ARTICLE 1. WHY WE COLLECT INFORMATOIN
1.1. We collect a range of information including but not limited to Personal Data necessary for the use of Services and to address regulatory considerations and obligations under Applicable Law, including those relating to know Your Customers (the “KYC”), Anti-Money Laundering (the “AML”) and Countering Financing Terrorism (the “CFT”).
1.2. Some Services require your registration and provisions of certain Personal Data, and you acknowledge that if you choose to withhold any Personal Data requested by us, it may not be possible for you to gain access to certain parts of the Services or for us to respond to queries.
1.3. The Personal Data includes any information that can be used to identify you, directly or indirectly, or to contact you (and similarly, such information relating to corporates’ individual shareholders, beneficial owners, directors and authorized representatives). This Policy covers all such Personal Data requested and submitted to us or obtained by us from our Service providers and public sources.
1.3. To avoid any doubts, this Policy does not apply to anonymous data which cannot be used to identify you or to information relating to non-natural persons or body corporates themselves which is not the Personal Data.
1.4. We collect to process the Personal Data so as to provide you with our Services and to comply with Applicable Law and related regulatory requirements (to mitigate against risks of money laundering, terrorist financing, proceeds from crime or some other relevant purposes, including but not limited to fiscal or tax considerations).
1.5. We may make a request for your Personal data for other reasons to develop new products and services, market our products and services, complete surveys or to invite you to our events. We will in such instances week your consent. If you decided not to provide us with the types of Personal Data requested or disclose the specific information, we may not be able to service you as effectively or offer you all of our Services.
ARTICLE 2. TYPES OF INFORMATION OR INFORMATION WE COLLECT
2.1. We may collect your Personal Data such as email address, password, first and last name, phone number, residence details (e.g. country, address, city, state, postal code, etc), date of birth, government issued identification or passport, photographs, etc when you use our Site.
2.2. If you tell us where you are (e.g., by allowing your mobile device or computer to send us your location), we may store that information.
2.3. Certain services like two-factor authentication, may require our collection of your phone number. We may associate that phone number to your mobile device identification information.
2.4. If you provide us feedback or contact us via e-mail, we will collect your name and e-mail address, as well as any other content included in the e-mail, in order to send you a reply.
2.5. We may collect other types of Personal Data that you provide to us voluntarily when seeking support services such as email, information submitted via online form, other contact information and other information provided to support services staff.
2.6. We may collect other data, including but not limited to, referral URLs, your location, wallet information such as wallet addresses and the amount you deposit or withdraw.
2.7. Our servers (which may be hosted by a third party service provider) collect your information including your browser type, operating system, Internet Protocol (the “IP”) address (a number that is automatically assigned to your computer when you use the Internet, which may vary from session to session), domain name, and/or a date/time stamp for your visit.
2.8. As is true of most websites, we gather certain information automatically and store it in log files. This information includes IP addresses, browser type, Internet service provider (the “ISP”), referring/exit pages, operating system, date/time stamp, and click stream data.
2.10. We retain information on your behalf such as transactional data and other session data linked to your Account.
ARTICLE 3. THE WAY WE USE INFORMATION COLLECTED
3.1. In general, the Personal Data you submit to us is used either to respond to requests that you make, or to aid us in serving you better. We use your Personal Data in the following ways:
- (a) facilitate the creation of and secure your Account on our network;
- (b) identify you and perform identity verification through a service provider;
- (c) provide improved administration of our Site and Services;
- (d) improve the quality of experience when you interact with our Site and Services;
- (e) send you a welcome e-mail to verify ownership of the e-mail address provided when your Account was created;
- (f) send you administrative e-mail notifications, such as account activity, transaction processing, security or support and maintenance advisories;
- (g) identify, prevent, and report potentially suspicious, fraudulent, or illegal activities;
- (h) notify you about important changes to our Terms; and
- (i) respond to your inquiries related to employment opportunities or other requests.
3.2. All data collected automatically will be used to administer or improve our services:
- (a) We use IP address to make our Site and Services more useful to you, and to perform identity verification;
- (c) We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience on our Site. This type of information is collected to make the Site more useful to you and to tailor the experience with us to meet your special interests and needs.
- (d) We may create the “Anonymous Data” records from Personal Data by excluding information (such as your name) that makes the data personally identifiable to you. We use this Anonymous Data to analyze request and usage patterns so that we may enhance the content of our Services and improve Site navigation. We reserve the right to use Anonymous Data and aggregated and other de-identified information for any purpose and disclose Anonymous Data to third parties in our sole discretion; and
- (e) Bitholic does not sell your data to any third party at all.
ARTICLE 4. THE WAY WE SHARE YOUR PERSONAL DATA
- (a) It may be necessary to disclose your information to comply with any law, subpoenas, court orders, or government request, defend against claims, investigate or bring legal action against illegal or suspected illegal activities, enforce our Terms, or to protect the rights, safety, and security of Bitholic, our Users, or the public;
- (b) We may share your Personal Data with third party service providers to provide you with the Services that we offer you through our Site; to conduct quality assurance testing; to facilitate creation of accounts; to provide technical support; to verify your identity; and/or to provide other services to us. These third party service providers are required not to use your Personal Data other than to provide the services requested by us;
4.2. We may contain links to other third party websites which are regulated by their own privacy policies. We are not responsible for the privacy policies of these third party websites even if they were accessed using the links from our site.
Please keep in mind that we are not responsible or can be held liable for any loss resulting from your decision or inability to use such features.
ARTICLE 6. SECURITY MEASURE WE TAKE TO PROTECT YOU
We take the protection of your personal information seriously. We use industry-standard data encryption technology and have implemented restrictions related to the storage of and the ability to access your personal information.
Please note that no transmission over the Internet or method of electronic storage can be guaranteed to be 100% secure.
ARTICLE 7. OVERSEA MIGRATION OF PERSONAL INFORMATION
We use oversea cloud services to provide better service and enhance your convenience. In this regard, we inform you of the transfer of personal information to overseas as follows:
7.1. Consent to transfer personal information to overseas according to use of Amazon overseas server
- (a) Item to be migrated (ask to confirm the item to be collected)
- (b) Email address, Password, first and Last Name, phone number, residence details (e.g. such as country, address, city, state and postal code, date of birth, government issued identification or passport, photographs, etc) when you use the Site.
7.2. Country, Date, and how to be transferred
- (a) Country: Amazon Global Cloud Service Area (Singapore)
- (b) Date: When each member joins and changes customer information
- (c) How: Global Cloud Local area server that transfers data through a secure private network.
7.3. Service Provider
- (a) Company: Amazon Web Services, Inc.
- (b) Address: P.O. Box 81226
- (c) Seattle, WA 98108-1226
- (d) Phone: (206) 266-4064
- (e) FAX: (206) 266-7010
7.4. Transfer Purpose
To provide global cloud service for management and operation of Bitholic service.
7.5. Retention and Use Period
Until the termination of the Bitholic service or your account cancellation hereafter will be retained and destroyed in accordance with internal policies and other relevant law regulation.
ARTICLE 8. DATA POTECTION OFFICER
8.1. We take our responsibilities under the Personal Data Protection Act 2012 (the “PDPA”) seriously. We also recognize the importance of the Personal Data which you have entrusted to us and believe that it is our responsibility to properly manage, protect and process your Personal Data.
8.2. If you, at any time, have any queries on this Policy and any other queries in relation to how we may manage, protect and/or process your Personal Data, you can contact our Data Protection Officer (the “DPO”) through [email protected] and/or our support center.