LAEVITAS PRIVACY POLICY
Last updated : 07 July 2022
We recognise our responsibilities in relation to the collection, holding,
processing, use and/or transfer of personal data. Your privacy is of
utmost importance to us.
This policy (the
Policy)
outlines how
we collect, use, store and disclose your personal data. Please take a
moment to read about how we collect, use and/or disclose your personal
data so that you know and understand the purposes for which we may
collect, use and/or disclose your personal data. By accessing the website
at
Laevitas and any sub-domains
(the
Website), you agree and consent to
Laevitas Pte. Ltd. (the
Company), its related corporations,
business units
and affiliates, as well as their respective representatives and/or agents
(collectively referred to herein as
Laevitas , us, we or
our), collecting,
using, disclosing and sharing amongst themselves the personal data, and to
disclosing such personal data to relevant third party providers. This
Policy supplements but does not supersede nor replace any other consent
which you may have previously provided to us nor does it affect any rights
that we may have at law in connection with the collection, use and/or
disclosure of your personal data. We may from time to time update this
Policy to ensure that this Policy is consistent with our future
developments, industry trends and/or any changes in legal or regulatory
requirements. Subject to your rights at law, the prevailing terms of this
Policy shall apply. For the avoidance of doubt, this Policy forms part of
the terms and conditions governing your relationship with us and should be
read in conjunction with such terms and conditions.
The
security of your personal data is important to us. At each stage of data
collection, use and disclosure, Laevitas has in place physical,
electronic, administrative and procedural safeguards to protect the
personal data stored with us. However, do note that no transmission of
personal data over the internet can be guaranteed to be 100% secure –
accordingly and despite our efforts, Laevitas cannot guarantee or warrant
the security of any information you transmit to us, or to or from our
online services. Laevitas shall not have any responsibility or liability
for the security of information transmitted via the internet.
This Policy describes how Laevitas may collect, use, disclose, process and
manage your personal data, and applies to any individual’s personal data
which is in our possession or under our control.
1. What personal data is collected by Laevitas "Personal data"
means data, whether true or not, about an individual who can be identified
(i) from that data, or (ii) from that data and other information to which
the organisation has or is likely to have access. Some examples of
personal data that Laevitas may collect are:
- (a) personal particulars (e.g. name, alias(es), gender, contact details,
residential
address, date of birth, identity card/passport details, social media
handles and other social media profile information, and/or education
details);
- (b) e-mail address;
- (c) information about your use of our services
and Website, and specific user interactions with the Website such as
features utilised, areas visited or clicked on, and time spent;
- (d) usernames and password, third party account credentials (such as your
Facebook login credentials, Google login credentials), Internet Protocol
address (IP address), and geographical location;
- (e) browser type and version, operating system used by the accessing system,
internet
service provider of the accessing system, the website from which an
accessing system reaches our website (i.e. "referrers"), location of
access, or other similar data and information;
- (f) behaviour such as pages (and sub-page) visited, time and date of your visit,
time spent on
each page, and other diagnostic data;
- (g) information or details regarding digital assets held;
- (h) particulars of digital wallet addresses (including transactions
performed by said digital wallet addresses), public cryptographic key
relating to digital wallet addresses on distributed ledger networks and/or
similar information; and/or
- (i) personal opinions made known to us (e.g. feedback or responses to surveys).
Personal data may be collected when you interact with our services or use the Website, or may
be received by Laevitas from third-party databases or service providers
that provide business information.
2. Personal data and the
Blockchain Blockchain technology, also known as distributed
ledger technology (DLT), is at the core of our business. Blockchains are
decentralized and made up of digitally recorded data in a chain of
packages called "blocks". The manner in which these blocks are linked is
chronological, meaning that the data is very difficult to alter once
recorded. Since the ledger may be distributed all over the world (across
several "nodes" which usually replicate the ledger) this means there is no
single person making decisions or otherwise administering the system (such
as an operator of a cloud computing system), and that there is no
centralized place where it is located either.
Accordingly, by design, a blockchain’s data cannot be changed or deleted
and is said to be "immutable". This may affect your ability to exercise
your rights such as your right to erasure ("right to be forgotten"), or
your rights to object or restrict processing of your personal data. Data
on the blockchain cannot be erased and cannot be changed. Although smart
contracts may be used to revoke certain access rights, and some content
may be made invisible to others, it is not deleted.
