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KRYPTOS-X – PRIVACY POLICY

Last updated: 30 Oct 2018

Welcome to Kryptos-X!

Kryptos-X Pte Ltd, a Singapore-registered company with its registered address at 10 Collyer Quay, #16-01 Ocean Financial Centre, 049315 (“ we”, "our" or "us"), values your privacy.

Your use of the Platform and our Services may involve you disclosing certain Personal Data to us, and our use and storage of that Personal Data. This Privacy Policy sets out how this will occur and how we will collect, use, store and protect your Personal Data. It is incorporated into, and forms part of, our Terms of Use.

By using the Platform and our Services, you agree to our processing of your Personal Data in accordance with this Privacy Policy. If you do not agree with this Privacy Policy, please do not use the Platform and our Services.

If you have any questions or complaints regarding this Privacy Policy or the use of your Personal Data, please contact our Data Protection Officer via support@kryptos-x.me

1. Definitions

1.1. Defined terms in this Policy have the meaning given to them in our Terms of Use. In addition, these terms as used in this Policy will have the following meanings:

Personal Data” means data or a combination of data, whether true or not, about you or that relates to you and that is sufficient to enable us to identify you, either when considered in isolation or together with other information that we have or are likely to have access to – including:

  1. the data set out in clause 4.1;
  2. information that you have provided to or made available to us, including while accessing or using the Platform or our Services;
  3. information which we have collected as a result of you using the Platform or our Services; and
  4. information about you that others using the Platform or our Services have made available to us.

Personal Data Protection Act” means the Singapore Personal Data Protection Act 2012.

2. SCOPE OF THIS PRIVACY POLICY

2.1 This Privacy Policy applies to the Platform and our Services. This Privacy Policy does not apply to any non-Personal Data, or any Personal Data that you choose to disclose or submit to or via:

  1. services other than the Platform or our Services (e.g. other products or services supplied or operated by us or our affiliates), that do not expressly state that this Privacy Policy applies;

  2. any third party services (including any third party websites) that you may access through the Platform or our Services; or

  3. companies or organisations that advertise products or services through the Platform or our Services.

2.2 Your use of any third party services, including any Personal Data you provide to such third parties and their collection and use of your Personal Data, are subject to the relevant third party’s own terms of services and privacy policies and not this Policy or our Terms of Use.

2.3 We may from time to time send you service-related announcements when we consider it necessary to do so (e.g. maintenance, security, privacy, or administrative-related communications). We send these to your email address or via SMS. You may not opt-out of these service-related announcements, which are not promotional in nature and used solely to protect your account and keep you informed of important changes to the Platform and our Services.

3. CHANGES TO THIS PRIVACY POLICY

3.1 We may from time to time revise or add specific instructions, policies and terms to this Privacy Policy. These instructions, policies and terms form part of this Privacy Policy.

3.2 Whenever we make any changes to this Privacy Policy that are reasonably material, we will make such changes in accordance with clause 3 of our Terms of Use.

4. Collection of Personal Data

4.1 In order to provide you with our Services, we may collect, use, disclose or store the following data about you:

  1. information that you provide by filling in forms on the Platform or through another remote channel connected to the Platform, or that you otherwise send to us. This includes information provided when registering to use the Platform, subscribing to our Services, posting material on the Platform, and reporting a problem you have with the Platform;

  2. if you contact us, records of such correspondence;

  3. details of transactions you carry out on the Platform and our Services – including your account balance, trading activity and account history, details of your external bank and your financial arrangements;

  4. details of your visits to the Platform and the resources that you access;

  5. documents uploaded on to the Platform by you or others and metadata associated with such documents;

  6. details of other accounts that you may link to our Platform; and

  7. other information that you may disclose to us, including your use of our Services.

5. Use of Personal Data

5.1 By accessing the Platform or using our Services, you grant us permission to collect, use, disclose, copy, transmit, store and back-up your Personal Data for the purposes of providing you with our Services or access to and use of the Platform, or for any other purpose(s) as contemplated by this Policy and our Terms of Use.

5.2 The purposes for which Personal Data may be used by us include:

  1. assessing whether you should be allowed to access and use the Platform or any of our Services, e.g. ensuring that you comply with our AML/KYC Policy;

  2. providing you with alerts, newsletters, education materials, or information that you have requested or signed up to;

  3. carrying out our obligations under any contracts you have entered into with us (including the Terms of Use);

  4. investigating any suspicious activities;

  5. complying with Applicable Laws in Singapore or in any other jurisdiction;

  6. evaluating and improving upon our Services;

  7. promoting and marketing our Services and any other products or services we may offer (subject to clause 9.1(d) below); and

  8. purposes directly related to or incidental to any of the above.

