Privacy Policy

Last Revised: 5 April 2018

Thank you for visiting our website. We are committed to protecting and respecting your privacy. We ensure that any information provided by you would be dealt with and handled only in accordance with this privacy policy (“Privacy Policy”), which describes our policies and procedures on the collection, possession, storage, use and disclosure of information provided by the Users in furtherance of their use of this website (hereinafter the “Website”).

The terms “We”, “Our”, “Company” and “Us” refers to Global DCX Pte Ltd, a private limited company incorporated in Singapore (hereafter referred to by its trading name, "Alluma"). The terms “User”, “You” and “Your” refer to a User of our Website. The capitalized terms used in this Privacy Policy, but not defined herein, shall have the meaning given to such terms in the Terms of Use.

This Privacy Policy has been published pursuant to the requirements under the Personal Data Protection Act 2012 and the rules made thereunder (the “Act”). For the purposes of the Act, the Data Protection Officer of alluma can be reached at [email protected].

Policy is part of our terms

This AML & KYC Policy is a part of and incorporated within, and is to be read along with, our Terms of Use (the “Terms”) and our Privacy Policy. You may view the current version of these policies, in effect from time to time, at www.alluma.io.

Unless otherwise specified, or required by reasonable or necessary implication, terms in this Privacy Policy have the same meaning as terms defined and used elsewhere in our Terms of Use. To avoid doubt, all provisions within our Terms of Use, including but not limited to, the General Terms, apply equally and uniformly to this Privacy Policy.

Consistent to changes

We have the right, at any time, to change or modify the terms and conditions applicable to your use of our Services, or any part thereof (including this Privacy Policy), or to impose new conditions, including, but not limited to, adding fees and charges for use. Such changes, additions or deletions shall be effective immediately upon notice thereof. This notice may be given by means including, but not limited to, updating the “Last Updated” field at the top of this document with the date of the current revision.

Any use of our Services by you after such notice shall be deemed to constitute acceptance by you of such changes, modifications or additions. Any amended Terms will apply prospectively to use of the Services after such changes become effective. It is important therefore that you review our Terms of Use and Privacy Policy on a regular basis to ensure that you are familiar with the terms in force from time to time and/or any changes made to them. If you do not agree to any amendments, you must discontinue using our Services and contact us to terminate your account.

Links to third party sites

The procedures and practices set forth in this Privacy Policy describe the use and disclosure of information collected only through our Website. However, our Website may at times contain links to other websites. Any personal information about you collected whilst visiting such websites is not governed by this Privacy Policy. You are encouraged to exercise caution and review the privacy policies applicable to such websites before accessing them. You acknowledge that the Company shall not be responsible for and has no control over the practices and content of any website accessed using the links contained on our Website. This Privacy Policy shall not apply to any information voluntarily disclosed by you to other Users of our Website or third parties except Selected Third Parties (defined herein).

Comptentency to contract

This Privacy Policy is not applicable to Users who are minors or otherwise incompetent to contract. Such Users must not provide us or other visitors with any personal information. You acknowledge that the Company shall not be responsible for and has no control over any information submitted by such Users on our Website.

Can you opt-out of sharing your information?

By using our Website or our Services, you agree and consent to the collection and use of information collected in the manner described above and in accordance with this Privacy Policy. You also agree and consent to any changes made to this Privacy Policy in due course and without notice. If you do not agree with the terms and conditions of this Privacy Policy, please do not provide any information to us. If you refuse or withdraw your consent, or if you choose not to provide us with any information as required by us, we may not be able to provide you with the Services that are being offered through the Website.

What information do we collect?

We may collect and process the following data about you (collectively “Personal Information”). You must ensure that all your data and/or information shared with us is accurate, correct and complete, at all times, and you must promptly inform us of any changes to your data and/or information which may impact your use of our Services. You understand that we shall not be liable or responsible for the authenticity of your data and/or information, or any loss or damage that may occur to you or other third parties on account of the incorrect data and/or information being provided by you.

  • Verification Information.