In certain
circumstances, in order to comply with our contractual obligations to you
(such as delivery of tokens or provision of other services) it will be
necessary to collect certain personal data, such as your wallet address,
onto the blockchain; this is done through a smart contract and requires
you to execute such transactions using your wallet’s private key.
The ultimate decisions to (a) transact on the blockchain using your wallet
address, as well as (b) share the public key relating to your wallet
address with anyone (including us) rests with you.
IF YOU WANT TO
ENSURE
YOUR PRIVACY RIGHTS ARE NOT AFFECTED IN ANY WAY, YOU SHOULD NOT TRANSACT
ON BLOCKCHAINS AS CERTAIN RIGHTS MAY NOT BE FULLY AVAILABLE OR EXERCISABLE
BY YOU OR US DUE TO THE TECHNOLOGICAL INFRASTRUCTURE OF THE BLOCKCHAIN. IN
PARTICULAR THE BLOCKCHAIN IS AVAILABLE TO THE PUBLIC AND ANY PERSONAL DATA
SHARED ON THE BLOCKCHAIN WILL BECOME PUBLICLY AVAILABLE.
3. Purposes for collection, use and disclosure of your personal data
Laevitas may collect, use and/or disclose your personal data for its
legitimate interests or business purposes, including operations for these
purposes. These may include, without limitation, the following:
- (a) developing and providing facilities, products or services (whether
made available by us or through us) or your participation in interactive
features of our services, including without limitation:
- (i) various products and/or services (whether digital or not, and whether
provided through an external service provider or otherwise);
- (ii) making payments for participation in any blockchain, network or platform
developed or managed by us (as applicable);
- (iii) any escrow, courier, anti-counterfeiting, cyber-security or dispute
resolution services;
- (iv) carrying out research, planning and statistical analysis;
- (v) trouble-shooting, technical maintenance and bug fixes; and/or
- (vi) analytics for the purposes of developing or improving our
products, services, security, service quality, staff training, and
advertising strategies;
- (b) assessing and processing applications, instructions, transactions, or
requests from you or our customers;
- (c) communicating with you, including providing you with updates on
changes to services or products (whether made available by us or through
us) including any additions, expansions, suspensions and replacements of
or to such services or products and their terms and conditions;
- (d) managing our infrastructure and business operations and complying with
internal policies and procedures;
- (e) responding to queries or feedback;
- (f) addressing or investigating any complaints, claims or disputes in connection
with the
services;
- (g) complying with all applicable laws, regulations,
rules, directives, orders, instructions and requests from any local or
foreign authorities, including regulatory, governmental, tax and law
enforcement authorities or other authorities;
- (h) monitoring products and services provided by or made available through
us;
- (i) financial reporting, regulatory reporting, management
reporting, risk management (including monitoring credit exposures,
preventing, detecting and investigating crime, including fraud and any
form of financial crime), audit and record keeping purposes;
- (j) enabling any actual or proposed assignee or transferee, participant or
sub-participant of Laevitas's rights or obligations to evaluate any
proposed transaction;
- (k) enforcing obligations owed to us, protecting our rights or property,
and protecting against legal liability; and/or
- (l) seeking professional advice, including legal or tax advice.
We may also use personal data for purposes set out in the terms and
conditions that govern our relationship with you or our customer.
4. Use of personal data for marketing purposes
We may use your personal data to offer you products or services, including
special offers, promotions, contests or entitlements that may be of
interest to you or for which you may be eligible. Such marketing messages
may be sent to you in various modes including but not limited to
electronic mail, direct mailers, short message service, telephone calls,
facsimile and other mobile messaging services. In doing so, we will comply
with all applicable data protection and privacy laws.
In respect of sending telemarketing messages to your telephone number via
short message service, telephone calls, facsimile and other mobile
messaging services, please be assured that we shall only do so if we have
your clear and unambiguous consent in writing or other recorded form to do
so or if you have not otherwise made the appropriate registration of that
number with the Do Not Call Registry. If we have an ongoing relationship
with you and you have not indicated to us that you do not wish to receive
telemarketing messages sent to your telephone number, we may send you
telemarketing messages to that number related to the subject of our
ongoing relationship via short message service, facsimile and other mobile
messaging services (other than a voice or video call).
You may at any time request that we stop contacting you for marketing
purposes via selected or all modes.
To find out more on how you can change the way we use your personal data
for marketing purposes, please contact us.
