Effective date : 01.04.2021
Last updated: 08.04.2021
2. PERSONAL DATA
- directly from that data; or
- indirectly from that data and other information to which we have or are likely to have access.
- 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:
- e-mail address;
- information sent by or associated with the device(s) used to access our Services; and
- any other information about you when you sign up to use our Services, when you use our Services, as well as how you use our Services.
3. COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA
- We generally do not collect your personal data unless (a) it is provided to us voluntarily by you directly or via a third party who has been duly authorised by you to disclose your personal data to us (your “authorised representative”) after (i) you (and, where applicable, your authorised representative) have been notified of the purposes for which the data is collected, and (ii) you (and, where applicable, your authorised representative) have provided written consent to the collection and usage of your personal data for those purposes, or (b) collection and use of personal data without consent is permitted or required by applicable Privacy 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 processing of the applicable data without your consent is permitted or authorised by applicable Privacy Laws).
- For the avoidance of doubt, in the event that Privacy Laws or other applicable laws permit an organisation such as us to collect, use or disclose your personal data without your consent, such permission granted by the laws shall continue to apply.
- We may collect, use and/or process your personal data for any or all of the following purposes:
- [verifying your identity;
- performing obligations in the course of or in connection with our provision of Services;
- responding to, handling, and processing queries, requests, applications, complaints, and feedback from you, or to otherwise communicate with you as part of dealing with or facilitating customer service;
- notifying you of service issues and unusual account actions;
- to manage, operate, provide and/or administer your use of and/or access to our Services, as well as managing your relationship and user account with us;
- processing payment or credit transactions;
- to maintain and administer any software updates and/or other updates and support that may be required from time to time to ensure the smooth running of our Services;
- to protect the rights, property or safety of Wildchain, our Services as well as the ones of our users and others;
- to prevent, investigate or enforce any actual or suspected violations of our Terms of Service, fraud, unlawful activity, omission or misconduct, whether relating to your use of our Services or any other matter arising from your relationship with us;
- 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;
- to conduct research, analysis and development activities (i.e., data analytics, surveys, product and service development and/or profiling), to analyse how you use our Services, to improve our Services or products and/or to enhance your customer experience;
- any other business purposes related to or in connection with our Services, such as sending you marketing information about our Services; and
- any other purposes which we notify you of at the time of obtaining your consent.
- We may disclose your personal data:
- to third parties (i.e., third party services providers, agents), like AWS and Amazon EC2, whether sited in Singapore or outside of Singapore, where such disclosure is required to perform any of the functions listed in clause 3 above, or is otherwise required in the course of our provision of Services;
- In connection with, or during the negotiation of, any investment activity or any merger, financing, acquisition, divestiture, or dissolution of any or all of our investments or all or a portion of our business; and
- if required to do so by law or pursuant to an order of a court or by any governmental or regulatory authority having jurisdiction over us or in a good faith belief that such access preservation or disclosure is reasonably necessary to respond to any threatened or actual claims asserted against us.
- Subject to clauses 11 and 13, 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).
- As the purposes for which we will/may collect, use, disclose or process your personal data depend on the circumstances at hand, such purpose may not appear above. However, we will notify you of such other purpose at the time of obtaining your consent, unless processing of the applicable data without your consent is permitted by the Privacy Laws.
- If you are located in the EEA, the relevant information on the legal basis can be found in the clause 13
4. INFORMATION ON CHILDREN
- If you are located in the EEA, the relevant information on the processing of data related to children can be found in the clause 13
6. WITHDRAWING YOUR CONSENT
- The consent that you provide for the collection, use and disclosure of your personal data will remain valid until such time it is withdrawn by you in writing. In certain jurisdictions, 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 DPO at the contact details provided in clause 1 below.
- 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 10 days of receiving it.
- While 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 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 via email to our DPO at the contact details provided in clause 1 below.
- 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 Privacy Laws.
- If you are located in the EEA, the relevant information on the legal basis can be found in the clause 13
7. ACCESS TO AND CORRECTION OF PERSONAL DATA
- 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 DPO at the contact details provided in clause 1 below.
- 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.
- We will respond to your request as soon as reasonably possible. Should we not be able to respond to your request within 30 days after receiving your request, we will inform you in writing within 30 days of the time by which we will be able to respond to your request. 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 applicable Privacy Laws).
- If you are located in the EEA, the information on the rights granted to you can be found in the clause 13
8. PROTECTION OF PERSONAL DATA
- To safeguard your personal data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, we have introduced appropriate administrative, physical and technical measures such as up-to-date antivirus protection, encryption and the use of privacy filters to secure all storage and transmission of personal data by us, and disclosing personal data both internally and to our authorised third party service providers and agents only on a need-to-know basis.
- 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. To the maximum extent allowed by applicable law, you agree and acknowledge that Wildchain will not be liable or responsible if any information about you is intercepted, accessed, and/or used by an unintended recipient. If you have reason to believe that the security of your communications or personal data has been compromised, please notify us immediately using the contact information below.