    If you register / attempt to register as a User of our Website, you may be required to give us personal information about yourself. The minimum information you give us may include without limitation your name, postal address, e-mail address and phone number. There may be restrictions on your use of the Services at this stage. If you request us to give you access to additional Services such as increased buy and sell limits, transfer any funds to your Linked Bank Account or third- party digital asset wallets, or correspond with us by phone, e-mail in order to troubleshoot problems reported by you or otherwise, you may be required to give us additional sensitive personal information which we may share with Third Party Service Providers acting on our behalf to verify your identity or address, and/or to manage risk. This sensitive personal information you give us may include without limitation information about/images of your taxpayer identification number, your government-issued identification documents, your date of birth, your photograph, details of your Linked Bank Account and digital asset wallets held on third-party exchanges/websites, or other information requested by us to detect and protect against frauds and similar criminal activity, and such other information required by us from time to time for providing the Services. We may also occasionally request or require you to participate in surveys. Your personal information may be collected through such surveys. Further, we may also require additional information about you for performing on-going due diligence (necessitated under the applicable law) based on your risk assessment, transaction value, etc.

  • Automatically Collected Information.

    During each of your visits to our Website, we may automatically collect and analyze demographic and other information, including without limitation, (a) technical information about your device, including its operating system and the browser, the IP address being used, location and other similar information; (b) information about your activity, including the full Uniform Resource Locators (URL) clickstream to, through and from our Website (including date and time); information about transactions and trades executed or attempted to be executed by you; material or information that you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs); (c) information about fund-transfer requests, executed while accessing Services through our Website. In such transactions, we may collect information relating to such transactions provided by you or by a Selected Third Party; and (d) Metadata and other technical data associated with the content you submit, post or share on the Website. Users can add or may have metadata added to their content including geolocation, date, attribution, or other data.

  • External Information.

    We may receive information about you from external sources such as from your use any of the other websites/apps we operate or the other Services we provide. Such data may be shared internally and combined with data collected through your use of the Website. We also work closely with select third parties (including, for example, sub-contractors such as advertising networks, analytics providers, search information providers) and may receive information about you from such sources.

  • Statistical Information.

    We collect non-personally identifiable information to track the total number of visitors to our Website in aggregate form and identify the type of Internet web browser (e.g. Google Chrome®) and operating system (e.g. Windows®) used by the visitor. This information allows us to improve the Website and Services continuously.

How do we use your personal information?

As a matter of practice, we will use your personal information only for the following purposes (collectively the “Purposes”) and inform you if any purpose is changed:

Verification Information. We will use this information:

  • to verify and process your personal particulars;

  • to inform you of promotions, offers, surveys, events, products, and services, which may be of interest to you;

  • to facilitate and provide the Services offered through our

  • to update and back-up our records;

  • to carry out our obligations arising from any contracts entered into by you with other Users of our Website (including processing of any transactions executed or attempted to be executed by you) and to provide you with the information and Services, that you request from us;

  • to enhance the security of our Website;

  • to personalize content/Services offered to you;

  • to remember information to help you efficiently access your Account;

  • to provide you with information about other Services we offer that are similar to those that you are already using or have enquired about;

  • to provide you, or permit Selected Third Parties to provide you, with information about Services we feel may interest

  • to notify you about any changes to our Services;

  • to ensure that content from our Website is presented in the most effective manner for you and for your computing

  • to send you Service-related notices or emails and other non-essential promotional material. In case you do not wish to receive such e-mails or SMS, you may unsubscribe at any time by clicking on ‘Unsubscribe’ or by contacting our Data Protection

  • for KYC verification of the details of identification documents provided by you. You understand that in order to verify that such information belongs to you: (a) we may send you a verification e-mail; and (b) share all such information with a Selected Third Party. If you are a new User, such Selected Third Party or our representatives may contact you for the purposes of verification and authentication of your identification documents;

  • to prevent and identify suspicious /other illegal transactions in order to mitigate risks relating to money laundering and other illegal activities;

  • to carry out any other purpose for which the information was

Automatically Collected Information. We will use this information:

  • to administer our Website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;

  • to improve our Website to ensure that the content is presented in the most effective manner for you and for your device;

  • to allow you to participate in interactive features of our Services, when you choose to do so;

  • as part of our efforts to keep our Website safe and secure;

  • to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;

  • to better understand the volume of traffic to particular areas of our

  • to make suggestions and recommendations to you and other Users about Services that may interest you or

  • or fulfilling our obligations under applicable law including performing on-going due diligence and reporting suspicious/other illegal

  • as part of our security, anti-fraud, and authentication checks in order to mitigate risks relating to money laundering and other illegal

  • in order to comply with the requests and/or directions of various law enforcement agencies/regulators.

