Privacy Notice

DATA PRIVACY POLICY

This Data Privacy Policy (“Policy”) sets out the basis which Four1Three.Tech (“we”, “us”, or “our”) may collect, use, disclose or otherwise process personal data provided to us in accordance with the Personal Data Protection Act 2012 of Singapore (“PDPA”). This policy applies to personal data in our possession or under our control, including personal data in the possession of organizations which we have engaged to collect, use, disclose or process personal data for our purposes and in connection with:

use of any of our products, services or applications (together the "Services"),

visit or use of the websites under the Crypto.com brand ("Site") or mobile application ("App").

Please note that our Services, Site and App are not intended for minors under the age of 18 years and we do not knowingly collect data relating to minors.

PERSONAL DATA

1. As used in this Notice: “You” means an individual who (a) has contacted us through any means to find out more about any goods or services we provide, or (b) may, or has, entered into a contract with us for the supply of any goods or services by us; and “personal data” means data, whether true or not, about an individual who can be identified:

• from that data; or
• from that data and other information to which we have or are likely to have access.

1. Depending on the nature of your interaction with us, some examples of personal data which we may collect from you include your name and identification information such as your NRIC number, contact information such as your address, email address or telephone number, nationality, gender, date of birth, marital status, photographs and other audio-visual information, employment information and financial information such as credit card numbers, debit card numbers or bank account information.
2. Other terms used in this Notice shall have the meanings given to them in the PDPA (where the context so permits).

COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA

1. We generally do not collect your personal data unless

• it is provided to us voluntarily by you directly or via a third party who has been duly authorized by you to disclose your personal data to us (your “authorized representative”) after:

• (i) you (or your authorized representative) have been notified of the purposes for which the data is collected, and

• (ii) you (or your authorized representative) have provided written consent to the collection and usage of your personal data for those purposes, or

• collection and use of personal data without consent is permitted or required by the PDPA or other laws. We shall seek your consent before collecting any additional personal data and before using your personal data for a purpose which has not been notified to you (except where permitted or authorized by law).

1. We may collect any personal data that is necessary for legitimate business purposes when such collection and use is reasonable, given your relationship with us and your reasonable expectations for how your personal information will be used. We will use this information for the purposes which it was collected for. We may also collect personal data from trusted third-party sources and engage third parties to collect such personal data to assist us.

1. If we receive your personal information from someone who reasonably purports to be your representative or acting on your behalf (for example, someone at your firm or an affiliated firm), we will assume that such information is being provided to us in a manner that is compliant with applicable law, including any applicable privacy rules, and any applicable corporate policies in effect at your firm.

1. We may collect and use your personal data for any or all of the following purposes:

• performing obligations in the course of or in connection with our provision of the goods and/or services requested by you;

• verifying your identity;

• responding to, handling, and processing queries, requests, applications, complaints, and feedback from you;

• managing your relationship with us;

• processing payment or credit transactions;

• sending your marketing information about our goods or services including notifying you of our marketing events, initiatives and promotions, lucky draws, membership and rewards schemes and other promotions;

• complying with any applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority;

• any other purposes for which you have provided the information;

• transmitting to any unaffiliated third parties including our third-party service providers and agents, and relevant governmental and/or regulatory authorities, whether in Singapore or abroad, for the aforementioned purposes; and

• any other incidental business purposes related to or in connection with the above.

1. We may disclose your personal data:

• where such disclosure is required for performing obligations in the course of or in connection with our provision of the goods or services requested by you; or

• to third party service providers, agents, and other organizations we have engaged to perform any of the functions listed in clause 7 above for us.

1. The purposes listed in the above clauses may continue to apply even in situations where your relationship with us (for example, pursuant to a contract) has been terminated or altered in any way, for a reasonable period thereafter (including, where applicable, a period to enable us to enforce our rights under any contract with you).

WITHDRAWING YOUR CONSENT

1. The consent that you provide for the collection, use and disclosure of your personal data will remain valid until such time it is being withdrawn by you in writing. You may withdraw 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 in writing or via email to our Data Protection Officer at the contact details provided below.

1. Upon receipt of your written request to withdraw your consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed 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 ten (10) business days of receiving

1. Whilst we respect your decision to withdraw your consent, please note that depending on the nature and scope of your request, we may not be in a position to continue providing our goods services to you and we shall, in such circumstances, notify you before completing the processing of your request. Should you decide to cancel your withdrawal of consent, please inform us in writing in the manner described in clause 10

1. Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclose without consent is permitted or required under applicable laws.

ACCESS TO AND CORRECTION OF PERSONAL DATA

1. If you wish to make (a) an access request for access to a copy of the personal data which we hold about you or information about the ways in which we use or disclose your personal data, or (b) a correction request to correct or update any of your personal data which we hold about you, you may submit your request in writing or via email to our Data Protection Officer at the contact details provided below.

1. Please note that a reasonable fee may be charged for an access request. If so, we will inform you of the fee before processing your request.

1. We will respond to your request as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days after receiving your request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to your If we are unable to provide you with any personal data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the PDPA).

PROTECTION OF PERSONAL DATA

1. To safeguard your personal data from unauthorized access, collection, use, disclosure, copying, modification, disposal, or similar risks, we have introduced appropriate administrative, physical, and technical measures and disclosing personal data both internally and to our authorized third-party service providers and agents only on a need-to-know basis.
2. You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.

ACCURACY OF PERSONAL DATA

1. We generally rely on personal data provided by you (or your authorized representative). In order to ensure that your personal data is current, complete and accurate, please update us if there are changes to your personal data by informing our Data Protection Officer in writing or via email at the contact details provided below.

RETENTION OF PERSONAL DATA

1. We may retain your personal data for as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws.

COOKIES

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

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 Site or a partner site 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).

1. We use the following cookies:

• Strictly necessary cookies – These are cookies that are required for the operation of our Site. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.

1. You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you do so, you may not be able to access all or parts of our Site.

1. We may use third-party web services on our Site. The service providers that administer these services use technologies such as cookies (which are likely to be analytical/performance cookies or targeting cookies), web server logs and web beacons to help us analyze how visitors use our Site and make the information displayed on it more relevant to your interests. The information collected through these means (including IP addresses) is disclosed to these service providers. These analytics services may use the data collected to contextualize and personalize the marketing materials of their own advertising network.