PLEASE READ THIS POLICY CAREFULLY AS IT CONTAINS IMPORTANT INFORMATION AND AFFECTS YOUR LEGAL RIGHTS.

 

This Privacy & Cookies Policy (this “Privacy Policy”) is incorporated in our General Terms of Use (the “Terms“) by reference, and together with the Terms constitutes a binding agreement between you and Arkadiah, and describes our information handling practices when you access and use our data or. All terms and references used in this Privacy Policy and which are defined or construed in the Terms shall have the same meaning and construction in this Privacy Policy.

This Privacy Policy is meant to help you understand our data processing activities and practices when visitors and Users access our Infrastructure, and how we handle your  personal data (“Personal Data“) (as defined below) including how we collect, use or disclose your Personal Data. Arkadiah respects the privacy of its Users and recognizes the need for adequate protection and administration of the Personal Data in accordance with this Privacy Policy.

This Privacy Policy supplements but does not supersede nor replace any other consents you may have previously provided to us in respect of your Personal Data, and any consents you may have provided in connection with this Privacy Policy are cumulative and additional to any rights which we may have under Data Protection Laws (as defined below) to collect, use and disclose your Personal Data. 

Arkadiah may, at its sole discretion, make changes to this Privacy Policy from time to time. The changes will be effective immediately upon their publication on our Infrastructure. Please review this Privacy Policy on a regular basis. If changes are significant, we will provide a more prominent notice (including, in certain cases, email notification of the Privacy Policy changes). 

 

BY INTERACTING WITH US, SUBMITTING INFORMATION TO US, SIGNING UP FOR THE USE OF OUR INFRASTRUCTURE, ACCESSING AND/OR USING OUR INFRASTRUCTURE, YOU AGREE TO BE BOUND BY, AND ACCEPT THIS PRIVACY POLICY AS UPDATED FROM TIME TO TIME. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, YOU MUST IMMEDIATELY DISCONTINUE YOUR ACCESS OR USE OF THE INFRASTRUCTURE.

 

  1. DEFINITIONS 

In addition to the terms defined elsewhere in this Privacy Policy, the following words and expressions shall have the meanings respectively assigned to them hereunder, unless the context requires otherwise:

1.1 “Data Protection Laws” means any applicable law relating to the protection, privacy and security, collection, use or disclosure of sensitive or other personally identifiable information, including the Singapore Personal Data Protection Act 2012; 

1.2 “Personal Data” means all personal information and/or personal data as defined under Data Protection Laws; and 

1.3 “Process” (“processed” or, “processing”) means any set of operations which is performed on any Personal Data or set of Personal Data, whether or not by automated means, such as collection, recording, organisation, structuring, reformatting, analysis, storage, adaptation or alteration, retrieval,  use, disclosure by transmission, dissemination or otherwise making available, combination with other data, restriction, compression, encryption, erasure or destruction. 

 

  1. PERSONAL DATA WE COLLECT

2.1 The Personal Data we collect includes the Personal Data you provide to us as part of your access and/or use of the Infrastructure (the “Provided Information“). If you choose not to share the Provided Information with us, we may not be able to serve you as effectively or offer you access to, and use of the Infrastructure. As we add new features and services, you may be asked to provide additional Provided Information. 

2.2 The Provided Information may include:

2.2.1 certain financial information (such as virtual assets wallet address) (the “Financial Information“);

2.1.2 information about your transactions, which may include any one or more of the following: information about the transaction, the amount of the transaction and its time (the “Transactions Information“);

2.2.3 correspondence information, which may include any one or more of the following: survey responses, information provided to our support team or user research team; records and copies of your email messages together with your email address and our responses, if you choose to correspond with us through email (the “Correspondence Information“); and

2.2.4 information about your User Content, which may include any one or more of the following: User Content you submit to be published or displayed on the Infrastructure or transmitted to other Users or third- parties (the “User Information“);

2.2.5 technical information and usage data, such as statistical and site-related information relating to how a visitor arrived at our websites or platforms, the IP address which may provide information about precise or approximate location, device information, clickstream information and time stamp, and information about how you use our websites and services; 

2.2.6 marketing and communications data, such as your preferences in receiving marketing messages from us, your communication preferences and history of communications with us, our service providers or third parties; and/or

2.2.7 other information, which may include your participation in our contests, promotions, or surveys, and photographs, videos and/or audio recordings taken by us or our representatives.

