Issued on November 17, 2018
5. By using qPocket, providing personal information and/or using any of our Services, you acknowledge that:
a. we are not responsible for your own disclosure of your information to third parties through qPocket or our Services;
b. you, and you alone, are responsible for the content of any profile or registration you create or any information you provide and its accuracy;
d. if you have provided information to us relating to any other person, you:
i. have a right to provide that information;
iii. each such person has agreed to those terms.
II. PERSONAL INFORMATION
7. The type of information we may collect from you includes:
a. personal information ("Personal Information"), including without limitation:
i. personally identifiable information, such as your name and date of birth;
ii. contact information, such as your email address, telephone number and postal address;
iii. social media handles and other social media profile information that you make available to us or to the public;
iv. third-party account credentials (such as your Facebook login credentials, Google login credentials);
v. a user’s IP address when the user accesses or uses qPocket or our Services; and
vi. demographic information such as information regarding your gender, nationality and occupation ("Demographic Information").
b. other information ("Other Information") including without limitation:
i. financial information, such as credit card, bank account or other payment details;
ii. usernames and passwords that you create when registering for an account with us;
iii. details of any Services that we provide to you;
iv. your operation record, transaction record and wallet address; and
v. records of our communications with you, including any messages you send us.
Paragraphs (a) and (b) directly above are "Information".
III. COLLECTION OF INFORMATION
9. We collect information about you in the following ways:
a. Information you provide to us directly, including without limitation to:
i. when you register for an account on our website, when you update your account details, when you open an email from us, or request or use our Services;
ii. when you submit a query or request to us;
iii. device information - when you access qPocket or our Services via your mobile device or computer, we collect data about you including unique identification numbers associated with mobile devices or through its API, mobile carrier, device type, model and manufacturer, mobile device operating system brand and model, battery life, and, depending on the user’s mobile device settings, the geographical location data, including GPS coordinates (e.g. latitude and/or longitude) or similar information regarding the location of the mobile device ("User Data") that enables us to provide you with information, advertisements, or offers specific to your location and interests.
b. Information collected automatically - whenever you access or use qPocket or interact with our Services, we automatically receive and record Information on our server logs from your browser or device, which may include your IP address, device identification, "cookie" information, browser and/or device type, and the page or feature you requested.
c. from third parties who are entitled to disclose that information - you may have the option of registering an account and logging into or otherwise linking to that account using a third-party account such as Facebook, Google or other account provided by a third-party site or application. If you choose to provide or log into your account using your credentials for a third-party platform, we may have access to certain information from that site, such as your name, contacts or friend’s lists, account information, public profile, and email address.
d. all or part of your transaction records copied by us on the blockchain. However, you should refer to the blockchain system for your latest transaction records.
10. To the extent permitted by applicable laws and regulations, the Company may collect and use the Personal Information in the following circumstances without your prior consent or authorization:
i. information related to national security and national defense;
ii. information related to public security, public health, significant public interests;
iii. information related to criminal investigation, prosecution, trial and enforcement;
iv. Personal Information in the public domain;
v. Personal Information collected from legally publicly disclosed information, such as legal news reports, government information disclosure and other channels;
vi. Personal Information necessary to maintain the security and compliance of services, such as to detect or to solve the malfunction of products and services; and/or
vii. other circumstances permitted by laws and regulations.
11. In some cases we may be required by law to collect certain types of personal information about you.
12. Where we collect personal information from you, we will generally do so ourselves. However, in some cases we may collect Personal Information from a third party, such as through your representatives, contractors who provide services to us, or third parties who refer you to us because they think you may be interested in our Services.
13. You can always opt not to disclose Information to us. However, without the Information, we may not be able to provide you with our Services (or with some of the features and functionality offered by our Services) or to respond to queries or request that you submit to us.
14. You acknowledge that your Wallet Password, Private Key, Mnemonic Words, Keystore on qPocket are not stored or synchronized on Company’ servers. Company does not offer the service to recover your Wallet Password, Private Key, Mnemonic Words or Keystore.
IV. USE OF INFORMATION
15. We use the Information we collect about you for the following purposes:
a. to verify your identity when you are dealing with us;
b. to determine your eligibility for any of our Services;
c. to answer your queries and requests;
e. to email you about your use of the Services;
f. to enable us to provide our Services and personalize your experience by better responding to your individual needs;
g. to improve qPocket based on your information and feedback;
h. to process transactions;
i. to send periodic emails for keeping you informed of our activities;
j. to comply with our legal and regulatory obligations and manage related risks;
k. to manage and resolve any legal or commercial complaints or issues;
l. to conduct our internal audit, data analysis and research;
m. to carry out market analysis and research;
n. to carry out planning and forecasting activities and other internal business processes; and/or
o. any other reasonable purposes related to the aforesaid.
