PRIVACY AND COOKIES NOTICE

Last updated: 5 November 2019

1. ABOUT THIS PRIVACY AND COOKIES NOTICE
   • The website www.tokenclan.io (the Site) is operated by Flag One Pte Ltd (“we”, “us”, “our”), a company incorporated in Singapore under company number 200721476H. Our registered office is at 81 Ayer Rajah Crescent, #02-45, Singapore, 139967.
   • We are committed to protecting your privacy and complying with our data protection obligations under the Singapore Personal Data Protection Act 2012 (PDPA).
   • When you interact with us or use the Site, we act as the data controller of your personal data. This means that we are responsible for processing your personal data and deciding how to use it. This privacy and cookies notice explains the types of personal data we may collect about you when you interact with us, why we collect it, what we use it for and what rights you have over that data. Personal data is any information about an identifiable person. Processing is anything we do with your personal data, including using, storing, sharing and deleting it.
   • This notice was last updated on the date shown at the top. We may change this notice at any time by posting an updated version on the Site and will make reasonable efforts to bring any material changes to your attention. You may wish to check it before using the Site as any changes will be effective from the date that they are made.
2. CONTACT INFORMATION
   • If you have any concerns or would like further information about our use of data or this notice in general, you can contact our Data Protection Officer through email;support@tokenclan.io or write in and send in your request to 81 Ayer Rajah Crescent, #02-45, Singapore, 139967.
3. WHAT INFORMATION DO WE COLLECT?
   • We collect, store and use the types of personal data set out in the table at the end of this notice.
4. HOW WILL WE USE YOUR PERSONAL DATA?
   • We will use your personal data for the purposes set out in the table at the end of this notice.
5. HOW DO WE SHARE YOUR PERSONAL DATA?
   • When we share personal data, we do so in accordance with Personal Data Protection Act (PDPA), Singapore. We may share certain personal data:
     • with government or quasi-governmental organisations, law enforcement and other regulatory authorities or third parties when required or permitted by law, including but not limited to in response to court orders, for the prevention and detection of crime and to protect intellectual property and any other legal rights;
     • if the Company or part of the business is sold, transferred or integrated with another business, with our advisers, a prospective purchaser, a prospective purchaser’s advisers or the new owner of the Company to facilitate the process; and
   • We may also provide third parties with aggregated but anonymised information and analytics about our customers. Before we do so we will make sure that it does not identify you.
   • In some cases, when we share personal data, it will involve the transfer of that personal data to countries outside Singapore which have different data protection standards to those which apply in Singapore.
   • Where we transfer personal data outside Singapore we will ensure that we will obtain your consent for the transfer to be made and take steps to ensure there are adequate safeguards to protect your privacy rights under a standard of protection that is at least comparable to that provided under the PDPA.
6. 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 our Data Protection Officer 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.
   • Whilst 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 goods or services to you 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 in writing in the manner described in clause 6.1 above.
   • 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 or required under applicable laws.
7. USE OF COOKIES AND SIMILAR TECHNOLOGIES
   • We and our third-party service providers use cookies and similar technologies to collect information about, and relevant to, your usage of the Site. Cookies are small text files that are stored on your computer when you visit the Site. It is standard practice to use cookies to make your experience better when using a website.
   • We use the following categories of cookies and similar technologies on this Site:
     • Strictly necessary cookies: These cookies are essential to enable you to move around the Site and use its features. Without these cookies, services you have asked for (such as remembering your login details or the items you placed in your basket) cannot be provided.
     • Analytics cookies: These cookies collect information about how you use the Site, for instance which pages you go to most often, what searches you perform and if you get error messages from web pages. Information these cookies collect can be used to improve how the Site works.
     • Customization cookies: These cookies allow the Site to remember choices you make (such as your user name) and provide enhanced, more personal features. These cookies cannot track your browsing activity on other Sites.
     • Social media cookies: These cookies allow you to share your activity on the Site on social media such as Facebook and Twitter. These cookies are not within our control. Please refer to the privacy policies of the social networks in question for information regarding how their cookies work.
   • When you visit the Site for the first time (and periodically after that), we will request your consent to the setting of all cookies other than strictly necessary cookies.
   • You can delete existing cookies and disable some or all types of cookies in future if you wish. To disable some or all types of cookies, you will have to change the settings on your browser. If you change your mind, you can enable cookies again at any time. Disabling cookies on your browser may stop the Site from working properly.
   • To find out more about cookies please visitwww.allaboutcookies.org.
8. THIRD PARTY LINKS
   • This Site contains links to other websites over which we have no control. We are not responsible for and do not review or endorse the privacy policies or practices of other Sites which you choose to access from this Site. We encourage you to review the privacy policies of those other Sites, so you can understand how they collect, use and share your personal information.
9. YOUR RIGHTS
   • We respect your rights to privacy and will respond to requests for access or control over information about you in accordance with Data Protection Law. We may require you to verify your identity before we take any action.
   • Depending on the reason we have your personal data, you have a right to:
     • access the personal information we hold about you (commonly known as subject access);
     • request that we correct or complete personal information we hold about you that is inaccurate or incomplete;
     • request that we erase your personal information in some circumstances, or object to our processing it as detailed at clause 9.5;
     • restrict how we use your personal information, in certain circumstances;
     • request that we provide you with copies of your personal information in a machine-readable format or transfer it across different services; and
     • where we have asked for your consent to process your data, to withdraw this consent.
   • 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. If you wish to exercise any of these rights, please contact us using the details in clause 2.1 above.
   • 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).
   • Your right to object

