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1. GENERAL INFORMATION

  • 1.1 We value your privacy and want to be transparent with you in the way that we collect and use your personal data. This privacy policy ("Privacy Policy") explains how we collect, store, use, process and disclose your personal data and other information acquired in connection with our apps, platforms (including the Arcadier platform), services, events (including the Token Sale) and Websites (collectively, the "Services").
  • 1.2 This Privacy Policy will apply to all the Services offered by us, but excludes services that may have separate privacy policies and that do not incorporate this Privacy Policy.
  • 1.3 We are always looking to improve the information we provide to our customers and contacts so if you have any feedback on this Privacy Policy, please let us know by contacting our Data Protection Officer whose details are set out at Section 16 below.

2. DEFINITIONS

In this Privacy Policy, unless the context otherwise requires, the following definitions shall apply:

"Data Protection Legislation" means the Personal Data Protection Act 2012 (No. 26 of 2012) of Singapore and any other applicable data protection laws in the relevant jurisdictions.

"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 an organisation has or is likely to have access. Personal data includes but is not limited to an individual's name, address, email address, phone number, gender, birth date, online identifier (such as username), device unique identity, operating system or version, hardware information, date and time spent on the Services and financial information (such as credit card numbers, bank account information and digital / crypto wallet address).

"Section" means a section in this Privacy Policy.

"Services" shall have the meaning given to it in Section 1.1

"Token" means the ERC-20 token based on the Ethereum blockchain known as the "Arcadier Token", with the symbol "ARCX", which is intended for sale during the Token Sale.

"Token Sale" means the sale of the Tokens by us, which is divided into the Pre-Sale and the Public Sale.

"user", "you" and "your" means the end-user of our Services.

"we", "us" and "our" means ArcadierX Pte. Ltd. (Singapore Company Registration No. 201834549N), a company incorporated in Singapore with its registered address at 34 Boon Leat Terrace #04-17 Singapore 119866, and its affiliates.

"Websites" means our main website at www.arcadierx.io and other websites which may be offered by us from time to time.

3. CONSENT

  • 3.1By using or subscribing for any of the Services, or submitting any information to us, you agree and consent to us collecting, using, disclosing or otherwise processing your personal data in accordance with this Privacy Policy. If you do not agree to this Privacy Policy in general or any part of it, please do not subscribe for, or use, any of the Services or participate in the Token Sale.
  • 3.2Without prejudice to Section 3.1, you are deemed to have given your consent for the collection, use, disclosure and processing of your personal data in the following circumstances:
    • (a) when you voluntarily provide your personal data to us, you are aware of the purpose for which you provide your personal data to us, and it is reasonable for you to have provided your personal data to us in the circumstances; and
    • (b) in any other circumstances where consent is deemed under the Data Protection Legislation.

4. THE INFORMATION YOU PROVIDE

  • 4.1You represent and warrant that the personal data and the information which you provide or otherwise disclose to us is accurate and complete.
  • 4.24.2 If you provide us with any personal data or information relating to a third party, you represent and warrant that (i) such personal data or information is accurate and complete; (ii) you have obtained the consent of the said third party to the collection, use, processing and disclosure of their personal data or information on the terms set forth in this Privacy Policy, and are duly authorised by the third party to do so.

