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Privacy Policy

Effective as of 29 March 2023 / Last updated on 07 February 2024

DAOSURV Pte Ltd (hereinafter referred to as, “DAOSURV”, “we”, “our”, or “us”) provides the DAOSURV Services. This privacy policy (“Privacy Policy”) consists of our Data Protection Policy and Cookies Policy.
By your use and access of the DAOSURV Services (as defined in the Terms found at https://token.unlocks.app/terms), you are deemed to have read, understood and accepted the terms and conditions of this Privacy Policy which shall be read together and complement, our Terms and our Service Subscription Agreement where you have one or more Subscription Plans with us.
In the event that you are below eighteen (18) years of age, you confirm that you have your parent’s or legal guardian’s consent to the terms of this Privacy Policy. Unless otherwise defined in this Privacy Policy, capitalised terms used in this Privacy Policy shall have the respective meaning set out in our Terms.
You may contact our Data Protection Officer at [email protected] at any time to update your preferences, to withdraw or vary any consent previously provided to us, or to seek the deletion or correction of your information previously provided to us. More details are set out below.
We carry out periodic reviews of our internal policies from time to time and where necessary, we will update this Privacy Policy. We reserve the right to amend the terms of the Privacy Policy at any time and at our sole and absolute discretion.
A) DATA PROTECTION POLICY
We comply strictly with Singapore’s Personal Data Protection Act 2012 (the “PDPA”).
We recognise the importance of safeguarding the Personal Data you have provided to us and it is our responsibility to properly manage, protect and process your Personal Data.
Our DAOSURV data protection policy (this “Data Protection Policy”) is designed to inform your understanding of how we collect, use, disclose, store, transfer and/or process the Personal Data you have provided to us, as well as to assist you in making an informed decision when you are providing us with your consent and/or any of your Personal Data.
If you, at any time, have any queries on this Privacy Policy or in relation to how we may manage, protect and/or process your Personal Data, please do not hesitate to contact our Data Protection Officer.
1. CONSENT TO COLLECTION OF PERSONAL DATA
1.1 “Personal Data” shall have the same meaning ascribed to it in the PDPA.
1.2 We will collect your Personal Data, either directly from you or your authorised representatives from the access and use of our website and/or any of all of the DAOSURV Services, and/or through our third-party service providers (e.g. partners, resellers) and third-party data intermediaries.
1.3 We will notify you of the purposes for which your Personal Data may be collected, used, disclosed, stored and/or processed, as well as obtain your consent for the collection, use, disclosure and/or processing of your Personal Data for the intended purposes, save for exceptions or exemptions to consent permitted under applicable laws.
2. OTHER DATA COLLECTED
In addition to Personal Data, we also collect other information directly from you (“Other Data”) in the following ways:
(a) through your IP address, web browser type and version and/or operating system (automatically collected);
(b) through your activity on our home page and DAOSURV Services (automatically collected);
(c) through Cookies (defined below); and
(d) through any other data and information you provide us with by any other means of communication whatsoever.
All Personal Data and Other Data collected from you shall be collectively referred to as “Collected Data”. In accessing our home page and any of the DAOSURV Services, you have consented to our collection of the Collected Data.
3. PURPOSES FOR COLLECTION, USE, DISCLOSURE AND PROCESSING OF COLLECTED DATA
3.1 The Collected Data which we collect from you may be collected, used, disclosed, stored and/or processed for various purposes, depending on the circumstances for which we may/will need to process your Collected Data, include but are not limited to:
(a) Facilitating our operation and provision of the DAOSURV Services which you use;
(b) Communicating with you on your enquiries, and/or sending you marketing, advertising and promotional information and materials relating to DAOSURV Services that we, our partners and/or third-party organisations with whom we are collaborating, may be selling or marketing;
(c) for our internal account handling, business and administrative purposes, including without limitation, administrative matters on your Subscription Plans and/or managing your registered accounts, processing your sign-ups and/or registrations for mailing lists;
(d) Conducting market research and customer satisfaction surveys;
(e) Improving the Content as well as the features and quality of, our DAOSURV Services which we offer to you; and
(f) Such other purposes that we will notify you of when seeking your consent;
(collectively, the “Purposes”).
3.2 In order to conduct our business operations more efficiently and to fulfil the above-said Purposes, you consent to our disclosure from time to time of the Collected Data you have provided to us to our third-party service providers, third-party data intermediaries, our affiliates or related corporations, and/or other third parties whether situated in or outside your country of residence.
