This Data Protection Notice (“Notice”) sets out the basis which Ceito (“we”, “us”, “our”, or “Company”) may collect, use, disclose or otherwise process personal data of our customers in accordance with the Personal Data Protection Act (“PDPA”). Ceito Pte. Ltd., a Singapore company, located at 28C Stanley Street Singapore 068737 is committed to protecting and respecting your privacy.
This Notice applies to personal data in our possession or under our control, including personal data in the possession of organisations which we have engaged to collect, use, disclose, or process personal data for our purposes. This notice applies to information we collect whenever you use our websites (any page on the ceito.io domain), including https://www.ceito.io/ and https://dashboard.ceito.io/, (collectively, the “Sites”) or otherwise interact with us as described below. Please read the following thoroughly to comprehend our practices and views with regards to your personal data and how we will handle it.
We may make changes to this notice occasionally. If we do make changes, we will inform you by updating the last revised date at the top of the notice. We may also provide additional notices to you (like sending an email to you or including a statement at the homepage of our Sites). Please also do occasionally review our Data Protection Notice whenever you interact with us to be informed about the ways you can help protect your privacy and our information practices.PERSONAL DATA
- 1. As used in this Notice:
- "customer" means an individual who
- (a) has contacted us through any means to find out more about any goods or services we provide, or
- (b) may, or has, entered into a contract with us for the supply of any goods or services by us; and
- “personal data” means data, whether true or not, about a customer who can be identified:
- (a) from that data; or
- (b) from that data and other information to which we have or are likely to have access.
- 2. Depending on the nature of your interaction with us, some examples of personal data which we may collect from you include your name and identification information such as your NRIC number, contact information such as your residential address, email address or telephone number, nationality, gender, date of birth, marital status, photographs and other audio-visual information, employment information, web site Uniform Resource Locator (URL), free-form text, and personal description, and financial information such as cryptocurrency wallet addresses.
- 3. Other terms used in this Notice shall have the meanings given to them in the PDPA (where the context so permits).
- 4. We generally do not collect your personal data unless
a. it is provided to us voluntarily by you directly or via a third party who has been duly authorised by you to disclose
your personal data to us (your “authorised representative”) after
- i. you (or your authorised representative) have 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. collection and use of personal data without consent is permitted or required by the PDPA or other laws. We shall seek your consent before collecting any additional personal data and before using your personal data for a purpose which has not been notified to you (except where permitted or authorised by law).
5. We may collect and use your personal data for any or all of the following purposes:
- a. performing obligations in the course of or in connection with our provision of the goods and/or services requested by you;
- b. verifying your identity;
- c. responding to, handling, and processing queries, requests, applications, complaints, and feedback from you;
- d. managing your relationship with us;
- e. processing payment or credit transactions;
- f. sending your marketing information about our goods or services including notifying you of our marketing events, initiatives and promotions, lucky draws, membership and rewards schemes, and other promotions;
- g. complying with any applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority;
- h. any other purposes for which you have provided the information;
- i. transmitting to any unaffiliated third parties including our third-party service providers and agents, and relevant governmental and/or regulatory authorities, whether in Singapore or abroad, for the aforementioned purposes; and
- j. any other incidental business purposes related to or in connection with the above.
6. Regarding to your visits to our Sites, we may automatically collect the following information:
- a. Information about your visit to our Sites, including download errors, the full Uniform Resource Locator (URL), length of visits to our Sites, and products added to your shopping cart.
- b. Technical information, including browser type and version, the Internet Protocol (IP) address used to connect your computer to the Internet, operating systems, platforms, time zone setting, and browser plug-in types and versions.
- d. Information we obtain from other sources about you may be combined with information we collect about you.
7. 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 goods or services requested by you; or
- b. to third party service providers, agents and other organisations we have engaged to perform any of the functions listed in clause 5 above for us.
- c. To respond to a request for information if we believe disclosure is in alignment with any applicable regulation, law, or legal process, or as otherwise required by any applicable rule, law, or regulation;
- d. In connection with, or during negotiations of, any sale, merger of company assets, acquisition or financing of a portion or all of our business to another company or individual;
- e. If we believe that your actions are not consistent with our user policies and agreements, or to protect the property, safety, and rights of us or any third party;
- f. With consultants, vendors, and other service providers who require access to such information to do work on our behalf; and
- g. At your direction or with your consent.
- h. We may also share de-identified or aggregated information, which cannot reasonably be used to identify you.
- 8. The purposes listed in the above clauses 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).
- 9. The consent that you provide for the collection, use and disclosure of your personal data will remain valid until such time it is being withdrawn by you in writing. You may withdraw consent and request us to stop using and/or disclosing your personal data for any or all of the purposes listed above by submitting your request in writing or via email to our Data Protection Officer at the contact details provided below.
- 10. Upon receipt of your written 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) for your request to be processed and for us to notify you of the consequences of us 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 ten (10) business days of receiving it.
- 11. Whilst we respect your decision to withdraw your consent, please note that depending on the nature and scope of your request, we may not be in a position to continue providing our goods or services to you and we shall, in such circumstances, notify you before completing the processing of your request. Should you decide to cancel your withdrawal of consent, please inform us in writing in the manner described in clause 8 above.
- 12. Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclose without consent is permitted or required under applicable laws.
13. If you wish to make
- a. an access request for access to a copy of the personal data which we hold about you 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 about you, you may submit your request in writing or via email to our Data Protection Officer at the contact details provided below.
- 14. Please note that a reasonable fee may be charged for an access request. If so, we will inform you of the fee before processing your request.
- 15. We will respond to your request as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days after receiving your request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to your request. If we are unable to provide you with any personal data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the PDPA).
- 16. To safeguard your personal data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, we have introduced appropriate administrative, physical and technical measures such as up-to-date antivirus protection, encryption and the use of privacy filters to secure all storage and transmission of personal data by us, and disclosing personal data both internally and to our authorised third party service providers and agents only on a need-to-know basis.
- 17. You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.
- 18. We generally rely on personal data provided by you (or your authorised representative). In order to ensure that your personal data is current, complete and accurate, please update us if there are changes to your personal data by informing our Data Protection Officer in writing or via email at the contact details provided below.
- 19. We may retain your personal data for as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws.
- 20. 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.
- 21. Transfer of personal data to countries outside of Singapore is done during the Know Your Customer (KYC) and Anti-Money Laundering (AML) sections of the registration process. This includes data transfers to our KYC/AML partners, Jumio Pte Ltd and Thomson Reuters. Personal data transferred is done solely for the purpose of customer identity verification.
- 22. Personal data transferred continues to receive a standard of protection that is at least comparable to that provided under the PDPA.
23. You may contact our Data Protection Officer if you have any enquiries or feedback on our personal data protection policies
and procedures, or if you wish to make any request, in the following manner:
- DPO Name: Shaun Cheetham
- Email: Shaun@Ceito.io
- 24. This Notice applies in conjunction with any other notices, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your personal data by us
- 25. We may revise this Notice from time to time without any prior notice. You may determine if any such revision has taken place by referring to the date on which this Notice was last updated. Your continued use of our services constitutes your acknowledgement and acceptance of such changes.