Privacy Policy
This is the Privacy Policy of SBI Startale Labs Pte. Ltd. (Company Registration No. 202541123H) (herein referred to as the “Company”, “we”, “us” or “our” in this Privacy Policy), which operates the website. This Privacy Policy applies to all personal data that we hold about you as well as any personal data you may provide to us. By interacting with us (including use of the website), providing us with your personal data, submitting information to us or signing up for any newsletters, mailing list, services, products, events, or programs offered or organised by us, you shall be deemed to agree and consent to all terms and conditions in this Privacy Policy. If you have any questions regarding this Privacy Policy, please contact our Data Protection Officer (“DPO”) at the contact details provided in Section 12 below.
If you do not accept or agree to any of the provisions in this Privacy Policy, you should refrain from entering the website or accessing or using any of the services of the website.
1. Collection of Personal Data
1.1 When you interact with us or use any service or product we provide or participate in any program that we organise, manage or offer, we may collect the following information:
- your personal data, including but not limited to your name, email address, mobile number and address;
- information to process your enquiry, such as your company name, company background, company description and company website;
- publicly available blockchain data and any other publicly accessible sources;
- your public wallet address and blockchain identifiers of the tokens used to interact with our services or products or programs; and
- information about your use of our websites and services, products and programs, including cookies, IP addresses, browser type, your mobile operating system, statistics on page views and traffic to our website and other diagnostic data.
1.2 Generally, we collect your personal data and other information in the following ways:
- when you submit forms relating to any of our products or services or programs that we organise, manage or offer;
- when you register for or use any of our services or products on websites owned or operated by us;
- when you register for or participate in any programs that we organise, manage or offer;
- when you use or purchase our products or services;
- when you request that we contact you;
- when you request to be included in an email or other mailing list;
- when you browse our website. Please see the Cookie Policy in Section 7 for more information; and
- when you submit your personal data to us for any other reason.
You can always refuse to provide your personal data. However, this may prevent us from providing you with our products and services.
2. Use of Personal Data
2.1 Your personal data is used only for the specific purpose(s) for which it was collected. Generally, we collect, use and disclose your personal data for the following purposes:
- providing you with the products or services that were requested;
- evaluating your application or suitability for the products or services that were requested;
- evaluating your application for participation in the programs that you applied for;
- ensuring proper administration of our business which includes keeping proper records, responding to inquiries or requests, resolving complaints and managing our business relationships and opportunities;
- providing user support;
- improving our products or services or programs and the website, including analysing and tracking data to determine the effectiveness of our content and to understand the activity of users;
- providing ongoing information about products, services and programs of the Company which may be of interest to you;
- protecting and enforcing our contractual and legal rights and obligations;
- investigating, addressing or defending against fraud, abuse or suspicious activity linked to or associated with you;
- communicating changes to our policies and terms and conditions;
- to establish, exercise or defend legal claims in suspected or actual legal proceedings in any jurisdiction;
- facilitating transactions relating to the transfer or potential transfer of our business, rights, assets, duties or liabilities (which may include any merger, acquisition or asset sale);
- complying with any applicable rules, laws and regulations, codes of practice or guidelines or to assist in law enforcement and investigations by the relevant authorities;
- any other purposes for which you have provided the information;
- transmitting to third parties including our third party service providers and agents, and relevant governmental and/or regulatory authorities, whether in Singapore or abroad, for the aforementioned purposes; and
- any other incidental business purposes related to or in connection with the above.
2.2 You may unsubscribe from receiving marketing materials or mailing lists at any time by clicking on the “unsubscribe” link in the email you receive or updating your preferences to indicate through which modes of communication and what kind of marketing communications you wish to receive.
2.3 For us to provide information about products, services, programs and other matters which may be of interest to you, we may analyse and rely on your overall interaction with us (such as, but not limited to, your newsletter clicks / opening results, your web surfing activities, the newsletter types or mailing lists you are subscribed to and your interactions with us).
3. Disclosure of Personal Data
3.1 We may disclose your personal data for the above stated purposes to the following third parties:
- related corporations, parent company, subsidiaries and affiliates of the Company;
- anyone who we collaborate or partner with to provide the services or products that you have requested, such as sponsors and organisers of programs that are organised, managed and/or offered by us;
- third party service providers who provide services to us, such as market research and/or technology service providers;
- our professional advisors, such as lawyers and auditors;
- anyone to whom we transfer or may transfer our business, rights, assets, duties or liabilities, such as prospective or actual buyers or sellers in the event of a merger, acquisition or other reorganisation or sale or disposition of all or any portion of our business and/or assets;
- relevant government regulators or law enforcement agencies to comply with laws, rules or regulations imposed on us;
- banks, credit card companies and their respective service providers; and
- any other party to whom you authorise us to disclose your personal data.