3.3 Such third-party service providers, agents and/or affiliates or related corporations and/or other third parties would be processing some or all of the Collected Data either on our behalf or otherwise, in furtherance of the Purposes.
4. DATA YOU PROVIDE VOLUNTARILY
4.1 Account Information: You may choose to give us permission to access your wallet address as specified in the Terms.
4.2 Billing Information: If you subscribe to any Subscription Plan with us, your payment will be processed by third party payment services provider(s), details of which will be set out in the Service Subscription Agreement.
5. SPECIFIC ISSUES FOR THE DISCLOSURE OF PERSONAL DATA TO THIRD PARTIES
5.1 We respect the confidentiality and integrity of the Personal Data you have provided to us.
5.2 In that regard, we will not disclose your Personal Data to third parties without first obtaining your prior written consent permitting us to do so. However, please note that we may disclose your Personal Data to third parties without first obtaining your consent in certain situations, including, without limitation, the following:
(a) cases in which the disclosure is permitted, required or authorised based on the applicable laws and/or regulations;
(b) cases in which the purpose of such disclosure is clearly in your interests, and if your consent cannot be obtained in a timely way;
(c) cases in which the disclosure is necessary to respond to an emergency that threatens the life, health or safety of yourself or another individual;
(d) cases in which the disclosure is necessary for any lawful investigation or proceedings;
(e) cases in which the Personal Data is disclosed to any officer of a prescribed law enforcement agency, upon a lawful request; and/or
(f) cases in which the disclosure is to a public agency and such disclosure is necessary in the public interest.
5.3 For the avoidance of doubt, the instances listed above at paragraph 5.2 above are not intended to be exhaustive. For more information on the exceptions and exemptions, you are encouraged to peruse the PDPA, of which the current version in force is publicly available at government website.
5.4 Where we disclose your Personal Data to third parties with your consent, we will use our best efforts to require such third parties will be under legal obligations or binding agreements to protect your Personal Data in the manner that we do.
6. ANONYMOUS STATISTICS
6.1 We may anonymise your non-personally identifiable Collected Data for the purposes of internal statistics (“Reports”) to help us improve our DAOSURV Services, for future enhancements and/or marketing purposes. All information disclosed in these Reports shall only include non-personally identifiable data or anonymised data. We may in turn allow access of these Reports to third parties.
7. REQUEST FOR ACCESS AND/OR CORRECTION OF PERSONAL DATA
7.1 You may request to access and/or correct the Personal Data currently in our possession or control by submitting a written request to us. We will require enough information from you in order to ascertain your identity as well as the nature of your request so as to be able to deal with your request. Hence, please submit your written request to the DATA Protection Officer. We may request a reasonable administrative fee for the handling and processing of your request, which we shall disclose to you upon your request to access and/or correct your Personal Data.
7.2 For a request to access Personal Data, once we have sufficient information from you to deal with the request, we will seek to provide you with the relevant personal data within thirty (30) days. Where we are unable to respond to you within the said thirty (30) days, we will notify you of the soonest possible time within which we can provide you with the information requested. Certain Personal Data is exempt from such access in accordance with the PDPA.
7.3 For a request to correct Personal Data, once we have sufficient information from you to deal with the request, we will:
(a) correct your Personal Data within thirty (30) days. Where we are unable to do so within the said thirty (30) days, we will notify you of the soonest practicable time within which we can make the correction. Note that the PDPA exempts certain types of Personal Data from being subject to your correction request and also provides for situation(s) when correction need not be made by us despite your request; and
(b) subject to paragraph 7.4, we will send the corrected Personal Data to every other organisation to which the Personal Data was disclosed by us within a year before the date the correction was made, unless that other organisation does not require the corrected Personal Data for any legal or business purpose.
7.4 Notwithstanding paragraph 7.3(b), we may, if you so consent, send the corrected Personal Data only to specific organisations to which the Personal Data was disclosed by us within a year before the date the correction was made.
8. REQUEST TO WITHDRAW CONSENT
8.1 You may withdraw your consent for the collection, use and/or disclosure of your Personal Data in our possession or under our control by submitting your request to our Data Protection Officer.
8.2 We will process your request within a reasonable time from such a request for withdrawal of consent being made, and will thereafter not collect, use, disclose, store and/or process your Personal Data in the manner stated in your request.
8.3 Please be aware that such withdrawal of consent may result in certain legal consequences arising from such withdrawal. In this regard, depending on the extent of the consent withdrawn, we may not be able to continue with your existing relationship with us, including suspending or terminating Subscription Plan(s).
