Privacy

UPDATED AS AT JAN 12, 2019

Your privacy is important to us. The purpose of this privacy policy (the "Privacy Policy") is to inform you of how Hashcom Pte. Ltd. manages personal data in accordance with the Personal Data Protection Act 2012 of Singapore (the "Act") and EU General Data Protection Regulation (the "GDPR"), as may be modified, supplemented or amended from time to time.

Please take a moment to read this Privacy Policy so that you know and understand the purposes for which we collect, use and disclose your Personal Data (as defined below).

By interacting with us, submitting information to us or signing up for any services offered by us, you agree and consent to Hashcom Pte. Ltd. and its affiliates, (collectively referred to herein as "Hashcom", "us", "we" or "our"), as well as our respective representatives collecting, using, disclosing and sharing amongst themselves your Personal Data, and disclosing such Personal Data to authorised service providers of Hashcom in the manner contemplated and set forth in this Privacy Policy.

This Privacy Policy supplements but does not supersede nor replace any other consents you may have previously provided to Hashcom (where applicable) nor does it affect any rights which Hashcom may have at law in connection with the collection, use or disclosure of your Personal Data.

Hashcom may from time to time update this Privacy Policy to ensure that this Privacy Policy is consistent with our future developments, industry trends and/or any changes in legal or regulatory requirements.

Subject to your rights at law, you agree to be bound by the prevailing terms of the Privacy Policy as updated from time to time on our website(s). The onus is on you to check regularly for updated information on the handling of your Personal Data. For avoidance of doubt, Hashcom holds no responsibility in informing you of the changes or updates to our Privacy Policy as may be updated from time to time. See Section 12 for details.

For avoidance of doubt, this Privacy Policy forms a part of the Website Terms and Conditions ("Website Terms and Conditions"). In the event of any conflict, inconsistency or conflict between this Privacy Policy and the Website Conditions, the Privacy Policy shall prevail.

All defined terms contained in the Website Conditions shall apply to this Privacy Policy unless otherwise specifically stated.

