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ChainUp Privacy Policy
Effective from September 7, 2022

Chainup Pte. Ltd. ("Chainup"), a private company limited by shares incorporated in Singapore (UEN 201903588G) and whose registered office address is 1 Raffles Place, #50-00 One Raffles Place Singapore 048616.

This Privacy Policy applies to visitors to the website, https://custody.chainup.com, and individuals (including consumers and merchants who are natural persons) (each a "User") who are users of or have their personal information provided to us in the course of using our services (“Chainup Services”).

This Privacy Policy also applies to Chainup’s partners (“Partner”) and their personnel, officers, connected persons (“Partner Personnel”) where their personal information is provided to us in connection with the services.

Unless otherwise indicated or the context requires otherwise, reference to "you" or "your" are intended to refer to a User and Partner Personnel, and reference to " Chainup", "we", "us" or "our" in this Privacy Policy refer to Chainup Pte. Ltd. Our affiliates that are involved in providing the services are each referred to as an "Affiliate". Chainup and Affiliates are collectively referred to as the “Chainup Group”.

By continuing to use Chainup Services, you signify that you have read and understood this Privacy Policy.

1. WHAT DATA DO WE COLLECT ?

We collect and use personal information about you when you use Chainup Services, interact with us, request products or services directly from us, contact us directly with respect to any queries, participate in or opt out of any of our marketing promotions, or otherwise communicate with us.

The personal information we collect include:
a) your basic personal details, including first and last name;
b) contact information, including your address, phone number, email, or other information that permits us to contact you;
c) copies of your ID documents ; and
d) technical information, including information about the device you use to interact with us and our services (including IP address, geographical location, device type and model, screen resolution, app version, device language, device identification codes, device status information and other features/data that can be used to identify a device); and information from your visits to our websites or mobile applications (including browser/platform type and version, internet service provider, operating system, referral source/exit pages, length of visit/usage, page views and any search term you use, device logs in the event of a crash or error report).

2. HOW WE OBTAIN YOUR DATA

We collect personal information about you in connection with Chainup Services. We collect your personal information when you browse our website, use our mobile applications, enquire about any Chainup Services, sign a contract with us, sign up to receive messages from us; or when you communicate with us via e-mail, phone, SMS, or any other electronic means.

We also receive personal information about you from other sources, including:
• any other third parties, including those who support the ability to make payments and conduct transactions through the relevant Chainup Services;
• Affiliates;
• suppliers providing services on our behalf;
• third parties for fraud monitoring and prevention purposes, or other purposes required by law;
• in relation to Partner Personnel, from the relevant Partner; and
• publicly available sources.
We may combine information that we have about you from various sources, including the information you have provided to us.

3. HOW WE USE YOUR DATA
We use the information we collect to operate our business. This includes but shall not be limited to the following:
a) for the exercise of rights and performance of obligations under, and managing compliance with, our Chainup Group rules and related documentation;
b) to enable, build, provide, operate and test products and services, provide and operate the Chainup Services and related User services, enable transactions, facilitate the build, provision, operation and testing of products and services by others (including Affiliates);
c) to facilitate the provision of products by our Partners;
d) to respond to your queries, feedback, claims or disputes or otherwise provide customer support and services;
e) for research, statistical analysis, analytics, business planning and business intelligence purposes in order to understand how users like you perceive our products and services, industry trends, usage patterns and other factors that may affect our business;
f) to contact you in relation to our provision of Chainup Services, contact you in connection with any communication preferences or requests you have expressed, ask you for feedback about Chainup Services or other related products and services, collect feedback from you and your staff about our products and services and using such feedback to improve our business and/or customize products and services; send you information about products and services, including for promotional purposes, present you with offers or promotions (including customized offers and promotions); and contact you for legal purposes;
g) to operate marketing and advertising activities;
h) to manage our business, including billing, invoicing, account management, reconciliation, collection, audit purposes and internal reporting;
i) for security, authentication and risk control purposes, including to manage anti-money laundering and fraud risk, to perform creditworthiness and solvency checks, to assess, detect, investigate, prevent, remediate or report data breaches, fraud, other potentially prohibited or illegal activities and violations of our agreements and policies, industry standards, guidelines, laws and regulations, to protect the integrity and maintain the security of our services, products and platforms, to protect our rights or property and those of others and to prevent any harm or financial loss to us or others;
j) to provide you with customised content;
k) to make disclosures as may be required by any rules, law, regulation, subpoena, court order, other legal process or contractual or commercial requirements, including to regulatory authorities, government officials, courts, card associations or other payment schemes. Such requirements may relate to "know your customer" checks, anti-money laundering, counter-terrorist financing reporting, tax requirements or other commercial disputes;
l) for any proposed or actual merger, acquisition, corporate reorganization, financing, sale joint venture, assignment, transfer, disposition or similar transaction, including the sale of business, assets or stock; and
m) otherwise for everyday business purposes, to comply with law, or in other ways for which we provide specific notice at the time of collection.
4. TO WHOM DO WE SHARE DATA

We share your personal information to operate and manage our business, including for the purposes indicated under section 3. We may share your information with:
a) your merchants that provide you with goods and services and their acquirers (if applicable), and other third parties, including those who support the ability to conduct transactions through the relevant Chainup Services
b) third party online merchants whose services or mobile applications you elect to use;
c) service providers elected by you;
d) third parties where you have instructed us to share information with them;
e) Affiliates;
f) any agent, contractor or third party service provider that we work with in providing Chainup Services;
g) if applicable, banks and other financial institutions, card associations, payment networks or others, including those involved in processing of payments and conducting transactions through the relevant Chainup Services; and
h) law enforcement agencies, insurers, government and regulatory or supervisory authorities where under an obligation to make disclosure under the requirements of any applicable law, regulation or commercial arrangement;
i) parties relevant to litigation proceedings and the assessment of claims or disputes, including courts;
j) individuals and entities involved in any merger, acquisition, corporate reorganization, financing, or similar transaction with us, including in the event of the sale of all or part of our assets; and
k) our own and others' professional advisors.