5.3 We will keep your Personal Data that is within our possession and control confidential and take reasonable steps to prevent unauthorized disclosures of your Personal Data. However, we may disclose your Personal Data:

  1. to our Affiliates;

  2. to our personnel, employees, agents, advisers, auditors, lawyers, contractors, financial institutions, and service providers to the extent necessary for the provision and maintenance of the Platform or our Services or in connection with any of our operations;

  3. pursuant to Applicable Laws

  4. to Governing Bodies; or

  5. in the event of an internal restructuring of our or our Affiliate's businesses, or the sale of the Platform or our Services or any of its assets to a third party, the entity that consequently operates the Platform or our Services may be a different entity to us and we will transfer your information accordingly so that your service can continue.

5.4 We may aggregate your Personal Data together with similar data from other users. This aggregate data will be produced in a manner that means it is no longer identifiable to any specific user, including yourself. We may share such aggregated data with third parties to help us improve or enhance our products and services and for marketing, research, or academic purposes.

6. Cookies

6.1 A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer and of your other devices. Cookies contain information that is transferred to your computer's hard drive.

6.2 The Platform uses cookies to distinguish you from other users of the Platform. This helps us to enhance your user experience when you access and use the Platform. Information we gather from the cookies also helps us find ways to improve the Platform.

6.3 Please note that third parties (e.g. advertising networks, web traffic analysis services) may also use cookies. We have no control over these third parties’ use of cookies and are not liable for any impact these third parties’ cookies may have on you.

6.4 You can block or restrict cookies by activating the relevant settings on your device or internet browser. Please note that such blocking or restrictions of our cookies may impact our provision of the Platform or our Services to you, including not being able to provide them at all.

7. security of your personal data

7.1 We use a variety of security technologies and procedures for the purpose of preventing loss, misuse, unauthorised access, or disclosure of Information – for example, we use encryption technology (such as SSL) to protect certain sensitive information provided by you to us.

7.2 Please be aware that despite our efforts, no data security measures can guarantee 100% security at all times. We do not warrant or guarantee the security of, or any information you provide to us through, the Platform or our Services.

7.3 We may allow you to share certain Personal Data publicly on the Platform or via our Services. Such shared Personal Data will remain publicly-available for so long as you or a user that has shared such information retains it. Even after you delete such shared information, it may still be separately cached, copied, or stored by, or remain public through, other users or third parties who are not affiliated with and not controlled by us. Please consider carefully what you post and communicate via the Platform and Our Services.

8. Retention and transfer of your Personal Data

8.1 We will retain your Personal Data until the purpose for which that Personal Data was collected is no longer being served by the retention of the Personal Data, and the Personal Data does not need to be retained any longer for any purpose (including pursuant to Applicable Laws – e.g. in relation to AML/KYC checks, we will retain your Personal Data for at least five years after you terminate your account with us).

8.2 Subject to Applicable Laws– should you or we terminate your account for any reason, we will take steps to ensure that your Personal Information is no longer available through the Platform or our Services, or otherwise used by us, within a reasonable period of time (subject to technical limitations) after such account termination.

8.3 We may retain, transfer or process your Personal Data outside Singapore. We will comply with Applicable Laws in relation to such retention, transfer, or processing for as long as the data remains within our possession or control. We will take reasonable measures to ensure that the recipient(s) of your Personal Data located outside Singapore will treat your Personal Data with a level of protection that is comparable to that required by the Personal Data Protection Act. You may at any time inform us that you wish to withdraw your consent to such disclosure, transfer, storage, or processing of your Personal Data. However, this may affect or remove our ability to provide you with certain or all of the Platform or our Services.

9. Your consent and rights

9.1 Under the Personal Data Protection Act, you have the right to (amongst other things):

  1. access your Personal Data held by us;

  2. require us to correct any data relating to you that is inaccurate as soon as reasonably practicable;

  3. ascertain our policies and practices in relation to Personal Data and the kind of Personal Data held by us; and

  4. object to the use of your Personal Data for marketing purposes and require that we do not use your Personal Data for marketing purposes after you communicate your objection to us.

9.2 However, please note that Singapore law allows us to refuse such requests under certain circumstances, such as where:

  1. the burden or expense of providing access to the relevant data would be unreasonable to us or disproportionate to your interests; or

  2. disclosing such Personal Data would reveal confidential commercial information that could reasonably be expected to harm our competitive position.

9.3 Please send any such objections, and any requests for:

  1. access to or correction of Personal Data;

  2. information regarding this Policy;

  3. the Personal Data we hold; and

  4. any questions or complaints,

to our Data Protection Officer via email at support@kryptos-x.me. We reserve the right to charge a reasonable fee for processing any such data access objections or request(s).

10. AGE RESTRICTIONS

10.1 We do not knowingly collect Personal Information from anyone under the age of 18 years old (and do not permit anyone under such age to use the Platform and our Services). Please contact our Data Protection Officer if you believe we have any Personal Information from any such person – we will promptly investigate (and remove) such Personal Information.