5. PURPOSES OF COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA

  • 5.1The purposes for the collection, use, processing or disclosure of personal data (as the case may) may vary depending on the nature of the Services which you use or subscribe to. In general, we may collect, use, process or disclose personal data for one or more of the following purposes:
    • (a)to provide you with the relevant Services and to develop, improve and maintain such Services;
    • (b)to verify your identity;
    • (c)to restrict attempts to use the Services from a restricted territory and attempts to use the Services in breach of the applicable terms of service;
    • (d)to manage your subscription for the relevant Services, including the creation and management of your accounts;
    • (e)to facilitate certain events that we hold and organise, including the Token Sale;
    • (f)to manage, develop and improve the Services, including to respond and deal with enquiries or complaints, providing maintenance and support and preparing for data backup;
    • (g)to conduct investigations, internal audits or take action, including in relation to any violation of terms and conditions for the Services;
    • (h)to provide to third parties who provide Services on our behalf, but only to the extent necessary for the Services to be provided;
    • (i)to meet legal and regulatory requirements imposed by the applicable public authorities, laws or regulations; and
    • (j)for any other purposes which are necessary, ancillary or consequential to the above, or which are permitted under the Data Protection Legislation.
  • 5.2The purposes listed above 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).
  • 5.3 Personal data which we collect, use, disclose or otherwise process include but are not limited to the following:
    • (a)to improve and maintain any of the Websites or Services, we may gather anonymous analytics and statistical information from you, which include but are not limited to the number of daily users, operating system version, device make and model and coarse location;
    • (b)to facilitate the Token Sale and the transfer of the Tokens, we may collect your personal particulars such as your email address and digital / crypto wallet address;
    • (c)for system administration and to improve the Websites and our apps, we may require information such as IP address, operating system and browser type;
    • (d)to understand your browsing actions and patterns, we may collect statistical data about our users’ browsing actions and patterns without identifying any individual;
    • (e)we may also ask you for information when you report a problem with any Website or our apps;
    • (f)we may send you marketing and/or promotional materials on our latest Services or those of carefully selected third parties, so long as you consent to it;
    • (g)if you contact us, we may keep a record of that correspondence; and
    • (h)if you complete any survey, we may store and use that data for research purposes, which may include details of visits to our website such as traffic data and location.
  • 5.4 Except as otherwise provided for in this Privacy Policy or such other agreement entered between you and us, we will not share your personal data with other parties without your consent, unless required by law.

6. LIMITATIONS TO COLLECTION, USE OR DISCLOSURE OF PERSONAL DATA

  • 6.1 We shall only collect, use, disclose or process your personal data to the extent necessary for the purposes described under this Privacy Policy and to the extent allowed under the Data Protection Legislation.
  • 6.2 Subject to Sections 7 and 12, you may withdraw your consent at any time after giving reasonable notice by submitting your request to our Data Protection Officer at the email address set out at Section 16. Following the withdrawal of your consent, we shall no longer collect, use or disclose your personal data unless consent is again obtained or as authorised under the Data Protection Legislation. The withdrawal of your consent may however result in certain consequences. For example, in certain cases, we may not be able to provide you with certain Services.

7. RETENTION OF PERSONAL DATA

  • 7.1 We shall collect and retain personal data in accordance with this Privacy Policy for as long as it is necessary, required, or relevant for business or legal purposes.
  • 7.2 The length of time for which we retain personal data depends on the purposes for which we collect and use it and/or as required to comply with applicable laws and to establish, exercise or defend our legal rights. For example, after your account ceases to be active, we will retain your personal data for a reasonable period to ensure that we are in the position to respond to any queries or any issues that may arise thereafter.
  • 7.3 Without prejudice to any other provision in this Privacy Policy, we retain the right to collect and store identifying information for the purpose of providing and improving the quality, features and user experience of our Services. All identifying information will be stored and handled with proper security measures as required under the Data Protection Legislation.

8. TRANSFER OF PERSONAL DATA OUTSIDE SINGAPORE

  • 8.1 We shall only transfer personal data outside Singapore in accordance with the Data Protection Legislation.
  • 8.2 We may, to the fullest extent permitted under the Data Protection Legislation, transfer personal data to any government and law enforcement entity or officials in response to any lawful request, directive or order or pursuant to a discretion exercised by us in order to protect our rights, to protect the safety of public or any person or to prevent or stop any activity that may be considered to be illegal, unethical or criminal.
  • 8.3 Due to the nature of the Services provided by us, you agree, acknowledge and consent that your personal data (and such other personal data which you provide to us) may be stored or processed in any country where we have operations or where we engage service providers. We may transfer personal data outside Singapore to countries which may have data protection rules that are different from those of Singapore. However, we shall take measures to ensure that any such transfers comply with the Data Protection Legislation, and such personal data remains protected to the standards described in this Privacy Policy. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access the personal data.

9. WE AS DATA INTERMEDIARY

  • 9.1 We may collect, use, disclose or otherwise process personal data when acting as a data intermediary (as defined under the Data Protection Legislation).
  • 9.2 You are responsible for making sure that the requirements under the Data Protection Legislation are complied with, including ensuring appropriate disclosures about third party data collection and use. To the extent that we act as a user's data intermediary, we will process personal data in accordance with the terms of our agreement with such user and such user' lawful instructions.