 

2.3 If you provide us with any Personal Data relating to a third-party (e.g. information on your dependent), by submitting such information to us, you represent and warrant that the collection, use and disclosure of that Personal Data to us, as well as further collection, use, disclosure and/or Processing of that Personal Data by us for the purposes set out herein, is lawful, by or for the benefit of the persons referenced herein, and you have obtained the consent of the third-party to provide us with their personal data. 


2.4 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 offer you access to, and use of, the Infrastructure.

 

2.5 Information we collect from you automatically. To the extent permitted by Data Protection Laws, we may collect certain types of information automatically, such as whenever you interact with the Infrastructure (the “Automatically Collected Information“). This information helps us address customer support issues, improve the performance of our Infrastructure, provide you with a streamlined and personalized experience, and protect your Account from fraud by detecting unauthorized access. We may use a variety of technologies to collect the Automatically Collected Information, including, without limitation:

2.5.1 Cookies. A cookie is a small data file stored on the hard drive of your computer either for only the duration of your visit on the Website or for a fixed period (for more information, please, see Section 7 below);

2.5.2 Web Beacons. Web beacons are small files that are embedded in the Website and emails. Web beacons allow us, for example, to track who has visited the Website or opened an email, to test the effectiveness of our marketing, and for other related Website statistics;

2.5.3 JavaScripts. JavaScripts are code snippets embedded in various parts of Website that facilitate a variety of operations including accelerating the refresh speed of certain functionality or monitoring usage of various online components;

2.5.4 Entity Tags. Entity Tags are HTTP code mechanisms that allow portions of Website to be stored or “cached” within your browser and validates these caches when the Website is opened, accelerating Website performance since the web server does not need to send a full response if the content has not changed;

2.5.5 HTML5 Local Storage. HTML5 local storage allows data from Website to be stored or “cached” within your browser to store and retrieve data in HTML5 pages when the Website is revisited; and

2.5.6 Resettable Device Identifiers. Resettable device identifiers (also known as “advertising identifiers”) are similar to cookies and are found on many mobile devices and tablets (for example, the “Identifier for Advertisers” or “IDFA” on Apple iOS devices and the “Google Advertising ID” on Android devices), and certain streaming media devices. Like cookies, resettable device identifiers are used to make online advertising more relevant.

 

2.6 The Automatically Collected Information may include:

2.6.1 information about how you access and use the Infrastructure;

2.6.2 device type and unique device identification numbers;

2.6.3 device event information (such as crashes, system activity and hardware settings, browser type, browser language, the date and time of your request and referral URL);

2.6.4 how your device interacts with the Infrastructure, including pages accessed and links clicked; and

2.6.5 broad geographic location (e.g. country or city-level location).

 

2.7 You acknowledge and agree that: 

2.7.1 Arkadiah shall retain all rights, title and interest in and to all Automatically Collected Information; and

2.7.2 Any IP Rights of or in Automatically Collected Information shall vest solely in us. 

 

  1. PURPOSES FOR THE COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA

3.1 Our primary purpose in collecting, using or disclosing Personal Data is to provide you with a secure, smooth, efficient and customized experience. We generally use Personal Data to create, develop, operate, deliver, and improve our Infrastructure, content and advertising; and for loss prevention and anti-fraud purposes. We may collect, use and disclose your Personal Data in the following ways and for the following purposes:

3.1.1 to provide you with the Infrastructure, to deal with any requests or inquiries you may have with respect to the Infrastructure and to provide customer service and support, including to recommend features or content which may be relevant to you based on your usage of our services, your profile information and preferences, and other information that you submitted to us;

3.1.2 to maintain legal and regulatory compliance and to enforce or apply any agreement or to protect our (or others’) property or rights and to defend any potential claim;

3.1.3 communicate with you about your transactions;

3.1.4 inform you about important changes to, or other news about, the Infrastructure, including notifying you of any service issues and account updates, handling and responding to your queries, requests, feedback and suggestions, or sending you direct marketing messages or interest-based advertising, when carried out in our legitimate interests or in accordance with Data Protection Laws;

3.1.5 to prevent and detect money-laundering, terrorism, fraud or other crimes or abuses of the Infrastructure;