4. Transfer of Personal Data outside Singapore
The Company may transfer your personal data to countries outside of Singapore for the purposes stated in this Privacy Policy. When we do so, we have in place adequate safeguards in compliance with the requirements under the applicable laws. This includes ensuring that the recipient is bound by legally enforceable obligations to provide the transferred personal data a comparable standard of protection as that under the Personal Data Protection Act 2012 of Singapore.
5. Retention of Personal Data
The Company will retain your personal data for as long as necessary to carry out the purposes for which it was collected, or as required or permitted by applicable laws. We will cease to retain your personal data, or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purpose for which the personal data was collected, and is no longer necessary for legal or business purposes.
6. Protection of Personal Data
We apply security measures such as encryption technology and firewalls in order to prevent the unauthorised use, disclosure, copying, modification or hacking of personal data in our possession or under our control. However, neither the computer security system nor the Internet is entirely secure. As a result, we do not assume responsibility for any information you submit to or receive from us or for any unauthorised access, collection, disclosure or use of that information, and we cannot and do not guarantee the security of any information transmitted by you to us or vice versa. You agree not to hold us responsible for any loss or damage incurred as a result of any unauthorised access, collection, use, disclosure, copying, modification, interception, destruction, or similar risks, of the information you submit to or receive from us through the Internet. In the event of a data breach, we will notify you as soon as practicable as required by applicable laws.
7. Cookies
7.1 We use “cookies” to enhance user experience. Cookies are files that a website or its service provider transfers to your mobile device or computer’s hard drive which enable the website’s or service provider’s systems to recognise your device or browser and capture and remember certain information. We use cookies to track information such as the number of page views, the number of users, frequency of use, duration of use and common entry and exit points into the website.
7.2 If you do not agree to our use of cookies, you may disable cookies by configuring your browser or device settings. However, this may restrict your use of certain parts of the website.
8. Third-party Sites
You may find links on the website which direct you to sites and services of a third party that may require you to share your personal data. You acknowledge that we do not control how these third-party sites collect, use and disclose your personal data and you further acknowledge that these third-party sites fall outside the scope of this Privacy Policy and are governed by their own respective privacy policies. We are not responsible for the activity or content of any third-party site. You are advised to read the privacy policies of the respective third-party sites you visit.
9. Access and Correction Rights
9.1 It is essential that the information you (or your authorised representative) provide us with is true, accurate, current and complete. We rely on you (or your authorised representative) to ensure that your personal data is accurate. You may notify us of any changes to your personal data held by us by sending an email to our DPO at the contact details provided under Section 12 below. You may also send an email to our DPO to request a copy of the following information:
- your personal data held by us;
- how we use or disclose your personal data; and
- the parties to whom such personal data have been disclosed.
9.2 You may be charged with a reasonable administrative fee for our processing of access requests, but not for processing a correction.
10. Withdrawing Consent
10.1 You may withdraw your consent provided for the collection, use and disclosure of your personal data for any of the above stated purposes (where applicable), including receiving marketing materials, at any time by sending an email to our DPO at the contact details provided in Section 12 below. We will respond to your request as soon as reasonably possible. Please note that for certain purposes, your withdrawal of consent may prevent us from continuing to provide you with our products and/or services or your continued participation in any program that is organised, managed and/or offered by us. Kindly also note that withdrawing your consent for any purposes stated above does not affect our right to collect, use or disclose personal data where consent is not required for such collection, usage or disclosure under applicable laws.
10.2 We may ask you to provide proof of identity before we can respond to your request. In some situations, we may reject your request for access or correction where permitted under the law (for example, if an access request is frivolous or vexatious). If your request has been rejected by the Company, we will notify you of this as soon as practicable.
11. Changes to our Privacy Policy
We reserve the right to make changes and updates to this Privacy Policy without giving you prior notice. You are responsible for keeping track of the changes made to the Privacy Policy. Your continued use of the website or our services or products or continued participation in any program that we organise, manage or offer shall constitute your agreement to be bound by any such changes to this Privacy Policy. If we make any changes, the updated Privacy Policy will be posted on the website with a revised effective date.
12. Data Protection Officer - Contact Information
If you have any questions relating to your personal data or our Privacy Policy, or if you wish to make any request, please contact our DPO at [email protected] indicating:
- your full name and contact information;
- a brief description of your query; and
- the nature of your query in the subject header (for example, Correction of Personal Data Request, or Personal Data Access Request).