©2017-2019 by Mithqal, a Singapore registered company (UEN: 201808634M)

- the gold standard for digital assets governance

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Privacy and Data Processing Policy

In force from 05. July 2019

Mithqal Digital, as a responsible member of the blockchain and crypto community takes customer’s privacy seriously. We are principled and will do everything to earn your trust in us, Mithqal is committed to complying with the Personal Data Protection Act 2012 of Singapore. We will only collect, record, hold, store, disclose, transfer and use your personal information based on your consent and in a manner outlined below.

We only collect information where it is necessary for us to do so, and we will only collect information if it is relevant to our dealings with you. We will only keep your information for as long as we are either required to by law or as is relevant for the purposes for which it was collected.

We will never sell your personal information to third parties. 

You can visit our website and browse publicly displayed information without having to provide personal details. During your visit to our website you remain anonymous and at no time can we identify you, unless you are a member and log on with your username and password, or sign up for newsletters or request an answer through a chat session.

If you have any comments, suggestions or complaints, or want us to delete your personal data please contact us through our contact form on the website.

Contacting Mithqal

If you wish to withdraw your consent to our use of your personal information, request access and/or correction of your personal information, have any queries, comments or concerns, or require any help on technical or cookie-related matters, please feel free to contact us through our website contact form or chat.

Collection of Personal Information

When you become a member, use our verification services, or otherwise provide us with your personal information through our website, the personal information we collect may include your:

  • Name

  • Email Address

  • Mobile Number

  • Date of Birth

  • ID number and expiry date

  • Residential Address

  • Blockchain transactional address details

  • And any information that you choose to provide to us when filling in one of our forms on the website.

You must only submit to us information which is accurate and not misleading, and you must keep it up-to-date when reasonable for further interactions with Mithqal. We reserve the right to request for documentation to verify the information provided by you.

We will only be able to collect your personal information if you voluntarily submit the information to us. If you choose not to submit your personal information to us or subsequently withdraw your consent to our use of your personal information, we may not be able to provide you with our services. You may access and update your personal information submitted to us at any time as described below.

If you provide personal information of any third party to us, you confirm that you have obtained all necessary consents to do so, and that we may collect, use and disclose such personal data for the purposes set out below, in accordance with the PDPA.

Use and Disclosure of Personal Information

The personal information we collect from you will be used, or shared with third parties (including related companies, third party service providers), for some or all of the following purposes:

  • To facilitate your use of Mithqal’s services and/or access to our website;

  • To process identity verification you consent to through our website;

  • To deliver digital cryptographic tokens to you that you gained rights to by contributing to a community token sale - we may pass your personal information on to the third party in order to make delivery;

  • To update you on the completion of services or delivery of tokens, and for customer support purposes;

  • To compare information, and verify with third parties in order to ensure that the information is accurate;

  • To detect and prevent fraud, money laundering, terrorist financing and other criminal offences;

  • Further, we will use the information you provide to administer your membership (if any) with us; audit the downloading of data from our website; improve the layout and/or content of the pages of our website and customise them for customers; identify visitors on our website; carry out research on our users’ demographics and behaviour;

  • To provide you with information we think you may find useful or which you have requested from us, including information about our or third party services, provided you have indicated that you have not objected to being contacted for these purposes;

  • To send you newsletters, marketing and/or promotional materials about our or partnering products and services from time to time – conditional to providing you the ability to unsubscribe from receiving marketing information at any time by using the unsubscribe function within the electronic marketing material;

  • And in exceptional circumstances and when required by law to disclose personal information - when there are grounds to believe that the disclosure is necessary to prevent a threat to life or health, or for law enforcement purposes, or for fulfillment of legal and regulatory requirements and requests.

If you are an EU resident, we are required to disclose the legal basis for processing your personal data under the GDPR. We process your personal data for these purposes on the following legal basis:

  • to comply with our legal and regulatory obligations;

  • to perform a contract, such as enabling you to pass an identity verification process;

  • and for our legitimate interests in:

    • responding to your queries;

    • providing services and/or information to you;

    • carrying out surveys in order to obtain feedback on our services; and

    • our business purposes as set out in this paragraph.

You can object to processing your personal data based on our legitimate interests at any time by contacting us.

We may share your personal information with third parties and our affiliates for the above-mentioned purposes either within or outside Singapore, specifically, servicing you, managing your account and our relationship with you, marketing and fulfilling any legal or regulatory requirements and requests as deemed necessary by Mithqal. You authorise us to disclose all or any of your personal data to such third parties and collect your personal data from any other sources available to us.