V. DIRECT MARKETING
16. There may be instances where we will use your Information to send you marketing materials, for example, we may send promotional email offers to you about our Services that we think you may be interested (including in some cases products and services that are provided by a third party). We may not use your Personal Information unless we have received your consent. You can opt-out of receiving marketing communications from us by contacting us at email@example.com.
17. We may use your following Personal Information for the purpose of direct marketing:
a. identifying information, such as your name;
b. contact information, such as your e-mail address, mailing address or phone number; and/or
c. products and services portfolio information and demographic data held by us from time to time.
18. If we use your Personal Information in any direct marketing communications, you have the right to request that we provide you with the source of that Personal Information. There is no fee for requesting this information. We will provide you with the source of the Personal Information, unless it is impracticable or unreasonable to do so.
19. Please indicate your consent to receiving information relating to the above by contacting us at firstname.lastname@example.org or by providing your contact details through our website.
20. We may also use and disclose your Information for other purposes in accordance with your requests or instructions.
VII. INFORMATION PROTECTION
22. Protecting your privacy is important to us, which is why we endeavour to protect the security of your privacy and personal information using commercially reasonable security measures to protect the confidentiality and security of the Information that we hold, and we update these from time to time to address new and emerging security threats that we become aware of.
23. We will provide a standard of protection for the Personal Information collected and stored by us that is at least comparable to the protection under the PDPA.
24. We also take steps to monitor access to and modification of your Information by our staff members, and ensure that they are aware of and are properly trained in their obligations for managing your data privacy.
25. No website or Internet transmission is completely secure. Therefore, we cannot guarantee that your Information will never be hacked or that your Information is free from unauthorised access, data loss, or other breaches. In other words, your use of qPocket and our Services is at your own risk. We encourage you to exercise caution when using qPocket and our Services by keeping your password safe and not sharing it with other individuals.
26. You acknowledge that since blockchain is an open source system, your transaction records are automatically public and transparent in the whole blockchain.
VIII. INFORMATION STORAGE
27. We generally store the Information that we collect in electronic databases, some of which may be held on our behalf by third party data storage providers. Sometimes we also keep hard copy records of your Information in physical storage facilities.
28. Your Personal Information will not be kept longer than required. We may be required (by law or otherwise) to retain your account information or any other information associated with it and not delete it (or to keep this information for a certain period of time, in which case we are only be able to comply with your deletion request only after we have fulfilled such requirements). Some information may remain in our records after your deletion of such information from your account. We may use any aggregated data derived from or incorporating your Information after you update or delete it, but not in a manner that would identify you personally.
IX. SHARING INMFORMATION
29. We do not sell or trade your Personal Information to any third parties. We may share your Information with third parties as described in this section:
a. your representatives, advisers and others you have authorised to interact with us on your behalf;
b. our staff members who need the information to discharge their duties;
c. our affiliated entities within the same corporate group - in certain situations, businesses or third party websites we are affiliated with may sell or provide products or services to you through or in connection with the Services (either alone or jointly with us). You can recognise when an affiliated entity is associated with such a transaction or service, and we will share your Information with that affiliated entity only to the extent that it is related to such Services or their related transaction.
Please remember that the manner in which third party services use, store and disclose your information is governed solely by the policies of such third party service providers. We have no control over the policies and practices of third party websites or businesses as to privacy or anything else, so if you choose to take part in any transaction or service relating to a website of an affiliated entity or business, please review all such business’ or websites’ policies.
d. Our agents and service providers that assist us in operating our website, providing Services to you, or otherwise conducting our business, for example, we may:
i. employ other companies and people to perform certain tasks or services on our behalf, such as hosting services, and may share your Information with them to provide Services to you;
ii. employ companies to call or email you to in order to provide better services to you, such as to welcome you when you sign up with us, to notify you of your transaction information, to remind you of your account inactivity, to provide codes for you to refer your friends to our Services, or to notify you of an offer that you may be interested in. By providing the relevant communication means to us, you agree that we may, to the extent permitted by applicable laws and regulations, contact you for the above mentioned purposes.