Nothing in this Policy
shall vary or supersede the terms and conditions that govern our
relationship with you.
5. Disclosure and sharing of personal data
We may from time to time and in compliance with all applicable laws on
data privacy, disclose your personal data to any personnel of Laevitas,
group entities, or to third parties (including without limitation banks,
financial institutions, credit card companies, credit bureaus and their
respective service providers, companies providing services relating to
insurance and/or reinsurance to us, and associations of insurance
companies, agents, contractors or third party service providers who
provide services to us such as telecommunications, information technology,
payment, data processing, storage and archival, and our professional
advisers such as our auditors and lawyers, and regulators and
authorities), located in any jurisdiction, in order to carry out the
purposes set out above. Please be assured that when we disclose your
personal data to such parties, we will disclose only the personal
information that is necessary to deliver the service required, and will
also require them to ensure that any personal data disclosed to them are
kept confidential and secure.
For more information about the third parties with whom we share your
personal data, you may, where appropriate, wish to refer to the
agreement(s) and/or terms and conditions that govern our relationship with
you or our customer. You may also contact us for more information (please
see section 10 below).
We wish to emphasise that Laevitas does not sell personal data to any
third parties and we shall remain fully compliant of any duty or
obligation of confidentiality imposed on us under the applicable
agreement(s) and/or terms and conditions that govern our relationship with
you or our customer or any applicable law.
You are responsible for ensuring that the personal data you provide to us
is accurate, complete, and not misleading and that such personal data is
kept up to date. You acknowledge that failure on your part to do so may
result in our inability to provide you with the products and services you
have requested. To update your personal data, please contact us (please
see section 10 below for contact details). Where you provide us with
personal data concerning individuals other than yourself, you are
responsible for obtaining all legally required consents from the concerned
individuals and you shall retain proof of such consent(s), such proof to
be provided to us upon our request.
We may transfer, store, process
and/or deal with your personal data in any jurisdiction, and accordingly
such personal data may be transferred to computers, servers or hardware
located outside of your state, province, country or other governmental
jurisdiction where the data protection laws may differ from those in your
jurisdiction. Laevitas will take all steps reasonably necessary to ensure
that your data is treated securely and in accordance with this Policy and
no transfer of your personal data will take place to an organisation or a
country unless there are adequate controls in place including the security
of your data and other personal information (including without limitation
the Standard Contractual Clauses approved by the European Commission).
Your consent to this Policy followed by your submission of such
information represents your agreement to the transfer of personal data as
described herein.
6. Cookies and related technologies The Website uses cookies.
A cookie is a small text file placed on your computer or mobile device
when you visit a Website or use an app, which may include an anonymous
unique identifier. Cookies collect information about users and their visit
to the Website or use of the app, such as their Internet protocol (IP)
address, how they arrived at the Website (for example, through a search
engine or a link from another Website), how they navigate within the
Website or app, browser information, computer or device type, operating
system, internet service provider, website usage, referring/exit pages,
platform type, date/time stamp, number of clicks, ads viewed, and how they
use our services. We use cookies and other technologies to facilitate your
internet sessions and use of our apps, offer you customised products
and/or services according to your preferred settings, display features and
services which might be of interest to you (including ads on our
services), track use of our websites and apps, to compile statistics about
activities carried out on our websites, and to hold certain information.
Examples of cookies which we use include, without limitation, Session
Cookies to operate our service, Preference Cookies to remember your
preferences and various settings, as well as Security Cookies for security
purposes.
You may set up your web browser to block cookies from monitoring your
website visit. You may also remove cookies stored from your computer or
mobile device. However, if you do block cookies you may not be able to use
certain features and functions of our web sites.
We further utilise a variety of other similar tracking technologies,
including without limitation beacons, tags, and scripts to collect and
track information and to improve and analyse our services.
7. Other websites
Our websites may contain links to other websites which are not maintained
by Laevitas. This Policy only applies to the websites of Laevitas. When
visiting these third party websites, you should read their privacy
policies which will apply to your use of such websites.
8. Retention of personal data
Your personal data is retained as long as the purpose for which it was
collected remains and until it is no longer necessary for any legal or
business purposes. This enables us to comply with legal and regulatory
requirements or use it where we need to for our legitimate purposes, such
as transfers of digital assets, and dealing with any disputes or concerns
that may arise.