External Information. We may combine this information with the information you give to us and information we collect about you. We may use this information and the combined information for the purposes set out above (depending on the types of information we receive).

Statistical Information. We may share statistically anonymized information with third parties or publish generic transactional information relating to the trades undertaken on the Website such as 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; etc.

When might we disclose or distribute your personal information?

We will only distribute your information in accordance with the circumstances outlined in this section. However, you understand and acknowledge that generally, information published on a blockchain (including, without limitation, transactional information) is susceptible to public disclosure since any blockchain ledger is publicly accessible. As a result, Digital Asset transactions, whether executed on the Website or otherwise, are not truly anonymous. Similarly, the balance and transaction history of any public Digital Asset address can also be viewed by the public at large.

Further, the information relating a public Digital Asset address can also be correlated / matched with technical information automatically collected over the Internet, in order to ascertain your identity. Also, data-analysis techniques can be used on a blockchain to identify information about you. You understand and acknowledge that we cannot be held liable for any loss of your information sustained due to the inherent lacunas of blockchain technology.

We reserve the rights to distribute your personal information to any third party, provided we do so in reasonable furtherance of the Purposes outlined in this Privacy Policy. We also reserve the rights to export your personal information and other data outside of your country of origin, or our country of incorporation. Under these circumstances, your personal information may be processed and stored in a foreign country or countries, and the governments, courts, law enforcement, or regulatory agencies of that country or those countries may be able to obtain access to your personal information under the relevant foreign laws. Under these circumstances, we will also reasonably attempt to ensure your personal information continues to receive a standard of protection that is at least comparable to that provided under PDPA. We also reserve the rights to distribute any information that you (i) voluntarily disclose or chose to make public, or (ii) is freely accessible in public domain.

We further reserve the rights to distribute your personal information to any third party under one of the following circumstances:

For Crime Prevention or Investigation. We may share this information with government/enforcement agencies or other companies assisting us, when we are:

  • Obligated under the applicable laws or in good faith to respond to court orders and processes;

  • Detecting and preventing against actual or potential occurrence of identity theft, fraud, money laundering, abuse of Services and other illegal acts; or

  • Under a duty to disclose or share your personal data in order to enforce or apply our Terms and other agreements; or to protect the rights, property, or safety of the Company, our customers, or others. This includes exchanging information with third parties for the purposes of fraud protection and KYC

For Activities of the Website. We may share this information:

  • Interaction with Users. You may routinely execute Digital Asset transfers on our Website. In order to process such transactions between you and other Users on our Website, we may share information about you with such User, including your email address or mobile phone number, to inform such User that a transfer has been sent to or received by such user.

  • Interaction with Non-Users. You may also choose to send Digital Assets to or request Digital Assets from an email address. In such cases, your username may be displayed in an email message notifying the user of the designated email address of your action.

  • For Authorization and Verification. We may use this information in connection with transfers to confirm that you are our customer, that Digital Asset transfers are enabled, and/or to notify you that you have received Digital Asset from a third-party storage service. If you request that we validate your status as our customer with a third party, we will do so. We may, from time to time, generally permit you to access your Account through one or more third-party applications. In such cases, the information you have provided to us may be shared with such third-party applications. Based on the level of authorization you provide, these third parties may be allowed to use your information for any purpose other than facilitating your transactions using our Services

For Internal Use. We may share this information:

  • With any member of our The term “Group” includes means, with respect to any person, any entity that is controlled by such person, or any entity that controls such person, or any entity that is under common control with such person, whether directly or indirectly, or, in the case of a natural person, any relative of such person.

  • In the event that the Company sells any business or assets, or parts thereof, we may disclose your personal data to the prospective buyer of such business or

  • If the Company or substantially all of its assets are acquired by a third party, the personal data held by it about its Users will be one of the transferred

With Selected Third Parties. We or our Group entities may disclose and share your personal information with selected business partners and third parties including, but not limited to, service providers who authenticate KYC and details as furnished/provided by Users to the Company; commercial bank(s) which provide(s) banking facilities to the Company; payment processing companies; and credit rating agencies. (each a “Selected Third Party”).

