Privacy Policy

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This Privacy Policy (“Policy") is a legal agreement between you (referred to herein as "the User" or "your") and TomoChain Pte. Ltd. (UEN: 201716924E)
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1. Introduction
1.1. This Privacy Policy (“Policy") is a legal agreement between you (referred to herein as "the User" or "your") and TomoChain Lab Pte. Ltd. (UEN: 201716924E), a company incorporated under the laws of Singapore, and its subsidiaries, affiliates and related corporations who own or operate the Services (referred to herein as “the Company”, “we”, “us” or “our”)
1.2. Unless otherwise specified, all terms used in this Policy shall have the same meanings as provided in Clause 2. Definition and Interpretation of our Terms of Use.
1.3. By using any of the Services, you understand and agree that the Site is only an interface for the public blockchain TomoChain and TomoDEX. TomoDEX is a decentralized exchange powered by the TomoX protocol. TomoDEX is operated via TomoChain Lab Pte., Ltd yet secured by the trustless TomoChain Blockchain, where performance and decisions are not made by a single entity.
1.4. This Policy (together with our Terms of Use) explains and sets out the basis for why and when we collect Personal Information about the people who use our Services, how we use it, the conditions under which we may disclose it to others and the measures we take to keep it secure.
1.5. By using our Services, you are accepting and consenting to the practices described in this Policy. Please note that this includes consenting to the collection and processing of any Personal Information you provide, as described below. We may amend this Policy from time to time so please check it occasionally to ensure that you agree with any changes. Your continued use of our Services will constitute your acceptance of, and agreement to, any changes.
1.6. The Company values privacy and we make a concerted effort to minimize and, to the extent possible, eliminate the exposure of personal data during the use of our interface. 
1.7. We do not collect any special categories of iersonal information about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data).
1.8. We do not collect, hold, or store any information relating to your wallet, including private keys, keystore files, passwords, mnemonic phrases. TomoDEX minimizes Personal Information collected from you, as TomoChain and TomoDEX are anonymous.
1.9. To the extent we collect any Personal Information, this Policy describes how the Company collects, uses, and shares Personal Information of people who use our Services.
1.10. This Policy applies to anyone who accesses the Services. Please read the Policy carefully to understand our practices regarding your information and how we will treat it. By visiting the Site, and/or using the Services, you acknowledge that the collection, use, and sharing of your information will take place as described in this Policy.
1.11. So that we are clear about the terminology we are using, when we use the phrase “Personal Information” in this Policy, we mean information about an individual that (either by itself or when combined with information from other available sources) allows that individual to be identified, including but not limited, the individual’s name, telephone number, or e-mail address.

2. The Blockchain
Due to the inherent transparency of many blockchains, including the TomoChain Blockchain , transactions that individuals broadcast via TomoChain may be publicly accessible. This includes, but is not limited to, your public sending address, the public address of the receiver, the amount sent or received, and any other data a user has chosen to include in a given transaction. Information stored on a blockchain may be public, immutable, and difficult or even impossible to remove or delete. Transactions and addresses may reveal information about the user’s identity and information can potentially be correlated now or in the future by any party who chooses to do so, including law enforcement. Users are encouraged to review how privacy and transparency on the blockchain works.

3. How We Collect Information
We obtain information about you when you use our website, when you contact us via email or a web form or if you register to receive one of our regular newsletters. We may collect and process the following types of information about you:
Information you provide us
You may provide us with Personal Information by creating a TomoChain wallet; trading, financing on TomoDEX; filling in forms on our Site or by corresponding with us by e-mail or live-chat. The Personal Information you provide may include your name, email, address, phone number, language preference and information regarding the pages you access. By providing us with this information, you expressly consent to our use of your Personal Information in accordance with this Policy.
Information we collect about you
When you use our Services we may automatically collect information about your IP address, information about your visit, browser plug-in types and versions, your browsing activity, timezone setting, how you use our Services, and information about your visit, including the dates and times you use the Site length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page.:
Information we receive from other sources
We may receive information about you if you use any other Services we, or our partners, operate. We also work with third parties (including, contractors, project partners, service providers, analytics providers) and may receive information about you from them. This may be combined with other information you provide to use to collect information about you as described below. We use this information to enhance your experience with our Services.

4. Use of Information
4.1. We use the information that we have about you to provide support and certain services to you.
4.2. We may use the Personal Information we collect from and about you to:
provide you with information or services that you request from us, including to respond to your comments, questions, and/or provide customer service; 
provide information to you about developments and new products, features, including changes and enhancements to the Site;
monitor and analyze usage and trends and personalize and improve the Services and your experience using the Services;
conduct surveys and get feedback from you
develop, enhance, and market products and services, and provide products and services to you;
meet the Company’s legal and regulatory requirements, and
for any other purpose with your consent.
4.3. We use IP addresses to analyze trends, administer the Site, track user movements, and gather broad demographic information for aggregate use. For systems administration and detecting usage patterns and troubleshooting purposes, the Site’s web servers also automatically log standard access information including browser type, access times/open mail, URL requested, and referral URL. This information is not shared with third parties and is used only within the Company on a need-to-know basis. We reserve the right to block access for any user accessing the Site via a proxy service intending to conceal originating identity. 
4.4. We review our retention periods for Personal Information on a regular basis. We will hold your Personal Information on our systems for as long as is necessary for the relevant activity.

