PRIVACY POLICY

Getstan Technologies Pte Ltd (“Company”) has built the [●] application as a free-to-use mobile application, along with the website at [●] (collectively referred to as the “Platform”), and the offered content therein, which is provided to users (“User”) at no cost and is intended for use as is. This page is used to inform website visitors regarding Company’s policies in relation to the collection, use, and disclosure of personal information of anyone using Company’s Services through the Platform.

If User chooses to use any of the Services, then User agrees to the collection and use of information in accordance with this policy. The Personal Information that Company collects is used for providing and improving the Service. Company does not use or share User’s information with anyone except as described in this Privacy Policy.

The terms used in this Privacy Policy have the same meanings as in Company’s End User License Agreement (“EULA”), which are accessible at the [●] application and website, unless otherwise defined in this Privacy Policy.

This Privacy Policy shall apply to all the Users using the Platform for the Services. 

1. Salient Features of this Privacy Policy

1. Company will collect Personal Information by lawful and fair means and, with the knowledge or consent of the User concerned.
2. Before or at the time of collecting Personal Information, Company will identify the purpose for which information is being collected.
3. Company will collect and use Personal Information solely for fulfilling those purposes specified by Us and for other ancillary purposes, unless Company obtains the consent of the individual concerned or as required by law.
4. Company will protect Personal Information by using reasonable security safeguards against loss or theft, as well as unauthorized access, disclosure, copying, use or modification.
5. Company will make readily available to Users/Users information about Company’s policies and practices relating to the management of Personal Information.
6. Company will only retain Personal Information for as long as necessary for the fulfilment of those purposes.

Please do note that Personal Information and non-personal information may be treated differently as per this Privacy Policy

2. Application and Scope 

This Privacy Policy describes Company’s practices with respect to the collection, use and disclosure of Personal Information by Company.

This Privacy Policy (this “Policy”) is intended to establish responsible and transparent practices for the management of Personal Information and to satisfy the relevant and applicable legal requirements. This Policy sets out the standards, responsibilities, rights and obligations of the Company in respect of any Personal Information collected, accessed or processed by Company in the course of its business operations and specifies the obligations of Company that arise from Company’s End User License Agreement (“EULA” available here) (the “Terms”) entered into between Company and its Users/ Users, whereby Company might handle or have access to Personal Information.

This Policy also governs how Company uses and discloses Personal Information collected from Users, who visit its Platform. It also explains how Company uses cookies and similar technologies. If User does not agree with this Policy, then User should not access, or use the Platform and any related Services.

This Policy is an electronic record in the form of an electronic contract formed under the applicable laws of Singapore. This Policy does not require any physical, electronic or digital signature.

This Policy is published and shall be construed in accordance with the provisions of the applicable laws of Singapore that require publishing of the privacy policy for collection, use, storage and transfer of sensitive personal data or information.  

3. Definition of Personal Information: “Personal Information” means any information about an identifiable individual, including email addresses, contact details, information regarding User’s transactions on the Platform, User’s financial information, e-wallet address, internet protocol address, information provided to Company in the course of its business operations, or which Company may receive from business inquiries and any other items of “sensitive personal data or information” as such term is defined under the laws of Singapore, identification code of User’s communication device which User uses to access the Platform or any other information that User provides during User’s registration process, on the Platform. Personal Information that is aggregated and/or de-identified or that cannot be associated with an identifiable individual is not considered to be Personal Information.
4. Collection and Use of Personal Information through the Services (Purpose)

When providing the Services, Company only processes Personal Information in accordance with the EULA and applicable laws. Company generally uses Personal Information from or about its Users for the following purposes:

1. to create, establish and administer User’s account, to process payments, to respond to User’s inquiries related to his/her account and to contact User about Company’s Services or account-related matters;
2. to provide Services, including to provide Users with access and use of the Platform and User support;
3. to manage and develop Company’s business and operations;
4. to measure and analyze User behavior;
5. to monitor, maintain and improve Company’s Services or features;
6. to understand how Users interact with Company and ensure Company’s Services, products or features work correctly;
7. to develop new services, products, features, programs and promotions;
8. to understand Users’ needs and preferences and customize how Company tailors and markets products, programs and Services to Company’s Users based on their interest;
9. to meet legal and regulatory requirements and to allow Company to meet contractual requirements relating to the Services provided to User;
10. to conduct surveys on the quality of Services or to collect feedbacks on the Services;
11. to provide User with offers for additional services, features and products that Company believes may be of interest to User;
12. to send User important information regarding the Platform, changes in EULA, user   agreements, and policies and/or other relevant information;
13. to implement information security practices and to determine any security breaches, computer contaminant or computer virus;
14. to investigate, prevent, or take action regarding illegal activities and suspected fraud;
15. to enable a potential buyer or investor to evaluate the business of the Company;
16. to conduct market or benchmarking research and data analytics by tracking and analyzing current or previously collected Personal Information; and
17. to measure the effectiveness of Company’s marketing.