  1. Your Personal Data
    1. In this Privacy Policy, "Personal Data" refers to any data or information about you from which you can be identified either (a) from that data; or (b) from that data and other information to which we have or are likely to have access. Examples of such Personal Data which you may provide to us include:
      1. Your name, passport or other identification number, telephone number(s), mailing address, email address and any other information relating to you (such as an online identifier or to one or more factors specific to your physical, physiological, genetic, mental, economic, cultural or social identity) which you have provided us in any forms you may have submitted to us, or in other forms of interaction with you;
      2. Information about your use of our website and services, including cookies, IP address, subscription account details and membership details, but only to the extent that we may identify you from such information; and
      3. Your corporate information, including financial information and profit and loss statements, corporate data or such other corporation information which you have provided us in any forms you may have submitted to us, through the subscription of Services, usage of your Account and/or in your capacity as a Member or otherwise, or in other forms of interaction with you.
  2. Collection of Personal Data
    1. We collect your Personal Data in the following ways:
      1. When you submit forms and or any subscription document relating to any of our Services;
      2. When you register for or use any of our Services on websites owned or operated by us or when you register as a Member of websites owned and/or operated by us, or use Services on such websites;
      3. When you use some or any of our Services;
      4. When you establish any online accounts, including but not limited to the Account, with us;
      5. When you request that we contact you;
      6. When you interact with any of our officers and/or employees, for example, via telephone calls, letters, emails or face-to-face interactions;
      7. When you respond to our request for additional Personal Data;
      8. When we receive references from business partners and third parties, for example, where you have been referred by them;
      9. When you ask to be included in an email or other mailing list; and/or
      10. When you submit your Personal Data to us for any other reason.
    2. When you browse our website, you generally do so anonymously but please see Section 5 below on cookies policy.
    3. If you provide us with any Personal Data relating to a third party by submitting such information to us, you represent to us that you have obtained the consent of the third party to you providing us with their Personal Data for the respective purposes.
  3. Purposes for the Collection, Use and Disclosure of Your Personal Data
    1. We generally use your Personal Data for the following purposes:
      1. To provide you with Services;
      2. To enable us to develop, deliver and improve our Services;
      3. To administer our websites;
      4. To improve your experience with us;
      5. To send important notices, such as communications about our services, changes to our terms, conditions and policies;
      6. To respond to your queries;
      7. For internal purposes such as auditing, data analysis and research; and
      8. To improve our products, services and customer communications.
    2. We also use and disclose your Personal Data for the following purposes:
      1. Responding to your queries and requests and responding to complaints;
      2. Managing the infrastructure and business operations of Hashcom and complying with internal policies and procedures;
      3. Matching any Personal Data held which relates to you for any of the purposes listed herein;
      4. Verifying your identity;
      5. Preventing, detecting and investigating crime, including fraud and money-laundering, and analyzing and managing other commercial risks;
      6. Protecting and enforcing our contractual and legal rights and obligations;
      7. Conducting audits, reviews and analysis of our internal processes, action planning and managing commercial risks;
      8. Compliance with any applicable rules, laws and regulations, codes of practice or guidelines or to assist in law enforcement and investigations by relevant authorities; and/or
      9. Any other purpose related to the above.
    3. Hashcom may collect, use and disclose your Personal Data for the following purposes, depending on the nature of our relationship with you:
      1. If you have an Account with us:
        1. To maintain your Account with us;
        2. To verify your personal particulars and payment in connection with the Services pursuant to your Account;
        3. To provide you with the Services which you have signed up for;
        4. Communicating with you to inform you of changes and development to our policies, terms and conditions and other administrative information, including for the purposes of servicing you in relation to the Services offered to you;
        5. Resolving complaints and handling requests and enquiries; and/or
        6. The processing of your Personal Data in relation to any of the purposes stated above.
    4. In addition, where permitted under the Act and under the GDPR, Hashcom may also:
      1. Make certain Non-Personally Identifiable Information and Aggregate Information (as defined in Section 5 below) available to third parties for various purposes, including (i) compliance with various reporting obligations; and (ii) for business, research or marketing purposes; and
      2. Use such Non-Personally Identifiable Information and Aggregate Information for market analysis. We may provide such Non-Personally Identifiable Information and Aggregate Information (at all times in aggregate form, with identifying information removed) to third parties. When such Non-Personally Identifiable Information and Aggregate Information is provided, we extract it from the Accounts and/or Personal Data and strip it of any data that could be used to identify an individual and/or Member before it is used. Any third party that receives aggregated Non-Personally Identifiable Information and Aggregate Information must agree not to attempt to reverse engineer and/or re-identify origination of such information and/or Personal Data.

      For the purposes of the foregoing, "Non-Personally Identifiable Information" refers to automatically-collected, aggregated, or otherwise non-personally-identifiable information.

