1.1. “Personal Data” refers to any data or information about you from which you can be identified either (a) from that data; or (b) from that data and other information to which we have or are likely to have access. Examples of such Personal Data which you may provide us include (depending on the nature of your interaction with us):

  1. a) your name, date of birth, nationality, passport number or other identification number, telephone number(s), mailing address, email address, photograph (including any ‘selfies’) and any other information relating to you which you have provided us in any form you may have submitted to us, or in other forms of interaction with you;
  2. b) information about your use of our websites and services, including cookies, IP addresses, transaction details, subscription account details and membership details;
  3. c) proof of your address of residence (including as indicated in your utility or credit card bills); and
  4. d) your payment related information, such as your bank account or credit card information, and your credit history.
  5. Collection of Personal Data

2.1. Generally, we collect your Personal Data in the following ways:

  1. a) when you submit forms relating to any of our products or services, or submit any online queries;
  2. b) when you register for or use any of our services on websites owned or operated by us or when you register as a member of websites owned and/or operated by us;
  3. c) when you interact with our customer service officers or any of our staff, for example, via face-to-face meetings, telephone calls, letters, online forms (such as any “Contact Us” forms on our websites), social media platforms and emails;
  4. d) when you use or purchase our services or products;
  5. e) when you apply for and establish any online accounts with us;
  6. f) when you carry out transactions on our platform or our services;
  7. g) when you request that we contact you;
  8. h) when you respond to our request for additional Personal Data;
  9. i) when you ask to be included in an email or other mailing list;
  10. j) when you respond to our promotions and other initiatives;
  11. k) when you respond to our market surveys;
  12. l) when you submit a job application;
  13. m) when we receive references from business partners and third parties, for example, where you have been referred by them;
  14. n) when you submit your Personal Data to us for any other reason; and
  15. o) when you browse our website. Please refer to the Use of Cookies section below at paragraph 7 for more information.

2.2. We may monitor or record phone calls, your usage patterns and customer-facing interactions for quality assurance, employee training and performance evaluation, identity verification purposes, feedback, respond to your queries and requests and resolve complaints and other related purposes.

2.3. Where you provide Personal Data of a third party (e.g. information of your dependent, spouse, children and/or parents) to us, you represent and warrant that all necessary consents of that third party has been obtained for the collection, use and disclosure of the Personal Data for the purposes set out above and that you have provided a copy of this Privacy Notice to them.

  1. Use and Disclosure of Personal Data

3.1. Our business is to understand and meet your needs and provide you with the products and services that you require. To do this effectively, we need to collect a range of Personal Data about you.

3.2. In general, we use and disclose your Personal Data for the following purposes:

  1. a) as necessary for the performance of our contract with you to provide you with the products or services that you have requested;
  2. b) to help us review, develop, improve, manage the delivery of and enhance our products and services, including analysing future customer needs, conducting market research and data analytics;
  3. c) to communicate with you and respond to your queries, requests and complaints;
  4. d) to provide ongoing information about our products and services which may be of interest to you;
  5. e) to handle disputes and conduct and facilitate investigations and proceedings;
  6. f) to protect and enforce our contractual and legal rights and obligations;
  7. g) to prevent, detect and investigate crime, including fraud and money-laundering, and to analyse and manage other commercial risks (including via anti money-laundering (AML), counter-terrorism financing (CTF) and know-your-customer checks);
  8. h) to manage our business operations and to comply with internal policies and procedures;
  9. i) to facilitate business asset transactions (which may extend to any merger, acquisition or asset sale) involving any Almeedex Group entity; and/or
  10. j) to comply with any applicable rules, laws and regulations, codes of practice or guidelines or to assist in law enforcement and investigations by relevant authorities.

3.3. In addition, we may use and disclose your Personal Data for the following purposes, depending on the nature of our relationship with you:

  1. a) If you have an account with us:

(i) to process your application for the account;

(ii) to maintain your account with us;

(iii) to provide you with the goods and services which you have signed up for (including to facilitate and process crypto-related transactions and to seek your authorisation for such transactions);

(iv) to verify your personal particulars and process payment requests in relation to provision of the services which you may be entitled to or which you may have requested for;

(v) to communicate with you of changes and development to our policies, terms and conditions and other administrative information, including for the purposes of servicing you in relation to products and services offered to you;

(vi) to resolve complaints and handle requests and enquiries;

(vii) to carry out periodic screening on your transactions (including screening upon onboarding);

(viii) to carry out on-chain due diligence;

(ix) to conduct market research for statistical, profiling and statistical analysis for the improvement of services provided to you (including through the use of server log or device information); and/or

(x) to process your Personal Data in relation to any of the purposes stated above.

  1. b) If you are a vendor, a prospective vendor or a contractor:

(i) to evaluate your proposals and to conduct background checks on you;

(ii) to communicate with your deployed staff after award of contract who are providing products or services to us, and for any emergency or/and security concerns; and/or

(iii) any other purpose directly relating to any of the above.