We would not share your personal information with the exception of the above for Chainup Group’s ordinary course of business unless we have your expressed prior authorisation or consent. Notwithstanding the foregoing, your prior authorized consent is not required for the sharing, transfer, or public disclosure of your personal information in the following cases.
a) directly related to national security or defence security
b) directly related to public safety, public health, or vital public interest
c) where it is necessary to protect your or other individuals' significant legitimate rights and interests, such as life and property, but where it is difficult to obtain your consent
d) personal information that you disclose to the public at your own discretion
e) where personal information is collected from information that is lawfully and publicly disclosed
f) necessary to enter into and perform a contract at the request of the subject of the personal information
g) in other cases as provided for by law and regulations.

In accordance to the Personal Data Protection Act 2012 (“PDPA”) in Singapore, sharing or transferring personal data refers to personal data of an individual who can be identified (a) from that data; or (b) from that data and other information to which the organisation has or likely to have access. Pseudonymised data will not be treated as a personal data provided Chainup Group puts in place measures to prevent reidentification. To align with the global data protection legislations, Chainup shall put in strict measures and treat such pseudonymised data as equivalent to personal data so long such data cannot be reidentified. The sharing, transferring or publicly disclosing of such deidentified data will not require separate notification to you and your consent.
5. HOW DO WE STORE AND PROTECT YOUR DATA

We will only retain your information for as long as is necessary for providing Chainup Services to you and will not hold or process your information for any longer than we are legally required to.

We established a comprehensive information security management system and access control and will take reasonable and practicable security measures and technical means to store and protect your personal information in accordance with industry standards to prevent the loss, unauthorised access, public disclosure, use, modification, destruction, loss or leakage of your information consistent with applicable data protection and privacy laws and regulations. Notwithstanding the foregoing, we may retain your information for up to 7 years to ensure that any contractual disputes can be addressed. We will take all reasonably practicable steps to protect your personal information.

6. HOW DO WE PROCESS DATA ABOUT CHILDREN?
Our service is not directed towards children under 18 years old, nor does Chainup knowingly collect information from children under 18. If you are under 18, please do not use Chainup Services or submit any personal information to us.
7. THIRD PARTY SERVICES AND SITES
We may provide links to third party websites and services (including the websites, services and mobile applications of our Partners) for your convenience and information. These services and websites may operate independently from us and have different data protection and privacy practices from us. We are not responsible for the content and privacy practices of these other websites and services and encourage you to consult the Privacy Policy of those sites.
8. DATA TRANSFERS
Chainup Group has multiple offices globally and your information may be processed outside of the country where you live. Regardless of where your information is processed, we will implement appropriate measures to ensure that your personal information remains protected and secure in accordance with applicable data protection and privacy laws and regulations.
9. YOUR RIGHTS WITH RESPECT TO YOUR PERSONAL INFORMATION

When you use Chainup Services or interact with our Affiliates through our products or services, you consent to our receiving, using, aggregating, and analyzing your personal information, as necessary for our business and cooperation.
In accordance with applicable data protection and privacy laws and regulations, you may be entitled to:
• ask us about the processing of your personal information, including to request a copy of your personal information;
• request the correction and/or (in some cases) deletion of your personal information;
• in some cases, request the restriction of the processing of your personal information, or object to that processing;
• withdraw your consent to the processing of your personal information; and
• request receipt or transmission to another organization, in a machine-readable form, of the personal information that you have provided to us where we are using your personal information based on consent or performance of a contract; and
Where you are given the option to share your personal information with us, you can always choose not to do so. You also have the right to withdraw any consent previously given to us to share your personal information.

However, choosing not to share your personal information with us or withdrawing your consent to our use of it could mean that we are unable to perform the actions necessary to achieve the purposes of processing described or that you are unable to make use of the services and products offered by us. Please note that withdrawing your consent will not affect the lawfulness of processing based on consent before its withdrawal.

10. COOKIES

We may use "cookies", where a small data file is sent to your browser to store and track information about you when you enter our websites. The cookie is used to track information such as the number of users and their frequency of use, profiles of users and their preferred sites. While this cookie can tell us when you enter our sites and which pages you visit, it cannot read data off your hard disk.

You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.

11. CONTACT US
If you have questions or requests about the privacy of your personal information, please contact us by email via singapore@chainup.com. As required under applicable law, please note that we may take steps to ask you to provide further information to verify your identity before granting you access to information or acting on your request to exercise your rights.
12. CHANGES TO THIS PRIVACY POLICY
We may change, amend or revise this Privacy Policy from time to time. We will notify you of any substantive or material change in this Privacy Policy by updating this web page, sending push notifications, e-mails or letters, by phone or by publishing announcements on our website. You can also review this Privacy Policy at the home page of our website.