Information We Collect
When you access our Interfaces and access, receive and use our Products and Services, we may collect the following information:
- Contact Information – Information you provide to us, such as name and email address;
- Transaction Information - A record of your transactions using our Services such as timestamp, type and quantity of your transactions and the underlying cryptocurrency;
- Financial Information - Your Ethereum network address, cryptocurrency wallet information, transaction history and fees paid;
- Online Information - Your geolocation, IP Address and operating system browser fingerprint;
- Communications Information - Information regarding your communications and other interactions with us;
- Usage and Diagnostics - Information regarding your usage of our Services, such as user preferences, conversion events, and data collected via cookies and other technologies;
- Information From Third Parties - Information about you from other sources as required or permitted by applicable law. We may use this information in conjunction with other information (such as information we obtain from the Interfaces) to comply with applicable laws and limit the use of our Services in connection with fraudulent, improper or illegal activities; and
We may use collected information to:
- Provide Services - Provide, maintain, monitor and improve our Services, including to process transactions; open and maintain user accounts; and send confirmations, notices, updates, alerts and other support messages;
- Customer Support - Provide, monitor and improve customer support;
- Safety and Security - Help protect the safety, security and integrity of our Services, including by monitoring for fraudulent, unauthorized or illegal activities; complying with legal requirements; monitoring and verifying identity or service access; fighting spam, malware or security threats; and enforcing our agreements with third parties and enforcing our Terms of Service;
- Troubleshooting - Detect, prevent and address technical issues;
- Legal and Compliance - Investigate or engage in legal and compliance related functions, including by comparing your information with information obtained from other sources, addressing and resolving claims and disputes, or as requested by regulators and government entities; or
- Other Permitted Uses - As described below under the “Information Sharing and Disclosure” heading or in any other way we may describe when you provide the information or with your consent.
Information Sharing and Disclosure
We may disclose collected information:
- Provide Services - To provide Services, including to help service transactions and provide customer service and support;
- Affiliates and Service Providers - To third party service providers and affiliates that support our activities or technology platform. Examples include hosting our web servers, analyzing data, providing marketing assistance, further development of our Interfaces and Systems and providing customer service;
- Our Protection and the Protection of Others - To legal or regulatory authorities if required by them or we deem it appropriate, or if legally required to do so, pursuant to a request from a governmental entity, or if we believe in good faith that such action is necessary to:
- Conform to legal requirements or comply with legal processes (including subpoenas);
- Enforce or apply our terms of service and other agreements;
- Protect our property rights, rights and safety or property, rights and safety of a third party, our affiliated companies, or the public in general; or
- Stop any activity that we consider illegal, unethical, or legally actionable;
- Aggregated or Anonymized Information – On an aggregated or anonymized basis with our partners, other site visitors and other third parties, including so that they can understand our volume and usage of our Services. Such information will not be considered your information because it will be anonymized and aggregated in such a way that it cannot reasonably linked back to a specific user;
- With Your Consent - For any other purpose or to third parties if you consent to such disclosure; and
- Business Transactions - In the event of a reorganization, financing, investment, merger, sale, joint venture, partnership, assignment, transfer, or other disposition of all or any of our business, assets or stock, or bankruptcy or similar proceedings.
Transfer of Information
Collected information may be transferred to and maintained on computers located outside of your jurisdiction of residence where the data protection laws may differ from those of your home jurisdiction. Regulators or government entities in that jurisdiction may be able to obtain access to your information through the laws of the jurisdiction. When we engage a third-party service provider, we include customary confidentiality and non-disclosure obligations from that service provider regarding any collected information that is provided to it.
Retention of Information
Our Policy Toward Children
No persons under 18 are eligible to utilize our Services and we do not knowingly collect information from anyone under the age of 18. In the event that we become aware that we have collected information from children without verification of parental consent, we take steps to remove that information from our servers.
Security of Data
The security of user information is important to us but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your information, we cannot guarantee its security.
Links to Other Sites
Additional Matters Relating to Residents of the European Economic Area
The controller responsible for processing your Personal Data is Paradigm Connect Asia Pte. Ltd., with a principal place of business at 71 Robinson Rd, Suite 15-106, Singapore 068895.You can contact us by email at email@example.com.
Processing of Your Personal Data
We rely on different legal bases to process your Personal Data (as set out in the “Information We Collect” section) depending on the specific purposes for which we process your Personal Data.
- Providing you with requested Services - When you connect your wallet and use our Services, we process your online information, transaction information and financial information, as well as other Personal Data you choose to provide, if any, to deliver your requested Services. To the extent this requires processing your Personal Data, we rely on the performance of your requested Services.