When possible, Company will use Personal Information in an aggregated and/or de-identified format. Unless required or authorized by law, Company will not use Personal Information for any other or new purpose without obtaining prior consent.

5. Collection and Use of Personal Information through the Platform

Company generally collects and uses Personal Information from or about its Platform Users as follows:

1. For Creation of Account: For enabling the access to the Services, User needs to create an account. In order to manage such account from creation to deletion, the Company shall collect and process identification Personal Information such as User’s first name, last name, username and contact details).
2. For use of Services: The Company collects and processes User’s Personal Information for the use of the Services. This processing requires the Company to collect and process the following categories of Personal Information:

1. for the purchase, transfer, withdrawal and exchange of Collectibles: username and the blockchain public keys or payment identifier and part of User’s bank card's digits;
2. for the participation in the Stan Trump Game: username, blockchain public keys and prize winners;
3. for leaderboard: username.
4. The legal basis on which the Company relies for this purpose is the performance of a contract to which User is a party.

3. Information Provided by Users. In many cases, Company collects Personal Information directly from Users when they visit or use the Platform. For instance, Company may collect the following types of information:

• Inquiries and Requests for a Trial or Service. Company may collect Users’ name, contact information, email address and any other information provided when Users make an inquiry or contact Company through the Platform, when Users sign up to receive Company’s newsletter/updated about events or when Users submit a request or an order for a Company trial for Service.
• Personalization of Platform: When Users visit the Platform, they may, from time to time, be invited to provide information such as User’s title to help Company personalize or customize the User’s experience when using the Platform.
• Payment Processing: In connection with the payment of any Service on the Platform or through any other linked platform (whether offered by Company or its partners), Company may seek further information pertaining to the payment instrument/modes used by the User for payments towards such Service fee.

4. Technical Information: When Users visit the Platform, Company may collect, using electronic means such as cookies, technical information. This information may include information about visits to the Platform, including the IP address of the Users’ computer and which browser was used to view the Platform, the Users’ operating system, resolution of screen, location, language settings in browsers, the site the User came from, keywords searched (if arriving from a search engine), the number of page views, information entered, advertisements seen, etc. This data is used to measure and improve the effectiveness of the Platform or enhance the experience for Users. While most of the time this information is depersonalized, if this information relates to an identifiable individual, Company will treat this information as Personal Information. Company may also, without limitations, collect and use the following type of information when Users visit and/or interact with Company on the Platform:

• Google Analytics: Company uses Google Analytics which allows it to see information on User Platform activities including, but not limited to, page views, source and time spent on the Platform. This information is depersonalized and is displayed as numbers, meaning that it cannot be tracked back to individuals. Users may opt-out of Company’s use of Google Analytics by visiting the Google Analytics opt-out page.
• HubSpot:^[a] Company uses HubSpot which allows it to see information on Platform activities including, but not limited to, page views, source and time spent on the Platform. However, this information is not depersonalized and Users may not opt-out of Company’s use of HubSpot.
• Google AdWords: Company uses Google AdWords Remarketing to advertise Company across the Internet and to advertise on third party websites (including Google) to previous visitors of the Platform. AdWords remarketing will display ads to Users based on what parts of the Platform they have viewed by placing a cookie on the Users’ web browser. It could mean that Company advertises to previous visitors who haven’t completed a task on the site or this could be in the form of an advertisement on the Google search results page, or a site in the Google Display Network. This cookie does not in any way identify the User or give access to the Users’ computer or mobile device. The cookie is only used to indicate to other websites that the User has visited a particular page on the Platform, so that they may show the User ads relating to that page. If Users do not wish to participate in Google AdWords Remarketing, they can opt out by visiting Google’s Ads Preferences Manager.
• Interest-based Advertising. Company may also allow a limited number of trusted third parties to install cookies on Users’ hard drive from the Platform. The Platform may include third-party advertising and links to other websites which may be used to generate personalized advertisements. Personalized ads, sometimes referred to as interest-based or behavioral ads, are ads based upon information about Users, such as page views on the Platform, information requests or purchases on the Platform. Company does not provide any Personal Information to advertisers or to third party sites that display interest-based ads on the Platform. However, advertisers and other third-parties (including the ad networks, ad-serving companies, and other service providers they may use) may assume that Users, who interact with or click on a personalized ad or content displayed on the Platform are part of the group that the ad or content is directed towards. Advertisers or ad companies working on their behalf sometimes use technology to serve the ads that appear on the Platform directly to Users’ browser. They may also use cookies to measure the effectiveness of their ads and to personalize ad content. Company does not have access to or control over cookies or other features that advertisers and third-party sites may use, and the information practices of these advertisers and third party Platform are not covered by this Policy. Please contact them directly for more information about their privacy practices.
• Segment: Company uses Segment which allows it to transmit user Platform activities including, but not limited to, page views, source and time spent on the Platform to Company’s data warehouse. This information is depersonalized and is displayed as numbers, meaning that it cannot be tracked back to individuals. Users may not opt-out of Company’s use of Segment.