We may need to retain information for a longer
period where we need the information to comply with regulatory or legal
requirements or where we may need it for our legitimate purposes (e.g. to
help us respond to queries or complaints, fighting
fraud and financial crime, responding to requests from regulators etc).
When we no longer need to use personal data, we will remove it from our
systems and records and/or take steps to anonymise it so that you can no
longer be identified from it.
9. Queries, Access/Correction Requests and Withdrawal of Consent
If you:
- (a) have queries about our data protection processes and practices;
- (b) wish to request access to and/or make corrections to your personal
data in our possession or under our control; or
- (c) wish to withdraw your consent to our collection, use or disclosure of your
personal data,
please submit a written request (with supporting documents, (if any) to
our Data Protection Officer at:
[email protected] . Our Data
Protection
Officer shall respond to you within 30 days of your submission. Please
note that if you withdraw your consent to any or all use or disclosure of
your personal data, depending on the nature of your request, we may not be
in a position to continue to provide our services or products to you or
administer any contractual relationship in place. Such withdrawal may also
result in the termination of any agreement you may have with us. Our legal
rights and remedies are expressly reserved in such event.
We may charge you a fee for processing your request for access. Such a fee
depends on the nature and complexity of your access request. Information
on the processing fee will be made available to you.
10.
Contact information To contact us on any aspect of this Policy
or your personal data or to provide any feedback that you may have, please
contact our Data Protection Officer at
[email protected]
11. Governing Law and Jurisdiction This Policy and your use of the
Website
shall be governed and construed in accordance with the laws of Singapore.
You agree to submit to the exclusive jurisdiction of the Singapore
courts.
12. Amendments and updates to Laevitas Privacy Policy We reserve the
right
to amend this Policy from time to time to ensure that this Policy is
consistent with any developments to the way Laevitas uses your personal
data or any changes to the laws and regulations applicable to Laevitas. We
will make available the updated Policy on the Website. You are encouraged
to visit the Website from time to time to ensure that you are well
informed of our latest policies in relation to personal data protection.
All communications, transactions and dealings with us shall be subject to
the latest version of this Policy in force at the time.
13. For European
Union or European Economic Area Residents This section 13 applies if you
are an individual located in the European Union or European Economic Area.
Subject to applicable law, you have the following additional rights in
relation to your personal data:
- (a) the right to access your personal data
(if you ask us, we will confirm whether we are processing your personal
data in a structured, commonly used and machine-readable format and, if
so, provide you with a copy of that personal data (along with certain
other details). If you require additional copies, we may need to charge a
reasonable fee;
- (b) the right to ensure the accuracy of your personal data;
- (c)the right to have us delete your personal data (we will do so in
some circumstances, such as where we no longer need it, but do note that
we may not delete your data when other interests outweigh your right to
deletion);
- (d) the right to restrict further processing of your personal
data (unless we demonstrate compelling legitimate grounds for the
processing);
- (e)rights in relation to automated decision-making and
profiling (you have the right to be free from decisions based solely on
automated processing of your personal data, including profiling, that
affect you, unless such processing is necessary for entering into, or the
performance of, a contract between you and us or you provide your explicit
consent to such processing);
- (f) the right to withdraw consent (if we rely
on your consent to process your personal data, you have the right to
withdraw that consent at any time, but provided always that this shall not
affect the lawfulness of processing based on your prior consent); and
- (g) the right to complain to a supervisory authority in your country of
residence in the event that data is misused.
If you believe that our
processing of your personal information infringes data protection laws,
you have a legal right to lodge a complaint with a supervisory authority
responsible for data protection. You may do so in the EU member state of
your residence, your place of work or the place of the alleged
infringement. You may exercise any of your rights in relation to your
personal data by contacting our Data Protection Officer at:
[email protected], and we
shall respond to you within 30 days of your
submission.
14. Your acceptance of these terms This Policy
applies in
conjunction with any other notices, contractual clauses and consent
clauses that apply in relation to the collection, use and disclosure of
your personal data by us. We may revise this Policy from time to time
without any prior notice. You may determine if any such revision has taken
place by referring to the date on which this Policy was last updated. By
using the Website and/or any services provided by Laevitas, you signify
your acceptance of this Policy and terms of service. If you do not agree
to this Policy or terms of service, please do not use the Website or any
services provided by Laevitas. Your continued use of the Website following
the posting of changes to this Policy will be deemed your acceptance of
those changes.