  1. c) If you are an applicant for funding or initiatives provided by Almeedex Labs:

(i) to process your application including KYC, AML/CTF checks;

(ii) to provide or to obtain references for background screening/vetting;

(iii) to collect information about your suitability for the position applied for;

(iv) to assess your performance;

(v) to administer benefits and provide funding to you;

(vi) to communicate with you to coordinate the running of our initiatives, and to comply with our policies and processes, including for business continuity purposes; and/or

(vii) any other purposes relating to the aforesaid.

  1. d) If you submit an application to us as a candidate for employment:

(i) to process your application including pre-recruitment checks;

(ii) to provide or to obtain opinions or references for background screening/vetting from third parties; and/or

(iii) to collect information about your suitability for the position applied for, including past employment, professional qualifications and education, immigration and residential status and any other details about you which may be gathered during the recruitment process.

We may also review publicly available information about you on your social media accounts.

3.4. The above purposes are not exhaustive, and depending on the nature of your relationship with us, we may collect, use and disclose your Personal Data for additional purposes which you will be notified of, in accordance with applicable terms and conditions

3.5. The above purposes are not exhaustive, and depending on the nature of your relationship with us, we may collect, use and disclose your Personal Data for additional purposes which you will be notified of, in accordance with applicable terms and conditions.

3.6. In addition, where you have provided us with specific consents, we may also use and disclose your Personal Data for the following purposes:

  1. a) providing services and extending benefits to you, including promotions, reward programmes, and sending you industry market updates, newsletters and other information on our products, services, offers or promotions which may be of interest to you;
  2. b) matching Personal Data with other data collected for other purposes and from other sources (including third parties) in connection with the provision or offering of products and services, whether by us or third parties;
  3. c) administering contests, competitions and conducting lucky draws, including, where necessary, announcing the results of these contests, competitions and lucky draws and identifying and contacting the winners; and
  4. d) conducting market research to understand and determine customer locations, preferences and demographics for us to develop special offers, promotional and/or marketing programmes.

3.7. In relation to particular products or services or in your interactions with us, we may also notify or have specifically notified you of other purposes for which we collect, use or disclose your Personal Data. If so, we will collect, use and disclose your Personal Data for these additional purposes as well, unless we have specifically notified you otherwise.

3.8. If you have provided your contact details (for example. telephone number, mobile number, postal address or email address) and have indicated that you consent to receiving marketing or promotional information, then from time to time, we may contact you using such contact details (including via voice calls, text, fax, email or other means) with information about our products and services (including discounts and special offers). You have the right to withdraw your consent for us to use this information for this purpose. If you wish to do so, please contact us at the details provided in paragraph 10.

3.9. Your Personal Data will be protected and kept confidential, but subject to the provisions of any applicable law, your Personal Data may, depending on the products or services concerned, be disclosed to the following third parties:

  1. a) transaction counterparties;
  2. b) other divisions or entities within the Almeedex Group;
  3. c) our joint venture/ alliance partners and business partners;
  4. d) our agents, contractors, vendors, third party service providers and specialist advisers who have been contracted to provide us with administrative, financial, research, operational, IT or other services, such as telecommunications, information technology, payment, processing, training, market research, storage and archival;
  5. e) any third party business partners who offer goods and services or sponsor contests or other promotional programmes, whether in conjunction with us or not;
  6. f) insurers or insurance investigators and credit providers;
  7. g) in the event of default or disputes, any debt collection agencies or dispute resolution centres;
  8. h) any business partner, investor, assignee or transferee (actual or prospective) to facilitate business asset transactions (which may extend to any merger, acquisition or asset sale) involving the Almeedex group;
  9. i) our professional advisors such as our auditors and lawyers;
  10. j) relevant government regulators or authority or law enforcement agency to comply with any laws or rules and regulations imposed by any governmental authority;
  11. k) anyone to whom we transfer or may transfer our rights and obligations;
  12. l) banks, credit card companies and their respective service providers; and
  13. m) any other party as may be consented to by you, as specified by that individual or in the applicable contract.
  14. Keeping Your Personal Data Accurate and Up-To-Date

4.1. We endeavour to ensure that all Personal Data we have about you is accurate and up-to-date. We understand that this information changes frequently with changes of address and other personal circumstances. We encourage you to contact us as soon as possible to enable us to update any Personal Data we have about you in accordance with paragraph 10. Incomplete or outdated Personal Data may result in our inability to provide you with products and services you have requested.

  1. Transfer of Data

5.1. The personal data that we collect from you may be processed or shared with Almeedex Group Companies, or third party affiliate in a country or territory outside your home country, including outside the European Economic Area ("EEA").

5.2. Where we transfer your data to another jurisdiction which does not offer the same level of protection of personal data as may be enjoyed by your home jurisdiction, we will ensure that your data is appropriately protected.