3.1.6 to operate, maintain, improve, personalize, and analyze the Infrastructure, to monitor and analyze trends, usage, and activities for marketing or advertising purposes, to enhance your experience, to allow you to participate in interactive features on the Infrastructure;

3.1.7 to conduct our recruiting processes, to maintain appropriate records for internal administrative purposes; for statistical purposes, for market research and product analysis and to protect the health and safety of our employees and visitors, our facilities and our property and other rights;

3.1.8 managing our business operations and complying with internal policies and procedures, including but not limited to keeping records for tax purposes, managing and preparing reports on incidents and accidents, protecting and enforcing our contractual and legal rights and obligations, and facilitating business asset transactions;

3.1.9 to develop, test and improve new products or services, including by testing and troubleshooting new products and features, such as through the use of technical and usage data, as well as aggregated, de-identified, and/or anonymized data to understand user behaviour and market trends;

3.1.10 for any purpose that you provide your consent. We will not use your Personal Data for purposes other than those purposes we have disclosed to you, without your permission. From time to time, and as required under Data Protection Laws, we may obtain your consent to allow us to share your Personal Data with third-parties. In such instances, you may opt out of having your Personal Data shared with third-parties, or allow us to use your Personal Data for any purpose that is incompatible with the purposes for which we originally collected it or subsequently obtained your authorization. If you choose to limit the use of your Personal Data, certain features of the Infrastructure may not be available to you;

3.1.11 matching any Personal Data held which relates to you for any of the purposes listed herein; and/or

3.1.12 any other purpose relating to or reasonably necessary for any of the

 

3.2 We may also collect, use or disclose your Personal Data for marketing and promotions (e.g. to send promotional communications, such as information about features, newsletters, offers, promotions, contests and events), and will, to the extent required by Data Protection Laws, obtain your express consent before collecting, using, or disclosing your Personal Data for such marketing and promotions.

 

3.3 In relation to particular products or services or in your interactions with us, we may also have provided additional disclosures or specifically notified you of other purposes for which we process your Personal Data at the point of such interaction. These notices may supplement or clarify our privacy practices or may provide you with additional choices about how we process your Personal Data for these purposes as well. You also consent to your Personal Data so collected being handled in accordance with this Privacy Policy. 

 

  1. DISCLOSURE OF PERSONAL DATA

4.1 We take care to allow your Personal Data to be disclosed only with third- parties in accordance with this Privacy Policy. Arkadiah will never sell or rent your Personal Data to third-parties without your explicit consent. We will only disclose your Personal Data in the following circumstances, whether to third parties which are located overseas or in Singapore:

4.1.1 when we are required by Data Protection Laws to disclose to the relevant government regulators, ministries, statutory boards or authorities and/or law enforcement agencies, to comply with any directions, laws, rules, guidelines, regulations or requests issued or administered by any of them;

4.1.2 with our Affiliates for business purposes and as a normal part of conducting business and offering the Infrastructure to you;

4.1.3 within our cooperation with our service providers and suppliers, including network infrastructure providers, cloud providers, customer support service providers, marketing services providers, security services providers, data analysis service providers, software developers, land owners, real estate surveyors, non-governmental agencies, data scientist, as well as with our professional advisors who provide banking, legal, compliance, insurance, accounting, agricultural, geological, biodiversity, research or other consulting services in order to complete third party financial, technical, compliance and legal audits of our operations or otherwise comply with our legal obligations. The mentioned service providers and advisors are bound by contractual obligations with us to keep Personal Data confidential and use it only for the purposes for which we disclose it to them;

4.1.4 with companies providing services in the areas of fraud and crime prevention and with companies providing similar services, including financial institutions such as credit reference agencies and regulatory bodies, courts, law enforcement authorities, regulators or attorneys or other parties for the establishment, exercise or defense of a legal or equitable claim or for the purposes of a confidential alternative dispute resolution process;

4.1.5 aggregated Personal Data and statistics for the purpose of monitoring Infrastructure usage in order to help us develop our Infrastructure;

4.1.6 to facilitate equity or debt financing or asset sale transactions with companies or other entities that we plan to merge with, be acquired or financed by; 

4.1.7 for corporate governance, audit and compliance purposes, including disclosure to our board of directors, auditors, cybersecurity consultants and lawyers or other professional advisors engaged for compliance purposes; and/or

4.1.8 any other party to whom you authorise us to disclose your Personal Data to.