If you are a European Union (“EU”) resident, please note that we transfer personal data to Singapore and process it there. We will comply with the requirements set out in the GDPR pursuant to the transfer of the personal data outside of the European Economic Area (“EEA”), such as putting in placed appropriate safeguards to ensure that your personal data is protected.

We endeavor to ensure that any third parties and our affiliates keep your personal information secure from unauthorised access, collection, use, disclosure, or similar risks and retain your personal information only for as long as they need your personal information to achieve the above-mentioned purposes.

In disclosing or transferring your personal information to third parties and our affiliates located overseas, we take steps to ensure that the receiving jurisdiction has in place a standard of protection accorded to personal information that is comparable to the protection under or up to the standard of the PDPA of Singapore.

Withdrawal of Consent

You can contact us about your objection to our continual use and/or disclosure of your personal information for any of the purposes and in the manner as stated above at any time by contacting us at our contacts below.

Please note that if you request us to stop using and/or disclosing your personal information for the purposes and in the manner as stated above, depending on the nature of your objection, we may not be in a position to continue to provide our products or services to you or perform on any contract we have with you. Our legal rights and remedies are expressly reserved in such event. 

For EU residents, we will endeavour to delete data within 30 days of a request for deletion or contact you if it will take longer.

In certain cases, and as required by law, we may not be able to delete all or part of your personal information. In these cases we will let you know about possible alternatives to address your concerns.

Updating Your Personal Information

If you are a member on our website, you may update your personal information anytime by accessing your account on our website. If you do not have an account with us, you can do so by contacting us at our contacts above.

We take steps to share the updates to your personal information with third parties and our affiliates with whom we have shared your personal information if your personal information is still necessary for the above stated purposes.

Accessing Your Personal Information

If you would like to view the personal information we have on you or inquire about the ways in which your personal information has been or may have been used or disclosed by Mithqal within the past year, please contact us at our contacts above. We reserve the right to charge a reasonable administrative fee for retrieving your personal information records.

If you are a member on our website, you undertake to treat your login details confidentially and not make it available to unauthorised third parties. We cannot assume any liability for misuse of your username, password or other login details. 

Security of Your Personal Information

Mithqal ensures that all information collected will be safely and securely stored. We protect your personal information by:

  • Restricting access to personal information;

  • Maintaining technology products to prevent unauthorised computer access;

  • Securely destroying your personal information when it is no longer needed for any legal or business purpose.

Mithqal uses SSL (secure sockets layer) encryption technology when storing or processing your personal information. If you believe that your privacy has been breached by Mithqal, please contact us at our contacts below.

If you lose control of your login details, you may lose substantial control over your personal information and other information submitted to Mithqal. You could also be subject to legally binding actions taken on your behalf. Therefore, if your login details have been compromised for any reason or if you have grounds to believe that your login details have been compromised, you should immediately contact us and change your password. 

Minors

If you are under 16 years old, you may use our website only with the involvement of a parent or guardian. 

Collection of Computer Data

Mithqal or our partners may use cookies, web beacons, and other similar technologies for storing information to help provide you with a better, faster, safer and personalized experience when you use our services and/or access our website. When you visit our or our partners’ website, servers will automatically record information that your browser sends whenever you visit a website. This data may include:

  • Your computer's IP address

  • Browser type

  • Webpage you were visiting before arriving to our or partners’ website

  • The pages within our website which you visit

  • The time spent on those pages, items and information searched for on our website, access times and dates, and other statistics.

This information is collected for analysis and evaluation in order to help us improve our website and the services we provide, and better understand your preference and interests. You are able to manage and delete cookies through your browser or device settings. For more information on how to do so, visit the help material of your browser or device.

We use Google Analytics that tracks and reports website traffic to monitor and analyse the use of our website. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.

No Spam, Spyware, or Virus

Spam, spyware or virus is not allowed on our website. Please set and maintain your communication preferences so that we send communications to you as you prefer. If you would like to report any suspicious messages, please contact us at our contact form or website chat. 

Changes to the Privacy and Data Processing Policy

We will regularly review this Privacy and Data Processing Policy. We reserve the right to modify and change the Privacy and Data Processing Policy at any time. Any changes to this policy will be published on our website. 

Acknowledgement

You acknowledge and agree that Mithqal has the right to disclose your personal information to any legal, regulatory, governmental, tax, law enforcement or other authorities or the relevant right owners, if Mithqal has reasonable grounds to believe that disclosure of your personal information is necessary for the purpose of meeting any obligations, requirements or arrangements, whether voluntary or mandatory, as a result of cooperating with an order, an investigation and/or a request of any nature by such parties. To the extent permissible by applicable law, you agree not to take any action and/or waive your rights to take any action against Mithqal for the disclosure of your personal information in these circumstances.