- Responding to queries and for customer support purposes - If you contact us, we may collect the information you provide to us (such as contact information and process the content of your communication and related details, such as time and date of the communication and with whom you corresponded). In this case, we use your Personal Data to provide relevant customer service, respond to inquiries and fulfill requests. To the extent your communication requires the processing of your Personal Data, we rely on the performance of your requested functions to process your Personal Data.
- Enabling your use of our Interfaces – When you use our Interfaces, we may collect technical information associated with the device you use, including technical identifiers that identify the device or location, such as IP address. Depending on your cookie settings, we may also collect information concerning your browsing behavior and engagement information. We process your Personal Data collected through our Interfaces to enable access to our Interfaces and to correctly deliver content and functionalities. This processing is based on our legitimate interests.
Recipients of Your Personal Data and Data Transfers
We only share Personal Data with others if it is legally required or if there is another legal basis for doing so.
Your Personal Data is processed by third-party processors that operate on our behalf. For example, we rely on processors to safely store your Personal Data and to send you our newsletters. We carefully select our processors and contractually require them to maintain the safety and integrity of your Personal Data. Our processors are only authorized to process your Personal Data according to our explicit instructions.
Moreover, we collaborate with others that assist us in delivering and improving our Services to you and to comply with potentially applicable laws and regulations.
In order to process your Personal Data for the purposes outlined above, we may transfer your Personal Data to services located outside of the European Economic Area, such as any country where we have partners or service providers.
- A contractual arrangement being in place between us and the third-country recipient that is based on the standard contractual clauses for international data transfers adopted by the European Commission; or
- Any other transfer mechanism or transfer tool that legitimizes the international transfer of your Personal Data in compliance with applicable data protection law.
Where we rely on appropriate safeguards for the transfer of your Personal Data, we will assess whether these safeguards can sufficiently protect your personal data so that the level of protection guaranteed in the European Union is not undermined by the transfer. If this is not the case, we will take the additional measures necessary to provide appropriate protection for your Personal Data. If it is not possible to provide for appropriate protection of your Personal Data, we will not transfer your personal data to the recipient in a third country, or will transfer your Personal Data only if and to the extent that another mechanism justifies the transfer of your Personal Data in accordance with applicable data protection law. To obtain a copy of these data protection safeguards or to obtain information about their applicability, please send a request via email to firstname.lastname@example.org.
Your Rights as a Data Subject
- You have the right to request access to your Personal Data that we process.
- You have the right to obtain the rectification of any inaccurate Personal Data about you. Your rectification request must be supported by evidence of the inaccuracies in the data you are seeking to have corrected.
- Where we process your Personal Data based on your consent, you have the right to withdraw such consent at any time.
- Under the conditions foreseen in the applicable data protection legislation, you have the right to obtain the erasure of your Personal Data.
- Under the conditions foreseen in the applicable data protection legislation, you have the right to obtain the restriction of processing of your Personal Data.
- Where we process your Personal Data based on our legitimate interests, you have the right to object to the processing of your Personal Data on grounds relating to your particular situation. However, you can always object to processing for direct marketing at any time without any charge or justification.
- If we process your Personal Data with your consent or to fulfill a contract and the processing is carried out by automated means, you have the right to receive the Personal Data you provided to us in a structured, commonly used, and machine-readable format and to transfer this information to another controller.
- We do not use automated decision-making processes that have a legal or similarly significant effect on you.
To exercise any of the rights mentioned above, you can send a request via email to email@example.com. Please state clearly which right you wish to exercise and provide reasons or proof to support your request if required. We will acknowledge receipt of your request and proceed to review it. If your request is valid, we will honor it as soon as possible. In case we have doubts about your identity, we may request additional information to verify it.
If you are not satisfied with how we handle your Personal Data, please inform us by sending an email to firstname.lastname@example.org. You also have the right to lodge a complaint with a supervisory authority. You have the choice of submitting this complaint to the supervisory authority of the EU member state where you normally reside, where you have your place of work, or where the alleged infringement was committed.
Additional Matters Related to Singapore Residents
Scope of this Privacy Notice
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 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 us at the contact details provided 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 ten (10) business 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 (or your related User) 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 by contacting us in the manner outlined 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, in connection with the processing of transactions, or as required under applicable laws or for compliance purposes.
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 at the contact details provided 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 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 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 the PDPA).
You may contact us if you have any enquiries or feedback on our Personal Data protection policies and procedures, or if you wish to make any request, or would like to exercise your rights, please contact us at email@example.com.