5. Choice with Cookies. Users can block the use of cookies by activating the settings in their browser/device. If Users choose to withhold consent, or subsequently block cookies, they may not be able to access all or part of the content of the Platform. Additionally, Users can disable or delete similar data used by browser add-ons, by changing the add-on’s settings or visiting the Platform.
6. Privacy Policies of other Platform: This Policy only addresses the use and disclosure of information by Company. Other platforms that may be accessible through the Platform have their own privacy policies and data collection, use and disclosure practices.
7. Personal Information from Other Sources: Company may obtain from third parties additional Personal Information about a Platform User if such User gave permission to those third parties to share its information.

6. Sharing of Personal Information 

Company will not sell, rent or trade Personal Information to any third party. However, Company may share Personal Information when authorized and/or required by law or as follows:

1. Within Company: Company may share Personal Information within Company (i.e. between Company’s affiliates and subsidiaries) in Singapore and overseas for the purposes described in this Policy.
2. Service Providers: Company may grant access to Personal Information to third-party service providers in connection with the performance or the improvement of its Platform and Services. Before sharing any Personal Information with any of its third-party service providers, Company will request that the third party maintains reasonable data management practices for maintaining the confidentiality and security of Personal Information and preventing unauthorized access. Provided however, the Company shall not be responsible for any misuse or unauthorized disclosure of any Personal Information by such third party service provider. Company shall inform the User of such unauthorized disclosure as soon as reasonably possible.
3. As Permitted or Required by Law: Company may disclose Personal Information as required by applicable law or by proper legal or governmental authority. Company may also disclose information to its accountants, auditors, agents and lawyers in connection with the enforcement or protection of its legal rights. Company may also release certain Personal Information when it has reasonable grounds to believe that such release is reasonably necessary to protect the rights, property or safety of others and itself, in accordance with or as authorized by law. In the event Company receives a governmental or other regulatory request for any Personal Information, Company will promptly notify User, unless it is prohibited to do so, in order that User shall have the option to defend such action. Company shall reasonably cooperate with User in such defense.
4. Business Transaction: Company may disclose Personal Information to a third party in connection with a sale or transfer of business or assets, an amalgamation, re-organization or financing of parts of Company’s business. However, in the event the transaction is completed, Personal Information will remain protected by applicable data protection laws of Singapore. In the event the transaction is not completed, Company will require the other party not to use or disclose the Personal Information received in any manner whatsoever.

7. User Contributions

Company’s User agrees not to host, display, upload, modify, publish, transmit, store, update or share any information that:

1. belongs to another person and to which User do not have any right; 
2. includes bodily privacy, insulting or harassing, that is libelous, racially or ethnically objectionable, relating or encouraging money laundering or gambling, or otherwise inconsistent with or contrary to the laws in force;
3. is harmful to children; 
4. infringes any patent, trademark, copyright, or other proprietary rights;
5. violates any law for the time being in force; 
6. deceives or misleads the addressee about the origin of the message or knowingly and intentionally communicates any information which is patently false or misleading in nature but may reasonably be perceived as a fact; 
7. impersonates another person; 
8. threatens the unity, integrity, defence, security or sovereignty of Singapore, friendly relations with foreign states, or public order, or causes incitement to the commission of any cognizable offence or prevents investigation of any offence or is insulting other nation; and/or
9. contains software virus or any other computer code, file or program designed to interrupt, destroy, or limit the functionality of any computer resource.

