PRIVACY POLICY privacy

This Privacy Policy (“Privacy Policy”) is between you or the entity you represent (“Buyer” or “you”) and Spxtrum Pte. Ltd. (UEN: 201806905R) (“Spxtrum” or “we” or “us”), a private limited liability company established in Singapore.

BACKGROUND

Spxtrum may collect, use, disclose, process and manage your personal data through your access to and use of the official website of Spxtrum available at https://www.spxtrum.io (“Website”), the online platform being developed by Spxtrum (“SpectrumProtocol.io Platform”) and the services available on the SpectrumProtocol.io Platform or any similar or successor software platform (“Services”) and are committed to protecting the privacy, confidentiality and security of your personal data by complying with the requirements under applicable laws and regulations and is subject to the Personal Data Protection Act 2012 (the “PDPA”) as may be amended, revised or re-enacted from time to time.

The terms described herein shall apply to all personal data received or collected by us. Your access to and use of the Website, the SpectrumProtocol.io Platform and the Services signifies your acceptance of this Privacy Policy and agreement to be bound by them and any and all other applicable terms referenced herein absolutely.

IF YOU DO NOT ACCEPT ANY PART OF THIS PRIVACY POLICY, PLEASE DISCONTINUE YOUR ACCESS TO AND USE OF THE WEBSITE, THE SpectrumProtocol.io Platform AND THE SERVICES IMMEDIATELY.

1. INTERPRETATION 1

Clause headings do not affect the interpretation of this Privacy Policy.

Unless the context otherwise requires, words in the singular shall include the plural version and in the plural shall include the singular version.

Any words following the terms "including", "include", "in particular", "for example", or any similar expression shall be construed as illustrative and shall not limit the sense of the words, description, definition, phrase, or term preceding those terms.

2. CHANGES TO PRIVACY POLICY 2

We may amend the Privacy Policy from time to time to ensure compliance with any changes in the laws and regulations applicable to us without being obliged to notify you in advance. Spxtrum reserves the right, at any time and without notice, to add to, modify, change or update this privacy policy simply by posting such change, update or modification on the Website and the SpectrumProtocol.io Platform.

It is your responsibility to check this page periodically for changes to these Privacy Policy. By continuing to use the Website, the SpectrumProtocol.io Platform and the Services following such amendments to the Privacy Policy, you agree to be bound by such amendments.

3. COLLECTION OF PERSONAL DATA 3

We may collect your personal data when you create an account with us or otherwise provide us with your personal data to us through your access to and use of the Website, the SpectrumProtocol.io Platform and the Services. Personal data that we may collect includes but is not limited to:

  • Your personal particulars such as your name, date of birth, telephone numbers, home and email address and any other contact information;
  • Your financial information such as your bank account, credit card details, expenses, bank details and any other billing information;
  • blockchain information such as your blockchain address and public keys; and/or
  • any other form of personal data relevant to the Website, the SpectrumProtocol.io Platform and the Services including the username and password of the account created by you.

We may at other times acquire personal data from other sources such as offline records, publicly available information, or from third parties, in order to provide you with the Services.

4. Collection of Computer Data 4

When you access the Website and the SpectrumProtocol.io Platform, we will automatically collect your computer data, which may include browser type, IP address, language, operating system, location of your device, the state or country from which you accessed the Website and the SpectrumProtocol.io Platform, the pages you view, length of time spent on pages, communications with other users through the Website if applicable, the Services you use and the manner in which you use such Services (e.g., the content you access, view, click on, search for, post, follow, share, upload, or tag), the date and time of your visit, the websites you visited immediately before and after visiting the Website and the SpectrumProtocol.io Platform, error logs, and other hardware and software information, as well as other geographic and demographic information.

To the extent that such information is maintained in a manner that identifies your name or contact information, it will be treated as personal data; otherwise, such information will be treated as non-personal data.

We and our authorised service providers may use cookies, web beacons, and other similar technologies for storing information when you access the Website and the SpectrumProtocol.io Platform. Cookies are small text files (typically made up of letters and numbers) placed in the memory of your browser or device when you visit a website or view a message.

Most web browsers automatically accept cookies, but you may set your browser to block cookies (consult the instructions for your particular browser on how to do this). Please note that if you decide to block cookies, this may interfere with your ability to use certain functionalities of the Website, the SpectrumProtocol.io Platform and/or the Services.