With Advertisers and Advertising Networks. We do not disclose sensitive personally identifiable information about our Users to any advertisers, but we may provide them with aggregate information about our Users (for example, we may inform them that any given number of women in a specified age group clicked on their advertisement on any given day) to select and serve relevant adverts to you. We may also use such aggregate information to help advertisers reach the kind of audience they want to target.

General Information of Public Interest. 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 on the Website.

How do we use cookies and web beacons?

Our Website uses cookies and tracking technology (including pixels and/or web-beacons) depending on the features offered. Cookies are small files that are placed on your device (either temporarily or until manually deleted by you) in order to distinguish you from other Users of our Website. Web Beacons are tiny graphic image files embedded in a web page or email that provide a presence on the web page or e- mail and send back to its home server information from your browser.

The use of such technology allows us to statistically monitor how many people are using our Website and those of our affiliates, or opening our e-mails, and for what purposes. We also use local storage to provide you (a) with a customized experience when you browse our Website and (b) to improve our Website, our Services, and advertising. Third parties may also use such cookies and tracking technology if you interact with any content provided by them through our Website, however, we endeavor to identify these cookies before they are used and allow you to accept or deny them.

Limited personal but anonymous information may be collected through the cookies and tracking technology, including but not limited to transaction information and other generic information such as number of visitors, device information, etc. Further, if any personal information has been previously provided, cookies may be tied to such information.

Cookie and tracking information collected by us may be shared with third-parties which directly support our advertising/promotional activities and are involved in the development of/updating our Website.

Commonly used browsers are set up to automatically accept cookies however you can modify your device’s settings to either alert you when you receive cookies or block cookies. If you disable/block cookies, it may affect the performance and functionality of our Website and may also restrict your experience. If you use different devices to access our Website, you would be required to modify each device’s settings individually to suit your cookie preferences.

How may you access your personal information?

You may review the personal information we collect about you. To the best extent possible, we will attempt to ensure that such information is correct, and up to date. To exercise this right, you may send us a request at [email protected]. However, this right is subject to payment of a processing fee, and our Terms of Use and other legal and regulatory obligations.

How long do we retain your data?

We may, at our sole discretion, retain your information and/or 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. This includes retaining any information and/or data provided by you for as long as your Account is active, for resolution of disputes, for the purpose of investigations or ongoing prosecutions or in case of any suspicious/illegal transactions, for enforcement of any agreements, and/or as necessitated under applicable laws. Copies of public content may be retained indefinitely in our systems, including in cached and archived pages of our Website, or if other Users have copied or saved that information. We make no warranties and shall not be liable regarding non–availability or non–retention of any information and/or data provided by you either before or beyond the deletion of your Account.

How do we keep your data secure?

Personal Information refers to data, whether true or not, about an individual: (i) who can be identified from that data; or (ii) from that data and other information to which we have or are likely to have access. Your personal data is accessible only by our authorized employees and Selected Third Parties and is otherwise kept secure.

We have in place appropriate technical and security measures to prevent unlawful access to or accidental loss of information collected including those prescribed under applicable laws. All information you provide to us is stored on our secure servers. We use firewalls on our servers. Any information collected during processing of payment transactions electronically will be encrypted using Secure Socket Layer (SSL) technology. Where we have given you (or where you have chosen) a username and password which enables you to access certain parts of our Website, you are responsible for keeping these details confidential. We ask you not to share your password with anyone. You must log out when you leave any section of our Website protected by a password. We recommend closing the browser completely and re- opening it before accessing other websites over the internet.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee, give no warranties, and shall not be liable for breach of the security of your data transmitted through the Website due to malicious attacks, errors, commission or omissions not willfully initiated by us. Any transmission is at your own risk. Once we have received your information, we will use strict physical, electronic, and procedural safeguards to try to prevent unauthorized access.

What rights can you exercise?

You may deal with your personal information available to us as follows:

  • You may correct, amend, add or update personal information from your Account at any time by logging in to your

  • You are free to remove or delete your content from your Account at any point in time, provided, however, we may retain all or some of your data in accordance with its Terms in force or as per Applicable

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