any time and request us to stop sending you marketing materials or to stop using your Personal Data for any other marketing activities by submitting your request via email to our Data Protection Officer at the contact details provided below. We will endeavour to process your request within thirty (30) days from the day of receipt of your request.


  1. Please note that depending on the nature and scope of your request for withdrawal of consent, we may not be in a position to continue providing the platform or our services to you. In our acknowledgement email to you upon your request for withdrawal of consent, we will inform you of the likely consequences of withdrawing consent.


  1. If you do withdraw your consent, we will work with all relevant stakeholders such as data intermediaries and agents who have been authorised to collect, process or use your Personal Data to ensure that such relevant stakeholders also cease to collect, process or use your Personal Data.
  1. ACCESS


  1. You may send our Data Protection Officer requests for:


  1. access to Personal Data which we hold about you; and/or


  1. access to information about the ways in which we use or disclose or may have used or disclosed your Personal Data for the year immediately preceding the date of your request.


  1. Access requests may be subject to a fee to meet our costs in providing you with details of the information we hold about you. Where such a fee is chargeable, we will let you have a written estimate of the fee before proceeding.


  1. If we are unable to respond to your requests within thirty (30) days after receipt of your request, we will inform you within that time in writing the time by which we will be able to respond to the request.


  1. ACCURACY OF AND CORRECTION OF PERSONAL DATA


  1. We will make reasonable efforts to ensure the accuracy and completeness of the Personal Data you provide to us and/or update your Personal Data associated with your account on the Website. However, we also will require you to provide us with accurate, up-to-date and complete information. In order to ensure that the Personal Data that we maintain is accurate, you may send our Data Protection Officer at any time requests to update your information or for correction of errors or omissions in Personal Data which we hold about you.


  1. We will generally not charge for correction requests, although we reserve the right to do so under unforeseen circumstances. If we are unable to respond to your requests within thirty (30) days after receipt of your request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to the request.


  1. DATA PORTING REQUEST


  1. To the extent applicable under the Personal Data Protection Act, as long as you have an existing direct contractual arrangement with us, you may send our Data Protection Officer a request for us to transmit your Personal Data, which was collected or created by us prior to the date of your request, which is in our possession or under our control, to another organisation in Singapore.


  1. If we are unable to respond to your requests within thirty (30) days after receipt of your request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to the request.


  1. RETENTION OBLIGATIONS


  1. We will only retain and use Personal Data for as long as is required by law or for other legitimate business purposes including complying with our legal obligations, resolving disputes and enforcing our agreements.


  1. We will ensure that your Personal Data is destroyed, remove them from our records, and/or ensure that it no longer contains personally identifiable information, as soon as it is reasonable to assume that:


  1. the purpose for which the Personal Data was collected is no longer relevant; and


  1. retention is no longer necessary for legal or business purposes.


  1. To determine the appropriate retention period for the Personal Data we hold, we will consider the amount, nature and sensitivity of the Personal Data, the risk of harm from unauthorised use or disclosure of your Personal Data, the reasons why we handle your Personal Data, whether we can achieve those purposes through other means, and the applicable legal requirements.


  1. We may also anonymise your Personal Data so that it can no longer be associated with you, in which case we may retain and use this information indefinitely without further notice to you.


  1. THIRD-PARTY SITES


  1. Our platform/Website or our communication with you may, from time to time, contain links to third-party websites and/or websites of our partner networks, advertisers, affiliates and third party service providers, over which we have no control.


  1. If you follow a link to any of these websites, please note that they have their own practices and policies. We encourage you to read the privacy policies or statements of these websites to understand your rights. We accept no responsibility or liability for your access of third-party websites.


  1. CHANGES TO OUR PRIVACY POLICY


We may amend this Privacy Policy from time to time by posting the updated policy on our Website and/or platform. Any changes that we make will be posted on this page and, where appropriate, notified to you by e-mail or post. You should check this policy frequently to ensure you are aware of the most recent version that will apply each time you access the Website/platform. By continuing to use our Website/platform after the changes come into effect means that you agree to be bound by the revised policy.


  1. CONTACT US


If you have any questions, comments or requests regarding this Privacy Policy or your Personal Data, please address them to legal@blockchainspace.asia.



Last updated: 15 May 2023

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