 

4.2 We may also share information about you in an aggregate or anonymised form, for example, generic aggregated demographic information regarding visitors and users, with the abovementioned entities or parties (e.g. our business partners, trusted affiliates and advertisers).

 

4.3 You hereby acknowledge and agree that information that you post on or through the public areas of the Infrastructure are generally accessible to, and may be collected and used by others and may result in unsolicited messages or other contact from others. Users of the Infrastructure are encouraged to exercise caution when providing Personal Data about themselves in public or interactive areas.

 

4.4 Otherwise, we will only disclose your Personal Data when we are allowed or required by Data Protection Laws, and/or when you direct us or give us the consent to do so in accordance with this Privacy Policy.

 

  1. DEEMED CONSENT 

5.1 In addition to the matters set forth above, subject to and in accordance with Data Protection Laws, you shall be deemed to have consented to us collecting, using, disclosing and sharing amongst ourselves your Personal Data, and disclosing such Personal Data to our Affiliates, service providers, suppliers and relevant third parties: 

5.1.1 where in response to a request for your Personal Data in connection with identified purposes, you voluntarily provide such Personal Data to us for such purpose(s) and it is reasonable that you would voluntarily provide such Personal Data; and 

5.1.2 where the collection, use or disclosure of your Personal Data is reasonably necessary for the conclusion and/or performance of a contract between you and us or any other organisation entered into at your request, which may include recipients of your Personal Data not indicated in this Privacy Policy. 

 

  1. OTHER BASES FOR HANDLING OR PROCESSING YOUR PERSONAL DATA 

6.1 In addition to and without limiting the consents you have provided to our collection, use, or disclosure of your Personal Data for the purposes set out elsewhere in this Privacy Policy, where permitted by Data Protection Laws, Arkadiah may also in accordance with the requirements thereof also collect, use, or disclose your Personal Data as further detailed below including without consent, where we meet the requirements of Data Protection Laws: 

6.1.1 for our legitimate interests or the legitimate interests of another person (but not for sending you direct marketing messages unless you have otherwise provided your consent), including without limitation for the following purposes: 

  1. any investigations or proceedings; 
  2. fraud detection and prevention; and 
  3. detection and prevention of misuse of the Infrastructure by Users; and 

6.1.2 we may collect your Personal Data from any of our Affiliates, we may use your Personal Data, and any of our Affiliates may disclose your Personal Data to us, for improving our products, services, processes or business, understanding User preferences and personalising experiences and recommendations (regardless whether you are an existing or prospective user of any of our Affiliates). 

 

  1. COOKIES

7.1 Our websites and platforms may use cookies as follows:

7.1.1 as necessary in order to enable our websites and platforms to operate, for example, to enable you to log onto secure parts of our websites and platforms; 

7.1.2 to collate information on your search and browsing history within our websites and platforms in order to better tailor our products and services to your interests and needs, such as to personalise the websites and platforms for you and deliver prompts which may be of particular interest to you;

7.1.3 to track and compile statistics about visitors who interact with the websites, platforms and other Arkadiah online content; and/or

7.1.4 making our websites and platforms easier to use, for example, to help speed up your future interactions with our websites and platforms by storing your selected inputs so that you are not constantly asked for the same information. 

 

7.2 Most browsers let you remove or reject cookies. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. Please note that if you delete or disable the cookies associated with our websites and platforms by changing the settings on your browser, this may impact your user experience while on our websites or platforms, including but not limited to your ability to enter or use certain part(s) of our websites or platforms. For more information about cookies, including how to see what cookies have been set on your browser and how to manage and delete them, visit www.allaboutcookies.org

 

7.3 Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com/

 

7.4 If you have registered for an account with us, you may review and update certain account information by logging into your account, or by contacting us in the manner specified below. You should ensure that all Personal Data submitted to us is accurate, true and correct, as failure on your part to do so may affect our ability to provide you with any products and/or services.

 

  1. SECURITY, PROTECTION AND STORAGE OF PERSONAL DATA

8.1 Whilst we will undertake appropriate safeguards to protect the security and confidentiality of the Personal Data you entrust to us in accordance with Data Protection Laws, you acknowledge and agree that the safety and security of your Personal Data also depends on you. As such, where we have given you (or where you have chosen) a password for access to certain parts of the Infrastructure, you undertake to keep your 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 password or believe the confidentiality of your 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 authorized and/or fraudulent use of your password. 