    5. In relation to particular services or in your interactions with us, we may also have specifically notified you of other purposes for which we collect, use or disclose your Personal Data. If so, then we will collect, use and disclose your Personal Data for these additional purposes as well, unless we have specifically notified you otherwise.
  4. Disclosure of Personal Data
    1. We will take reasonable steps to protect your Personal Data against unauthorised disclosure. Subject to the provisions of any applicable law, this Personal Data may be disclosed, for the purposes listed above (where applicable), to the following third parties, whether they are located overseas or in Singapore:
      1. Our affiliates;
      2. Our agents, contractors or third party service providers who provide operational services to us;
      3. Any business partner, investor, assignee or transferee (actual or prospective) to facilitate business asset transactions (which may extend to any merger, acquisition or asset sale);
      4. Anyone to whom we transfer or may transfer our rights and duties;
      5. Banks and credit companies;
      6. Our professional advisors;
      7. Relevant government regulators or authority or law enforcement agency to comply with any laws or rules and regulations imposed by any governmental authority; and
      8. Any other party whom you authorise us to disclose your personal data.
  5. Cookies Policy
    1. When you interact with us on our websites, we may collect or analyse anonymised information from which individuals cannot be identified ("Aggregate Information"), such as number of users and their frequency of use, the number of page views (or page impressions) that occur on the website and common entry and exit points into website.
    2. We use "cookies", where a small data file is sent to your browser to store and track Aggregate Information about you when you enter our websites. The cookie is used to track information such as the number of users and their frequency of use, profiles of users and their preferred sites.
    3. Should you wish to disable the cookies associated with these technologies, you may do so by changing the setting on your browser. However, you may not be able to enter certain part(s) of our website
  6. Transfer of Personal Data to other Countries
    1. We may transfer your Personal Data between our affiliates, some of which may be located outside of Singapore. We are committed to ensuring that the recipient organisation will be bound by legally enforceable obligations in its jurisdiction and in any event to provide the transferred personal data the same level of protection as it would be accorded in Singapore.
    2. In compliance with the GDPR, we will never send your Personal Data outside of Europe and European Economic Area if such Personal Data is stored within Europe and European Economic Area, with the aim to provide adequate protection of Personal Data in connection with storage and processing of data, fulfilling your requests, and operating the Service. For avoidance of doubt, the above Section 6.1 shall not apply to the circumstances contemplated herein.
  7. Withdrawal, Access and Correction of your Personal Data
    1. We respect your privacy rights and will provide you with reasonable access to your Personal Data.
    2. Should you wish to withdraw consent to use of your Personal Data or obtain access to or make corrections to your Personal Data records, please log in to the relevant account through which the Personal Data was provided, if any, failing which please contact the relevant Personal Data Protection Officer, contact details of which are found in Section 8 below. At your request, we will have any reference to your Personal Data deleted or blocked in our database, subject at all times to Section 7.4 below.
    3. Please note that if your Personal Data has been provided to us by a third party, you should contact such party directly to make any queries, feedback, and access and correction requests to us on your behalf.
    4. Please note that if you withdraw your consent to any or all use of your Personal Data, depending on the nature of your request, we may not be in a position to continue to provide our services to you or administer any contractual relationship in place, and this may also result in the termination of any agreements with us and your being in breach of your contractual obligations or undertakings, and our legal rights and remedies in such event are expressly reserved.
  8. Personal Data Protection Officer
    1. For the purposes of this Privacy Policy, please contact our personal data protection officer at the following:

      Data Protection Officer
      Hashcom Pte. Ltd.
      33A Chander Road, Singapore 219539
      legal@the-hash.com

  9. Third Party Services
    1. Our Service may, from time to time and where applicable, contain features or links to web sites and services provided by third parties. Any information you provide on thirdparty sites or services is provided directly to the operators of such services and is subject to those operators’ policies, if any, governing privacy and security, even if accessed through the Service. We are not responsible for the content or privacy and security practices and policies of third-party sites or services to which links or access are provided through the Service. We encourage you to learn about third parties’ privacy and security policies before providing them with information.
  10. Opt-Out and Managing Your Preferences
    1. You can choose whether or not you would like to receive email from us. You may change your preferences at any time clicking the "unsubscribe" link at the bottom of each email you receive from us. You may also choose not to receive mail or phone communications by emailing us at the email prescribed in Section 8 above and specifying that this is your preference.
  11. Protection and Security
    1. We follow generally accepted industry standards to protect the information and Personal Data submitted to us, both during transmission and once we receive it. We maintain appropriate administrative, technical and physical safeguards to protect Personal Data against accidental or unlawful destruction, accidental loss, unauthorized alteration, unauthorized disclosure or access, misuse, and any other unlawful form of processing of the Personal Data in our possession. This includes, for example, firewalls, password protection and other access and authentication controls.
    2. However, no method of transmission is 100% secure. We cannot ensure or warrant the security of any information including Personal Data you transmit to us and you do so at your own risk. We also cannot guarantee that such information including Personal Data may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. If you believe your Personal Data has been compromised, please contact our Personal Data Protection Officer at Section 8 above.
    3. If we have knowledge of a security systems breach, we will inform you and the authorities of the occurrence of the breach in accordance with applicable law, the Act and the GDPR.
  12. Changes and Updates
    1. Please visit this page periodically to stay aware of any changes to our Privacy Policy, which we may update from time to time. Your continued use of the Service after the revised Policy has become effective (as per the effective date appearing at the top of this Privacy Policy) indicates that you have read, understood and agreed to the current version of the Policy.
  13. Governing Law
    1. This Privacy Policy shall be governed in all respects by the laws of Singapore.