Unless we tell you differently, our agents do not have any right to use the Information we share with them beyond what is necessary to assist us.
e. prospective purchasers or successors of all or part of our business or shares in our company or a related entity - We may choose to buy or sell assets, and may share and/or transfer user information, including the Information, in connection with the evaluation of and entry into such transactions. Also, if we (or our assets) are acquired, or if we go out of business, enter bankruptcy, or go through some other change of control, Information could be one of the assets transferred to or acquired by a third party. We may also share your Information, including usage information with our parent, subsidiaries and affiliates;
f. government authorities who ask us to disclose that information in order to:
i. comply with laws and regulations, court orders, or government requests;
iii. assist in any investigations or legal proceedings (including to respond to claims of alleged violations of any third party rights); and/or
iv. protect the rights, property, or safety of our employees, our users, or others; and
g. professional advisers who we engage to provide advice on our business.
30. We may share your User Data with our third party partners.
31. In some situations, transferees to whom we disclose your Information may be located overseas. Further, we may have servers located overseas. The jurisdictions in which these people and/or servers are likely to be located include China and other counties. We will ensure that:
a. we comply with the data protection provisions set out in the PDPA in respect of the transferred personal data, if the personal data remains in our possession or under our control; and
b. the recipient in a country or territory outside Singapore is bound by legally enforceable obligations to provide a standard of protection that is comparable to that under the PDPA.
32. The following acts of collection, use and disclosure of Personal Information are specifically exempted from the requirements of the PDPA:
a. that are clearly in the interest of the individual and consent cannot be obtained in a timely way;
b. in response to an emergency, or necessary for the national interest;
c. for an investigation or legal proceedings; and
d. for the provision of legal services.
XI. DE-IDENTIFYING YOUR INFORMATION
33. We may de-identify your Information (so that you are not identified) and provide that Information to our business partners and/or affiliated entities. We may also provide aggregate usage information to our business partners and/or affiliated entities (or allow them to collect that Information from you), who may use such Information to understand how often and in what ways people use our Services, so that they, too, can provide you with an optimal online experience.
34. However, we never disclose aggregate usage or de-identified information to a business partner and/affiliated entities (or allow them to collect such information) in a manner that would personally identify you.
XII. ACCESSING AND MODIFYING YOUR INFORMATION
35. If any Information you provided to us has changed, you should inform us. You are responsible for maintaining the accuracy of the Information you submit to us, such as your contact information.
36. You may be able to add, update, or delete Information.
37. In any event, you may request deletion of your account by contacting us by email at email@example.com.
38. To protect the integrity and security of the Information we hold, we may ask that you follow a defined access procedure, which may include steps to verify your identity. In certain cases we may charge you an administration fee for providing you with access to the Information you have asked for, but we will inform you of this before proceeding. There may be cases where we are unable to provide the information you request, such as where it would interfere with the privacy of others or result in a breach of confidentiality. In these cases we will let you know why we cannot comply with your request.
39. Even if you do not request access to and/or correct your personal information held by us, if we are satisfied, having regard to the reasons for which we hold your personal information, that personal information is inaccurate, incomplete, out-of-date, irrelevant or misleading, we may take reasonable steps to correct that information.
40. You are entitled to restrict us from or refuse us to process your Information.
XIII. THIRD PARTY LINKS AND TRACKING
42. Please be aware that third parties may continue to track your online activities even after you have left our Services, and those third parties may not honour "Do Not Track" requests you have set using your browser or device.
XIV. CHILDREN USERS
43. qPocket and our Services are intended to be used by adults, as defined under any applicable law in each specific case. If you are under 18 years old, you are not authorised to use qPocket or our Services. We do not knowingly collect or solicit personal information from anyone under the age of 18. If you are under 18, please do not attempt to use qPocket or our Services or send any Information about yourself to us. If we discover that we have collected Information from a child under age 18, we will delete that Information as quickly as possible. If you believe that a child under 18 may have provided us Information, please contact us at firstname.lastname@example.org.
XV. CHANGE OF POLICY
XVI. RAISE CONCERN
47. We try to meet the highest standards in order to protect your data privacy. However, if you are concerned about the way in which we are managing your Information and think we may have breached any applicable privacy laws, or any other relevant obligation, please contact our privacy compliance team using the contact details set out below. We will make a record of your complaint and refer it to our internal complaint resolution department for further investigation. We will deal with the matter as soon as we can, and keep you informed of the progress of our investigation.
48. If we have not responded to you within a reasonable time or if you feel that your complaint has not been resolved to your satisfaction, you are entitled to make a complaint to the Personal Data Protection Commission of Singapore.
52. This Policy shall become effective upon its issuance.
QUARKONIUM PTE. LTD.