 

8.2 Notwithstanding the foregoing, please be aware that no method of transmission over the internet or method of electronic storage is completely secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security, or that no malicious attacker or harmful code will enter or target our websites or services (for example, viruses, bugs, trojan horses, spyware or adware). 

 

  1. YOUR CHOICES AND PRIVACY RIGHTS

9.1 Depending on Data Protection Laws of jurisdictions where the relevant User resides, the User may be able to assert certain rights related to the Personal Data identified below:

9.1.1 to obtain from Arkadiah confirmation whether Arkadiah processes any of your Personal Data;

9.1.2 to request for access to your Personal Data processed by Arkadiah;

9.1.3 to withdraw your consent to processing of your Personal Data at any time (provided that the relevant Personal Data processing is based on your consent);

9.1.4 to obtain from Arkadiah the rectification (correction) of inaccurate Personal Data;

9.1.5 to obtain from Arkadiah the erasure (deletion) of the Personal Data;

9.1.6 to receive your Personal Data, which have been provided to Arkadiah, in a structured, commonly used and machine-readable format and to transmit that Personal Data to another controller without hindrance from Arkadiah;

9.1.7 to restrict or object to the processing of your Personal Data by Arkadiah;

9.1.8 not to be subject to a decision based solely on automated processing; and

9.1.9 to complain to the local data protection authority if your privacy rights are violated, or if you have suffered as a result of unlawful processing of your Personal Data.

 

9.2 These rights will only apply in certain circumstances. If you wish to exercise any of these rights or become acquainted with these circumstances, in which the relevant right is applied, please, contact us via any of the means provided in Section 11. That being the case, Arkadiah may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

 

9.3 If any of the rights listed above are not provided under Data Protection Laws for the relevant User’s jurisdiction, Arkadiah has sole and absolute discretion in providing the relevant User with those rights.

 

9.4 If you choose to withdraw your consent to any Processing of your Personal Data, please note that depending on the nature of your request, Arkadiah may not be in a position to continue to provide its products or services to you, administer any contractual relationship already in place, or perform or conclude an existing or prospective agreement. This may also result in the termination of any agreements you have with Arkadiah, and your being in breach of your contractual obligations or undertakings. Arkadiah’s legal rights and remedies in such event are expressly reserved. Please also note that withdrawing consent does not affect our right to continue to process Personal Data where such processing without consent is permitted or required under Data Protection Laws. Upon receipt of your written request, we may require reasonable time to process your request and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us. In general, we shall seek to process your request within thirty (30) days of receiving it, and will inform you should we require more time or information from you to process the request (which may depend on the complexity of the request, the rights and exemptions under Data Protection Laws, and the impact on our relationship with you).

 

  1. CONTACTING US

10.1 If you: 

10.1.1 have any questions or feedback relating to your Personal Data or about this Privacy Policy; 

10.1.2 would like to withdraw your consent to any collection, use or disclosure of your Personal Data as set out in this Privacy Policy; or would like to obtain access and make corrections to your Personal Data records;

you may also write to our Data Protection Officer as follows:

[email protected]

with a copy to: [email protected]

10.2 Please note that if your Personal Data has been provided to us by a third party, you should contact that third party to make such queries, complaints, and access and correction requests to Arkadiah on your behalf. 

 

10.3 If you believe that we have infringed your rights, we encourage you to first submit a request by sending an email to the email address in this Section 10 (subject line: “Privacy Policy Request”) so that we can try to resolve the issue or dispute informally.

 

10.4 You have the right to make a complaint at any time to the supervisory authority for data protection issues in the applicable jurisdiction. We would, however, appreciate the chance to deal with your concerns before you approach the relevant supervisory authority so, please, contact us in the first instance via email provided in this Section 10.

 

  1. GOVERNING LAW 

This Privacy Policy shall be governed in all respects by the laws of Singapore.

 

  1. THIRD PARTY SITES

Our websites and services may contain links to other websites or services operated or provided by third parties. We are not responsible for the privacy practices of such websites or services operated or provided by third parties, whether or not these third party websites or services may carry our logo or trademark even though they are not operated or maintained by us. Once you have left our websites or services, you should check the applicable privacy policy of the third party website or service to determine how they will handle any information they collect from you.

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