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Privacy Policy

This Privacy Policy is a legal agreement between you (Licensee or you) and TomoChain 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 (defined below) (“Company”, “we”, “us” or “our”)

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 Service(s), how we use it, the conditions under which we may disclose it to others and the measures we take to keep it secure.

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.

INTRODUCTION

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. TomoChain does not collect, hold, or store keys, account information, or passwords.

To the extent we collect any personal information, this privacy policy (“Policy”) describes how the Company collects, uses, and shares personal information of people who use our websites (the “Site”), TomoWallet, TomoScan, TomoMaster, TomoIssuer, TomoRelayer, TomoStats, TomoBridge and our other products (collectively, the “Services”).

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, App, and/or using the Services, you acknowledge that the collection, use, and sharing of your information will take place as described in this Policy.

So that we are clear about the terminology we are using, when we use the phrase “Personal Information” in this Privacy 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.

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.

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 filling in forms on our website(s) or by corresponding with us by e-mail or live-chat. The personal information you provide may include your name, email, address, phone number, IP address, 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 privacy policy.

Information we collect about you

When you use our Services we may collect information about your IP address, information about your visit, your browsing activity, and how you use our Services. This information may be combined with other information you provide.

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 collect information about you as described below. We use this information to enhance your experience with our Services.

The Company does not track users over time and across third party websites to provide targeted advertising and therefore does not respond to Do Not Track (DNT) signals.

USE OF INFORMATION

We use the information that we have about you to provide support and certain Services to you.

We may use the Personal Information we collect from and about you to (1) provide you with information or services that you request from us, including to respond to your comments, questions, and/or provide customer service; (2) monitor and analyze usage and trends and personalize and improve the Services and your experience using the Services; and (3) for any other purpose with your consent.

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

SHARING OF PERSONAL INFORMATION

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.

We may share the Personal Information we collect from and about you (1) to fulfill the purpose for which you provided it; (2) with your consent; (3) for legal, protection, and safety purposes; (4) to comply with any court order, law, or legal process, including to respond to any government or regulatory request; (5) to protect the rights of the Company, our agents, customers, and others, including by enforcing our agreements, policies, and terms of service; and (6) 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 (“Service Providers”). 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.

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.

OUR COMMITMENT TOWARDS CHILDREN'S PRIVACY

We do not direct the Services to, nor do we knowingly collect any Personal Information from children under 13. Children under 13 are not eligible to use the Services. If we learn that someone using our Services is under 13 years of age, we will take steps to remove any Personal Information from our database and to prevent them from utilizing the Services.

SECURITY OF YOUR PERSONAL INFORMATION & RIGHTS

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 our security measures.

In certain circumstances, you will also have the following rights:

Right to access: the right to request certain information about, access to and copies of any Personal Information about you that we are holding (please note that you are entitled to request one copy of the Personal Information that we hold about you at no cost, but for any further copies, we reserve the right to charge a reasonable fee based on administration costs);

Right to rectification: the right to have your Personal Information rectified if it is inaccurate or incomplete;

Right to erasure/“right to be forgotten”: where the processing of your information is based on your consent, the right to withdraw that consent and the right to request that we delete or erase your Personal Information from our systems (however, this will not apply if we are required to hold on to the information for compliance with any legal obligation, or if we require the information to establish or defend any legal claim);

Right to restriction of use of your information: the right to stop us from using your Personal Information or limit the way in which we can use it;

Right to data portability: the right to request that we return any information you have provided in a structured, commonly used, and machine-readable format, or that we send it directly to another company, where technically feasible; and

Right to object: the right to object to our use of your Personal Information including where we use it for our legitimate interests.

Requests in relation to the above rights should be sent to: [email protected]om

Legal Basis for Processing

The following legal bases apply to the ways in which we use and share an individual’s Personal Information:

We rely on an individual’s consent to process Personal Information to provide support and/or carry out Promotions. This consent can be withdrawn at any time.

We also process the information provided by an individual in our legitimate interests in ensuring our business is conducted legitimately and to a high standard.

We will retain the information you provide in order to process your request, provide support, and/or carry out and fulfill our Promotions. If you request support, we will retain your information for no longer than six (6) months. If you participate in a Promotion, we will retain your information until the Promotion is carried out and ninety (90) days after any prize, reward, or offer is fulfilled. Your Personal Information will then be deleted.

CONTACT INFORMATION

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

CHANGES TO PRIVACY POLICY

We may modify this Policy from time to time. We also may provide additional notice, as applicable, depending on the type of change. 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.

We keep this Policy under regular review. This Policy was last updated in February 27, 2020