9. ADMINISTRATION AND MANAGEMENT OF PERSONAL DATA
9.1 We will endeavour to ensure that your Personal Data is accurate and complete if your Personal Data is likely to be, used by us to make a decision that affects you, or disclosed to another organisation. However, this means that you must also update us of any changes in your Personal Data that you had initially provided us with. We will not be responsible for relying on inaccurate or incomplete Personal Data arising from you not updating us of any changes in your Personal Data provided to us.
9.2 We will also put in place reasonable security arrangements to ensure that your Personal Data is adequately protected and secured. Appropriate security arrangements will be taken to prevent any unauthorised access, collection, use, disclosure, copying, modification, leakage, loss, damage and/or alteration of your Personal Data. However, we cannot assume responsibility for any unauthorised use of your Personal Data arising from circumstances beyond our control, including illegal access by third parties through no fault of ours.
9.3 We shall retain the Personal Data which we collect for as long as reasonably necessary to fulfil the purposes for which the data was collected, to perform our contractual and legal obligations, as well as for any applicable statutory limitation periods.
9.4 We will also put in place measures such that your Personal Data in our possession or under our control is destroyed and/or anonymised as soon as it is reasonable to assume that:
(a) the purpose for which that Personal Data was collected is no longer being served by the retention of such Personal Data; and
(b) retention is no longer necessary for any other legal or business purposes, after which the only data retained by us will be data which is necessitated by compliance and legal requirements, such as invoices, subscription information, audit logs, etc.
9.5 Where your Personal Data is to be transferred out of Singapore we will seek your consent (if not already provided under the Terms and this Privacy Policy), unless an exception under the PDPA or applicable law applies, and take appropriate steps to ascertain that the foreign recipient organisation of the personal data is bound by legally enforceable obligations to provide to the transferred personal data a standard of protection that is at least comparable to the protection under the PDPA.
9.6 This may include us entering into an appropriate legal agreements with the foreign recipient organisation dealing with the Personal Data transfer.
10. MARKETING COMMUNICATIONS
10.1 If you should consent, from time to time you may receive from us a variety of communications, including but not limited to newsletters, emails and text messages (the “Marketing Communications”), that will include service updates, product advertising and offers or promotions related to our Services which we believe you may be interested in.
10.2 If you decide at any time that you no longer wish to receive Marketing communications from us, please follow the unsubscribe instructions provided in any of the communications. You may also opt out from receiving commercial emails from us by sending your request to us by email at [email protected]; [email protected];
10.3 Please be aware that, even after you opt out from receiving commercial messages from us, you will continue to receive some important service information or administrative messages from us that we believe is critical to the Services. In these exceptional circumstances, such information will be sent to you regardless of your Marketing Communications preferences.
10.4 If you send us a request (for example via a support email or via one of our feedback mechanisms), we reserve the right to publish it in order to help us clarify or respond to your request or to help us support other users.
11. GRIEVANCE PROCESS
11.1 If you have any complaint or grievance about how we are handling your Personal Data, we welcome you to contact us with your complaint or grievance via e-mail to our Data Protection Officer at [email protected].
B) COOKIES POLICY
1. Please note that we use “cookies” on our website. Cookies are text files that we put on your computer which store/record information about your visit to and use of the Site (“Cookies”). Cookies can compile information about your browsing habits and can also enhance your browsing experience. We have carefully chosen these Cookies and had taken steps to ensure that your privacy is protected and respected at all times. We set out more details about the Cookies we use below. You can also choose to disable Cookies.
2. We use Cookies for the following purposes:
(a) to improve your user experience when using and accessing DAOSURV Services;
(b) to remember your preferences;
(c) to monitor traffic to our home page and understand how our sites are performing; and
(d) to enable DAOSURV Services to function properly;
(collectively the “Cookie Purposes”).
3.You can control Cookies through your web browser settings. This allows you to determine which Cookies to allow and which to refuse. If you disallow the use of Cookies on our Site and/or choose to the delete the Cookies at any time, please note that you may not be able to access the full range of functions that our Site offers.
4. Personal Data (if any) that we collect from you through Cookies may be passed to our third-party service providers or third-party data intermediaries, whether located in Singapore or elsewhere, for one or more of the Cookie Purposes, for managing and/or administering our Site, or for the purpose of data hosting, storage and/or backup.
5. Your use and access of our home page and any of our DAOSURV Services constitutes your consent to our use of the Cookies in accordance with this Cookies Policy.
This Privacy Policy is effective as of 29 March 2023.
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