Last updated: August 30, 2018
"Data Protection Legislation" means the Personal Data Protection Act 2012 (No. 26 of 2012) of Singapore and any other applicable data protection laws in the relevant jurisdictions.
"Personal Data" means data, whether true or not, about an individual who can be identified from that data, or from that data and other information to which the organisation has or is likely to have access.
"Services" means our apps, platform, services, events and Websites.
"we", "us" and "our" refer to Property Access Asset Pte. Ltd. (Company Registration No. 201731288W), a company incorporated in Singapore with its registered address at 5 Cuscaden Walk Level 3 Singapore 249696, or its group companies, as appropriate.
"Websites" means https://cryptorealtyproject.io and other websites operated or provided by us from time to time.
3.1 Examples of Personal Data which we may collect include an individual's name, address, email address, phone number, gender, birth date, online identifier (such as username), device unique identity, operating system or version, hardware information, date and time spent on the Services and financial information (such as credit card numbers and bank account information).
3.2 3.2 We collect Personal Data about you in a number of different ways. For example:
(a) to improve and maintain any of the Websites or Services, we may gather anonymous analytics and statistical information from you, which include but are not limited to the number of daily users, operating system version, device make and model and coarse location;
(b) for system administration and to improve the Websites and our apps, we may require information such as IP address, operating system and browser type;
(c) to understand your browsing actions and patterns, we may collect statistical data about our users’ browsing actions and patterns without identifying any individual;
(d) we may ask you for information when you report a problem with any Website or our apps;
(e) we may send you marketing and promotional materials on our latest Services or those of carefully selected third parties, so long as you consent to it;
(f) if you contact us, we may keep a record of that correspondence; and
(g) if you complete any survey, we may store and use that data for research purposes, which may include details of visits to our website such as traffic data and location.
4.1 We generally do not collect your Personal Data unless:
(a) it is provided to us voluntarily by you or via a third party who has been duly authorised by you (your "authorised representative") to disclose your Personal Data to us after (i) you or your authorised representative has been notified of the purposes for which the data is collected, and (ii) you or your authorised representative have provided written consent to the collection and usage of your Personal Data for those purposes; or
(b) the collection and use of Personal Data without consent is permitted or required under the Data Protection Legislation.
(a) when you voluntarily provide your Personal Data to us;
(b) when you are aware of the purpose for which you provide your Personal Data to us;
(c) it is reasonable for you to have provided your Personal Data to us in the circumstances; and
(d) in any other circumstances where consent is deemed under the Data Protection Legislation.
5.1 We generally rely on Personal Data provided by you or your authorised representative.
5.2 You represent and warrant that the Personal Data and information which you provide or otherwise disclose to us are accurate and complete.
6.1 The purposes for the collection, use, disclosure or otherwise processing of Personal Data (as the case may) depend on the nature of the Services which you use or subscribe to.
6.2 We may collect and use your Personal Data for one or more of the following purposes:
(a) performing obligations in the course of or in connection with our provision of the Services requested by you;
(b) verifying your identity;
(c) restricting attempts to use the Services from a restricted territory and attempts to use the Services in breach of the applicable terms of service;
(d) facilitating certain events that we organise;
(e) managing your subscription for the relevant Services, including creating and managing your accounts, providing your with the relevant Services and developing, improving and maintaining such Services;
(f) responding to, handling, and processing queries, requests, applications, complaints and feedback from you;
(g) managing your relationship with us;
(h) processing payment or credit transactions;
(i) conducting investigations or internal audits or taking action, including in relation to any violation of terms and conditions for the Services;
(j) complying with any applicable laws, regulations, codes of practice, guidelines or rules or to assist in law enforcement and investigations conducted by any governmental or regulatory authority;
(k) any other purposes for which you have provided the information;
(l) transmitting to any third parties (including, for example, our third party service providers and agents and relevant governmental and regulatory authorities, whether in Singapore, Japan or elsewhere) for the aforementioned purposes; and
(m) any other purposes which are necessary, ancillary or consequential to the above.
6.3 We may disclose your Personal Data:
(a) where such disclosure is required for performing obligations in the course of or in connection with our provision of the Services requested by you; or
(b) to any third party service providers, agents and other organisations we have engaged to perform any of the functions listed in Section 6.2 above for us.
6.4 The purposes listed above may continue to apply even in situations where your relationship with us (for example, pursuant to a contract) has been terminated or altered in any way, for a reasonable period thereafter (including, where applicable, a period to enable us to enforce our rights under any contract with you).
7.2 The consent that you provide for the collection, use, disclose and processing of your Personal Data shall remain valid until it is withdrawn by you in writing. If you wish to withdraw your consent, please note the following:
(a) You may withdraw your consent at any time by submitting your request to our Data Protection Officer at the email address set out at Section 14 below.
(b) Upon receipt of your request to withdraw your consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) to process your request and for us to notify you of the consequences of acceding to the same, including any legal consequences which may affect your rights and liabilities to us. In general, we shall seek to process your request within 30 calendar days of receiving the same.
(c) The withdrawal of your consent may however result in certain consequences. Depending on the nature and scope of your request, in certain cases, we may not be able to provide you with certain Services.
(d) Please note that withdrawal of your consent does not affect our right to continue to collect, use, disclose and process Personal Data where such collection, use, disclosure and processing without consent is permitted or required under the applicable laws.
8.1 If you wish to make:
(a) an access request for a copy of your Personal Data which we hold or information about the ways in which we use or disclose your Personal Data; or
(b) a correction request to correct or update any of your Personal Data which we hold,
please contact our Data Protection Officer at the email address set out in Section 14 below.
8.2 Please give us a reasonable period of time to respond to any request and effect any change. We may ask to verify your identity and for more information about your request. Where we are legally permitted to do so, we may also refuse your request with or without providing you with any reasons for doing so.
8.3 Where you have made an access request pursuant to Section 8.1(a) above, we may charge a reasonable administrative fee to cover the costs of responding to such request. If we decide to do so, we will provide you with a written estimate of such fee before processing such request.
9.1 We shall take reasonable steps to secure and protect your Personal Data and information by implementing measures to secure and protect your Personal Data as required to comply with the Personal Data Legislation, including:
(a) reasonable security arrangements to prevent unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks to Personal Data; and
(b) security precautions safeguarding all electronic storage and transmission of Personal Data.
9.2 While we strive to use commercially acceptable means to protect your Personal Data, please note that no method of transmission over the Internet or method of electronic storage is completely secure and we cannot ensure absolutely the security of any Personal Data or information which you transmit to us.
10.1 We shall retain Personal Data for as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted by the applicable laws.
10.2 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.
11.1 We shall only transfer Personal Data outside Singapore in accordance with the Data Protection Legislation.
Our Services may, from time to time, contain links to external sites or resources which are operated by third parties. We have no control over the content and privacy practices of such sites or resources. You should review the privacy policies of these sites and resources operated by third parties and understand how your information may be used by those third parties.