8. Log Data

Whenever User uses Service, Company collects data and information (through third party products) on User’s phone called Log Data. This Log Data may include information such as User’s device Internet Protocol (“IP”) address, device name, operating system version, the configuration of the app when utilizing Service, the time and date of User’s use of the Service, and other statistics.^[b]

9. Cross-border data transfer

Personal Information that Company holds about User may be transferred to countries outside of Singapore for any of the purposes mentioned in this Privacy Policy. User expressly provides his/her consent for transfer of such Personal Information outside Singapore. Any Personal Information will be protected in accordance with this Privacy Policy as well as any applicable laws and regulations.

10. Security and Consent

Company has in place physical, electronic and administrative safeguards to protect User’s Personal Information. User’s posting and sharing of Personal Information through the Platform constitutes User’s acceptance of the risk that Company cannot guarantee absolute security, and User hereby agrees to waive any claims that User may have against us and any right to seek legal relief from us due to any misuse of the Personal Information in the manner aforesaid.

Company will store and process the Personal Information in a manner consistent with industry security standards, and as long as necessary for the purposes described in this Policy, unless a longer retention is required by law. Company has implemented technical, organizational and administrative systems, policies, and procedures to help ensure the security, integrity and confidentiality of Personal Information and to mitigate the risk of unauthorized access to or use of Personal Information, including: (i) appropriate administrative, technical and physical safeguards and other security measures designed to ensure the security and confidentiality of the Personal Information it manages; (ii) a security design intended to prevent any compromise of its own information systems, computer networks or data files by unauthorized Users, viruses or malicious computer programs; (iii) appropriate internal practices including, but not limited to, encryption of data in transit; using appropriate firewall and antivirus software; maintaining these countermeasures, operating systems and other applications with appropriate reasonable up-to-date virus definitions and security patches so as to avoid any adverse impact to the Personal Information that it manages; (iv) appropriate logging and alerts to monitor access controls and to assure data integrity and confidentiality; and (v) permitting only authorized users access to systems and applications (together, “Security Program”). However, Company understands that as effective as Company’s security measures are, no security system is impenetrable. Thus, Company cannot guarantee the security of Company’s database, nor can Company guarantee that information User supplies will not be intercepted while being transmitted to Company over the internet.

Company maintains adequate training programs to ensure that its employees and any others acting on its behalf are aware of and adhere to its Security Program.

User has the right to withdraw his/her consent at any point, by contacting Company at [●]. Once consent is withdrawn, Company will be unable to provide User with the Service.

11. Links to Other Sites^[c]

This Service may contain links to other sites. If User clicks on a third-party link, User will be directed to that site. Company strongly advises User to review the privacy policy of these websites before proceeding to avail any services or engaging in a transaction with such third-party websites. Company has no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.

12. Children’s Privacy

The Services do not address anyone under the age of [●]. Company does not knowingly collect personally identifiable information from children under the age of [●]. In the event that Company discovers that a child under the age of [●] has provided Company with Personal Information, Company shall immediately delete such Personal Information from Company’s servers. If User is a parent or guardian and User is aware that User’s child has provided Company with Personal Information, please contact Company so that Company is able to take necessary actions.

13. Changes to This Privacy Policy

Company may update this Privacy Policy from time to time. Thus, User is advised to review this page periodically for any changes. Company will notify User of any changes by posting the new Privacy Policy or amendments to the Privacy Policy on this page. These changes are effective immediately after they are posted on this page. User’s continued use of this Platform, Company’s Services or providing Company with User’s Personal Information shall signify consent and acceptance of the terms of the updated Privacy Policy.

14. Governing Law

The Privacy Policy shall be governed in accordance with the laws of Singapore and any disputes arising out of or in connection with the Privacy Policy shall be subject to exclusive jurisdiction of courts in Singapore.

15. Grievance Redressal Mechanism

In accordance with the [Name of Singapore Information Technology Law] and its rules thereof, if User faces any grievance with respect to this Privacy Policy, User may contact Company’s Grievance Officer as provided below:

Name: [●]

Address: [●]

Email: [●]

The Grievance Officer shall acknowledge receipt of User’s complaint within [●] hours and shall dispose of the same within [●] days of receipt.

16. Contact

If User has any questions or suggestions about this Privacy Policy, then contact the Company at [●].

16. Data Deletion

Account Deletion Instructions can be found in this link.  [●].