PRIVACY POLICY

ECOMI TECHNOLOGY PTE. LTD.(the “Company” or “we”) are committed to protecting and respecting your privacy.

This policy (together with our Terms and Conditions and Cookie Policy) sets out how we will process and use any personal data we collect from you, or that you provide to us. Please read the following carefully to understand our views and practices regarding your personal data and how we will handle it. By using the Secure Wallet app, you accept and consent to the practices described in this policy.

The data controller is ECOMI TECHNOLOGY PTE. LTD., a company incorporated in Singapore. We have appointed a data protection officer who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact our data protection officer by email at the Contact information set out below.

1. How we use your data

When you register an account with us:

• We will use your personal information to process your registration and to carry out our obligations arising from any agreements entered into between you and us.
• Information about you that we collect from you may include, your name, age, e-mail location, cryptocurrency wallet public address,
• We may also share your personal information with our affiliates, and selected third parties including business partners, suppliers and subcontractors for the performance of any contract we enter into with them or you

Where you have expressed an interest in receiving communications from us:

• This section applies if you have opted in to receive communications regarding our project from us, including your participation in our activities or events.
• We will handle your personal information (such as your name and email address) to provide you with communications regarding our project.
• When we send you emails regarding our project because you have opted-in to receive them, we rely on your consent to contact you.
• Every email we send to you regarding our project will also contain instructions on how to unsubscribe from receiving them.
• You can tell us that you do not want your personal information to be processed in this way at any time by contacting us at the Contact Information set out below or, where relevant, by following the unsubscribe link shown in every email you receive from us

To make our experience better:

• We share your aggregated, anonymous data with third party analytics providers that assist us in the improvement and optimisation of our product.
• We will also use your personal information for the purposes of making our app more secure, and to administer our app and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes.
• We process your data for this reason because we have a legitimate interest to provide you with the best experience we can, and to ensure that our site is kept secure.

If our company is sold

• We will transfer your personal information to a third party in the event that (i) we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets and/or (ii) if the Company or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be part of the assets transferred to such third party.
• We process your personal information for this purpose because we have a legitimate interest to ensure our business can be continued by the buyer. If you object to our use of your personal information in this way, the relevant seller or buyer of our business may not be able to provide services to you.

In order to comply with any legal obligation:

• In some circumstances we may also need to share your personal information if we are under a duty to disclose or share it to comply with any legal obligation, or in order to enforce or apply our Terms of Use or other agreements; or to protect the rights, property, or safety of the Company, our customers, or others.
• This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

2. Where we store your personal data

We engage commercial cloud storage providers to store the data that we collect from you. Therefore, your data may be transferred to and stored in different jurisdictions and may also be processed by staff operating within the various countries who work for us or for one of our contractors. By submitting your personal data, you agree to this transfer, storing or processing. We will take commercially reasonable steps to ensure that your data is handled securely and in accordance with this privacy policy and the relevant privacy laws.

Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share the password with anyone. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will take all commercially reasonable efforts to prevent unauthorized access.

3. How long do we retain your data for

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any accounting or legal requirements.

To determine the appropriate retention period for the personal information we hold, we consider the amount, nature and sensitivity of the personal information, the risk of harm from unauthorised use or disclosure of your personal information, the reasons why we handle your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances, we may anonymise your personal data so that it can no longer be associated with you for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

4. Your rights

You have various rights under the data protection laws, which you can exercise by contacting us. The easiest way to do this is by email at the Contact Information set out below.

Right to object

You have the right to object to us handling your personal information when:

• we are handling your personal information based on our legitimate interests (as described in the “How we use your data” section above). If you ask us to stop handling your personal information in this way, we will stop unless we can show you that we have compelling grounds as to why our use of your personal information should continue; or
• for marketing purposes. If you ask us to stop handling your personal information on this basis, we will stop.

Right of access

You have the right to access your personal information which we are handling, and to receive confirmation as to whether your personal information is being processed by us, as well as various other information relating to our use of your personal information.

Right to rectification

You have the right to require us to rectify any inaccurate personal information we hold about you. You also have the right to have incomplete personal information we hold about you completed, by providing a supplementary statement to us.

Right to restriction

You can restrict our processing of your personal information where:

• you think we hold inaccurate personal information about you;
• our handling of your personal information breaks the law, but you do not want us to delete it;
• we no longer need to process your personal information, but you want us to keep it for legal reasons; or
• where we are handling your personal information because we have a legitimate interest (as described in the “How we use your data” section above, and are in the process of objecting to this use of your personal information.

Where you exercise your right to restrict us from using your personal information, we will then only process your personal information when you agree, except for storage purposes and to handle legal claims. We will inform you before any restriction of processing is lifted.

Right to data portability

You have the right to receive your personal information in a structured, standard machine readable format and to send this to another organisation controlling your personal information.

This right only applies to your personal information we are handling because you consented to us using it or because there is a contract in place between us.

Right to erasure

You have the right to require us to erase your personal information which we are handling in the following circumstances:

• where we no longer need to use your personal information for the reasons we told you we collected it for;
• where we needed your consent to use your personal information, you have withdrawn your consent and there is no other lawful way we can continue to use your personal information;
• when you object to our use of your personal information and we have no compelling reason to carry on handling it;
• if our handling of your personal information has broken the law; and
• when we must erase your personal information to comply with a law we are subject to.

5. Changes to our privacy policy

We reserve the right to amend this privacy policy at any time. Any changes we make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. You agree that it is your responsibility to check periodically for any updates or changes to our privacy policy.

6. Contact Information

We welcome any questions, comments and requests regarding this privacy policy. Please address them to our data protection officer at hello@ecomi.com