5. USE OF PERSONAL DATA 5

Through the use of the Website, the SpectrumProtocol.io Platform and the Services or when you submit personal data to us, we may use your personal data to operate, maintain, develop and provide to you the features and functionality of our facilities, products or Services. The purpose for which we collect your personal data includes but not limited to:

  • Identifying, analysing and evaluating the areas in which the Website, the SpectrumProtocol.io Platform and the Services can be improved;
  • Improving your access and use of the Website, the SpectrumProtocol.io Platform and the Services;
  • Offering you updates and information relating to our products or Services; responding to any queries or requests you may have;
  • Verifying your identity for the purposes of providing our products or Services;
  • Conducting due diligence checks in accordance with legal and regulatory obligations in Singapore; and/or
  • Resolving any disputes or problems which may arise in relation to use of the Website, the SpectrumProtocol.io Platform and the Services.

6. SECURITY 6

We have implemented reasonable security arrangements including physical, administrative, technical, and electronic security measures to protect against the loss, misuse, and alteration of your personal information. Despite our best efforts, however, no security measures are perfect or impenetrable. In the event where you believe your privacy has been breached, please contact us immediately.

It is your responsibility to protect any passwords you require to access your account, the Website, the SpectrumProtocol.io Platform and the Services. Please use unique numbers, letters and special characters, and do not share your password with anyone. If you do share your password with others, you will be responsible for all actions taken in the name of your account and the consequences. If you lose control of your password, you may lose substantial control over your personal information and other information submitted to us. You could also be subject to legally binding actions taken on your behalf. Therefore, if your password has been compromised for any reason or if you have grounds to believe that your password has been compromised, you should immediately contact us and change your password.

You undertake to treat your password and other confidential information in relation to the use of the Website, the SpectrumProtocol.io Platform and the Services confidentially, and we disclaim any liability arising from your failure to do so.

7. USE OF PERSONAL DATA 7

Your personal data will never be sold, traded, or otherwise transferred to any third party. However, your personal data may, from time to time, be shared with but not limited to:

  • Our personnel who will use the data to carry out the purposes set out above; and/or
  • Financial institutions and payment operators.

Personal data we collect from you will also be used, or shared with third parties that assist in operating and facilitating use of the Website, the SpectrumProtocol.io Platform and the Services (including related companies and third party service providers), for some or all of the following purposes:

  • (I) Creating or maintaining any account or profile you may have with us;
  • (II) Verifying and carrying out financial transactions in relation to any payments or transfers you make;
  • (III) Carrying out research and analytics on our users’ demographics and behaviour;
  • (IV) Provide you with information we think you may find useful or which you have requested from us;
  • (V) Enhancing user experience;
  • (VI) Determining and verifying your eligibility for certain marketing or transaction events and other features of the Website;
  • (VII) Enforcing our terms of use available at https://www.spxtrum.io (“Terms of Use”); and
  • (VIII) Communicating with you in relation to your account and alerting you to the latest developments of Spxtrum.

Disclosure may also be made where we believe in good faith that such disclosure is necessary to:

  • (I) Comply with the law or in response to a subpoena, court order, government request, or other legal process;
  • (II) Produce relevant documents or information in connection with litigation, arbitration, mediation, adjudication, government or internal investigations, or other legal or administrative proceedings;
  • (III) Protect the interests, rights, safety, or property of Spxtrum or others;
  • (IV) Enforce our Terms of Use;
  • (V) Provide users of the Services with the services they request;
  • (VI) Provide you with special offers or promotions from us; or
  • (VII) Operate our systems properly.

Disclosure on information about our visitors, customers, or former customers may also be made with the following types of companies that perform services on our behalf or with whom we have joint marketing agreements:

  • (I) Non-financial companies such as envelope stuffers, fulfilment service providers, payment processors, data processors, customer/support services, etc.; and
  • (II) Financial service providers such as companies engaged in banking, mortgage lending, consumer finance, securities, and insurance.

In sharing your personal data with such parties, we shall endeavour to ensure that the 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.

If any disclosure of your information involves the transfer of your personal information out of Singapore, we will 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 Singapore's data protection legislation.

8. Access to, withdrawal of consent abnd update of personal data 8

You have a right to access your personal data which we have collected, subject to the exceptions referred to in section 21(2) PDPA, but we may charge a fee to cover the cost of verifying the application, and locating, retrieving and copying any material requested.

You may communicate your objection to our continual use and/or disclosure of your personal data for any of the purposes at any time.

You may update any of your personal data we possess by means of updating and accessing your account details, and if not, by contacting us.

If you would like to withdraw your consent to the use of your personal data or update your personal data or have any query concerning our Privacy Policy, please contact us at info@spxtrum.io

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