     You have a right to object to our processing of your personal data and ask us to stop doing so. If we are processing your personal data or direct marketing purposes (which includes profiling to the extent that it is related to such direct marketing) and you object to this, we will stop processing your personal data immediately.

     If our processing of your personal data is in the public interest or pursuant to our legitimate interests and you object to this, we will stop processing your personal data unless we have compelling reasons which override your interests, or our use of your personal data is for the establishment, exercise or defence of legal claims.

     We hope that we can satisfy any queries you may have about the way we process your data. However, if you have unresolved concerns you also have the right to complain to data protection authorities by going to www.pdpc.gov.sg

10. DATA RETENTION
    • Your personal data will only be kept for as long as necessary for our purposes. Specific periods are set out in the table at the end of this notice.
11. DATA PROTECTION PRINCIPLES
    • We process your personal data in accordance with the following principles:
      • we process your personal data lawfully, fairly and in a transparent way;
      • we collect your personal data for specified, explicit and legitimate purposes; any further processing we do is compatible with the original purposes for which for which we collected it;
      • we only process personal data which is adequate, relevant and limited to what is necessary to achieve the purpose for which it is processed;
      • we take reasonable steps to ensure that all personal data is accurate and kept up to date where necessary;
      • we do not store personal data in a form which identifies you for any longer than is necessary for the purposes of processing; and
      • we process personal data securely and in a way that protects against unauthorised or unlawful processing, accidental loss, destruction or damage.
    • When we ask for your personal data we will tell you whether you are required by law or contract to provide it, and what will happen if you do not provide the data.
    • Any request for consent to the processing of your personal data will be made directly to you and will include information about why we require the personal data and what will be done with it.
12. WHAT IS OUR LAWFUL BASIS FOR PROCESSING?
    • We will only process personal data when we have a lawful basis for doing that processing. The table at the end of this notice sets out the lawful basis we rely on for each type of data we process.
    • We will choose one of the lawful bases to justify how we use your personal data. These are:
      • Consent: You have given consent to the processing of your personal data for one or more specific purposes.
      • Contract: The processing is necessary for the performance of a contract with you or in order to take steps at your request before entering into a contract.
      • Legal obligation: We need to process your personal data to comply with a legal obligation.
      • Vital interests: The processing is necessary to protect the vital interests of you or another person.
      • Public interest: Processing is necessary for the performance of a task carried out in the public interest or in the exercise of some official authority.
      • Legitimate interests: Processing is necessary for the purposes of legitimate interests pursued by us or someone else, except where such interests are overridden by your interests or fundamental rights and freedoms requiring the protection of your personal data.