5. Sharing of Personal Information
5.1. We will not disclose your Personal Information other than as described below, and we do not and will not sell your Personal Information to anyone.
5.2. You agree that we have the right to share the Personal Information we collect from and about you:
to fulfill the purpose for which you provided it;
with your consent;
for legal, protection, and safety purposes;
to comply with any court order, law, or legal process, including to respond to any government or regulatory request;
to protect the rights of the Company, our agents, customers, and others, including by enforcing our agreements, policies, and terms of service; 
with third parties, if the Company or substantially all our assets are acquired by a third party, in which case Personal Information held by us about the users will be one of the transferred assets and,
with those who need it to do work for us (our service providers, as defined below).
Service providers: We may contract with third parties to perform functions related to the Services. In general, service providers will have access to your Personal Information only to the extent needed to perform their business functions but may not use or share that Personal Information for purposes outside the scope of their functions related to the Services.
5.3. We reserve the right to share current and historical bids, asks, and market prices; opening and closing range prices; high–low prices; trade prices; estimated and actual trade volumes; settlement prices; and other aggregate data and information related to the digital assets traded and financed on the Site.

6. Legal Basis for Processing 
The following legal bases apply to the ways in which we use and share your Personal Information:
when it is necessary for us to perform pursuant to our contract with you or in your interests;
in our legitimate interests in ensuring our business is conducted legitimately and to a high standard. Legitimate interests mean the interests of our organization to conduct and manage our business to enable us to better serve you and provide you with a secure experience on the Site;
generally, we do not rely on consent as a legal basis for processing your Personal Information
we will retain the information you provide in order to process your request, provide support, and/or carry out and fulfill our Promotions. 
7. Other Sites & Links to Other Sites
7.1. The Services contain links to other third-party websites or applications. Once you click on such a link and leave the Site or are redirected to a third-party website or application, you are no longer governed by this Policy. Any information you provide on those sites is subject to that third party’s privacy policy and we are not responsible for the privacy and security practices and policies of those third-party sites or applications.
7.2. This Policy and the use of your Personal Information only applies to the information you provide. You are cautioned that if you disclose Personal Information or personally sensitive data through the use of the Internet, such as through chat rooms, communities, bulletin boards, or other public online forums, this information may be collected and used by other persons or companies over which the Company has no control. It is your responsibility to review the privacy statements, policies, terms, and conditions of any person or company to whom you choose to link or with whom you choose to contract. We are not responsible for the privacy statements, policies, terms, conditions, or other content of any Site not owned or managed by us.

8. Our Commitment Towards Children’s Privacy
We do not direct the Services to, nor do we knowingly collect any Personal Information from children under 18. Children under 18 are not eligible to use the Services. If we learn that someone using our Services is under 18 years of age, we will take steps to remove any Personal Information from our database and to prevent them from utilizing the Services.

9. Security of Your Personal Information & Rights
9.1. We are committed to protecting the security of Personal Information. We have taken certain physical, administrative, and technical steps to help safeguard the information we collect from and about you. While we take steps to help ensure the integrity and security of our network and systems, we cannot guarantee the security of your data transmitted to us over the email or through the Site; any transmission is at your own risk. Once we have received your data, we will use strict procedures and security features to try to prevent unauthorized access
9.2. Personal Information and other data may be exported outside of the jurisdiction in which you reside. Your Personal Information may be processed and stored in a foreign country or countries. Under those circumstances, the governments, courts, law enforcement, or regulatory agencies of that country or those countries may be able to obtain access to your Personal Information through foreign laws. You need to be aware that the privacy standards of those countries may be lower than those of the jurisdiction in which you reside.

10. Contact Us
Any questions regarding this policy and our privacy practices should be sent by email to [email protected] or by writing TomoChain Lab Pte., Ltd at 10 Anson Road #22-15 International Plaza, Singapore 079903.

11. Changes to Privacy Policy
11.1. The Company shall be permitted to make amendments to the Policy from time to time. You will be deemed to have accepted such amended Policy by indicating your acceptance on the Site. Any further actions which you make will be subject to the Policy in effect at that time. If you object to any changes, you may stop using the Services. Your continued use of the Services after we publish or otherwise provide notice about our changes to the Policy means that you are consenting to the updated Policy.
11.2.We keep this Policy under regular review. This Policy was last updated in May 15th, 2020
User Agreement for TomoDEX Lending Service
Last modified 1yr ago
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Contents
1. Introduction
2. The Blockchain
3. How We Collect Information
4. Use of Information
5. Sharing of Personal Information
6. Legal Basis for Processing
7. Other Sites & Links to Other Sites
8. Our Commitment Towards Children’s Privacy
9. Security of Your Personal Information & Rights
10. Contact Us
11. Changes to Privacy Policy