10. PROTECTING YOUR INFORMATION

  • 10.1 We shall take reasonable steps to secure and protect your personal data and information by implementing measures to secure and protect your personal data as required to comply with the Personal Data Legislation, including:
    • (a) making reasonable security arrangements to prevent unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks to personal data; and
    • (b) implementing security precautions safeguarding all electronic storage and transmission of personal data.
  • 10.2 Notwithstanding Section 10.1, while we strive to use commercially acceptable means to protect your personal data, we cannot guarantee or warrant the security of any personal data or information which you transmit to us via the internet or otherwise. You acknowledge that the use of the internet have certain inherent risks. To the fullest extent permitted by the law, we shall not be liable in any manner for any losses arising from any unauthorised collection, use, disclosure or otherwise processing of such personal data or information whatsoever. We shall not be held responsible for the acts, omissions, data policies or use of cookies by any third party, or the content or security of any third party websites (even if linked to our website). Any such liability is expressly disclaimed and excluded to the fullest extent permitted under the law.

11. THIRD PARTY SITES

  • 11.1 Our Services may, from time to time, contain links to external sites or resources which are operated by third parties. We have no control over the content and privacy practices of such sites or resources. You should review the privacy policies of these sites and resources operated by third parties and understand how your information may be used by those third parties.
  • 11.2 Third party websites have their own terms and conditions and privacy policies, and you should read these carefully before you submit any personal data to these websites. We do not endorse or otherwise accept any responsibility or liability for the content of such third party websites or third party terms and conditions or policies.

12. ACCESSING AND UPDATING YOUR PERSONAL DATA

  • 12.1 If you wish to (i) apply for a copy of your personal data that we hold; (ii) update and/or correct your personal data that we hold, or (iii) withdraw consent that you previously provided in relation to the use, collection and disclosure of your personal data, please contact our Data Protection Officer at the email address set out in Section 16 below.
  • 12.2 Please give us a reasonable period of time to respond to any request and effect any change. We may ask to verify your identity and for more information about your request. Where we are legally permitted to do so, we may also refuse your request with or without providing you with any reasons for doing so. Where you have requested for a copy of your personal data that we hold, we may charge a reasonable administrative fee to cover the costs of responding to your request. If we decide to do so, we will provide you with a written estimate of such fee beforehand.
  • 12.3 In compliance with any laws or regulations or compliance authority requirements, we may require you to provide additional information, including regarding your computer and other access devices for fraud prevention, anti-money laundering or know your client policies. We may compare your information with third party databases in order to verify its accuracy and confirm your identity.

13. CHANGES TO THIS PRIVACY POLICY

  • 13.1 We may amend this Privacy Policy at any time with or without notice to you.
  • 13.2 Any amendment to the Privacy Policy shall become effective and binding on you as of the moment the amended Privacy Policy is posted on the relevant Websites. You may determine if any such amendment has taken place by referring to the date on which this Privacy Policy was last updated, as set out at the start of the Privacy Policy. Please check back frequently to see any updates or changes to this Privacy Policy
  • 13.3 To the fullest extent permitted by the law, by continuing to access or use the Services after the amended Privacy Policy is posted on the relevant Websites, you agree to be bound by the amended Privacy Policy.

14. BUSINESS TRANSFERS

  • We may sell, transfer or otherwise enter into schemes to share some or all of our assets, which may include your personal data, in connection with any merger, acquisition, reorganisation or sale of our assets whether in pursuant to a business transaction or in the event of bankruptcy or insolvency. Your consent to this Privacy Policy represents also your consent to that sale, transfer or scheme.

15. JURISDICTION AND GOVERNING LAW

  • This Privacy Policy including all matters, dispute or claims arising out of or in relation to it shall be governed by the laws of Singapore.

16. QUESTIONS OR CONCERNS

If you have any questions or concerns relating to your personal data and/or this Privacy Policy, please send us a message with sufficient detail to our Data Protection Officer at info@arcadierx.io . We will make every effort to resolve your concerns.

Last updated 23 November 2018