9. LINKS TO OTHER SITES
9.1 Our Site may contain links to other sites. Please be aware that we are not responsible for the content or privacy practices of such other sites. We encourage our users to be aware when they leave our website and to read the privacy statements of any other linked sites that collect personal data.
10. ACCURACY OF PERSONAL DATA
- We generally rely on personal data provided by you (or your authorised representative), and you agree not to submit any information to us which is inaccurate or misleading. In order to ensure that your personal data is current, complete and accurate, please update us if there are changes to your personal data. We reserve the right at our sole discretion to require further documentation to verify the information provided by you.
11. RETENTION OF PERSONAL DATA
- 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 Privacy Laws.
- We will cease to retain your personal data, or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that (a) such retention no longer serves the purpose for which the personal data was collected; (b) is no longer necessary for legal or business purposes; and (c) no other legitimate interest warrants further retention of such personal data.
- If you are located in the EEA, the relevant information on the applicable retention periods can be found in the clause 13
12. TRANSFERS OF PERSONAL DATA OUTSIDE OF SINGAPORE
- In most cases, your personal data will be processed in Singapore, where our servers are located and our central database is operated. We generally do not transfer your personal data to countries outside of Singapore. However, if we do so, we will transfer your information overseas in accordance with Privacy Laws, including obtain your consent for the transfer to be made and taking steps to ensure that your personal data continues to receive a standard of protection that is at least comparable to that provided under the Personal Data Protection Act 2012 (PDPA).
- For more information about the transfer of personal data out of the EEA, please refer to the clause 13
13. ADDITIONAL PROVISIONS FOR EEA USERS ONLY
- Legal basis. We only use personal data collected through our Site when we have a legal basis to do so and for the purposes outlined above in clause 3.
First, we process personal data for the management of our relationship on the basis of our contract in order to:
- perform obligations in the course of or in connection with our provision of Services;
- manage, operate, provide and/or administer your use of and/or access to our Services, as well as managing your relationship and user account with us;
- verifying your identity;
- process payment or credit transactions;
- respond to, handle, and process queries, requests, applications, complaints, and feedback from you, or to otherwise communicate with you as part of dealing with or facilitating customer service; and
- notify you of service issues and unusual account actions.
Besides, we rely on your prior consent in order to:
- send you marketing information about our Services; and
In addition, we process personal data based on our legitimate interests in order to:
- maintain and administer any software updates and/or other updates and support that may be required from time to time to ensure the smooth running of our Services;
- protect the rights, property or safety of Wildchain, our Services as well as the ones of our users and others;
- prevent, investigate or enforce any actual or suspected violations of our Terms of Service, fraud, unlawful activity, omission or misconduct, whether relating to your use of our Services or any other matter arising from your relationship with us; and
- conduct research, analysis and development activities (i.e., data analytics, surveys, product and service development and/or profiling), to analyse how you use our Services, to improve our Services or products and/or to enhance your customer experience.
Finally, we process personal data to comply 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.
- Your rights. Please note that the GDPR provides for certain rights. In particular, you have the right to:
- access personal data processed concerning you;
- correct inaccurate personal data;
- delete any personal data concerning you;
- restrict processing;
- receive your personal data provided to us in an interoperable format (data portability);
- object to the processing on grounds relating to your particular situation; and
- lodge a complaint with a competent supervisory authority.
- Retention of personal data. We will retain your personal data during the period of our contractual relationship, extended by the applicable limitation period. With regard to marketing communications with prospects, we will keep your personal data for [three (3) years] after the last correspondence with us. With respect to the processing carried out in order to protect the rights, property or safety of Wildchain, our Services as well as the ones of our users and others, we will keep your personal data for the time of the relevant limitation period. As to the processing carried out as required by applicable laws, such as tax and accounting laws, we will keep your personal data for the duration of such obligation.
- Information on Children. Our Services are not intended for children under the age of 16 who are located in the EEA. We do not knowingly collect or maintain any personal data or non-personally-identifiable information from anyone under the age of 16 who is located in the EEA, nor is any part of our Site, Game or Services directed to children under the age of 16 who are located in the EEA. We will close any accounts used exclusively by such children and will delete any personal data we believe was submitted by any child under the age of 16 who is located in the EEA.
14. DO NOT TRACK
14.1 “Do Not Track” is a privacy preference that you can set in your internet search browser that sends a signal to a website that you do not want the website operator to track certain browsing information about you. However, because our website is not configured to detect “Do Not Track” signals from a user’s computer, we do not respond to “Do Not Track” requests. More information about “Do Not Track” is available at www.allaboutdnt.org concerning such information.
15. CALIFORNIA SHINE THE LIGHT
15.1 California Civil Code Section 1798.83, also known as “Shine The Light” law, permits California residents to annually request information regarding the disclosure of your personal information (if any) to third parties for the third parties’ direct marketing purposes in the preceding calendar year. We do not share personal information with third parties for the third parties’ direct marketing purposes.
16. DATA PROTECTION OFFICER
- You may contact our DPO if you have any enquiries or feedback on our personal data protection policies and procedures, or if you wish to make any request, in the following manner:
Email address: email@example.com
Telephone number: [●]