Privacy Policy
HashKey Technology Services Pte. Ltd. and its affiliates (hereinafter referred to as “HTS”, "we" "us" or "our") is committed to protecting the privacy, confidentiality, and security of the personal data held by HTS complying with the requirements of applicable personal data protection laws including the Personal Data Protection Act 2012 of Singapore ("PDPA") with respect to the collection, use and management of personal data. In doing so, HTS is equally committed to ensuring that all its employees and agents uphold these obligations.
This Privacy Policy ("Privacy Policy") describes:
• the personal data which HTS will collect or process,
• how personal data will be used, shared and protected, and
• your rights in relation to personal data, including the right to make data access and correction requests.
Personal data will be collected only for lawful and relevant purposes and all practicable steps will be taken to ensure that personal data held by HTS is accurate. HTS will use your personal data which HTS may from time to time collect in accordance with this Privacy Policy.
HTS reserves the right from time to time to revise this Privacy Policy. Where any changes to this Privacy Policy are material, HTS will notify you using the contact details which you have provided HTS and by updating and issuing the new version on the Site. You are advised to check the Privacy Policy periodically and pay attention to its revision. After the publication of the new version of this Privacy Policy, your continued use of the Site or your continued relationship with HTS shall be deemed to be acceptance of and consent to this updated Privacy Policy, as amended from time to time. If we change the purpose for which personal data is used, such change will not go beyond what is reasonably considered to be relevant to the original purpose and we will notify you or make a public announcement of the revised purpose.
HTS will take reasonable and practicable steps to ensure the security of your personal data and to avoid unauthorised or accidental access, erasure or use for other purposes. This includes physical, technical, and procedural security methods, where appropriate, to ensure that your personal data may only be accessed by authorised personnel.
Please note that if you do not provide HTS with personal data (or relevant personal data relating to persons appointed by you to act on your behalf), HTS may not be able to provide the information, products or services you have asked for or process your requests, applications, subscriptions or registrations, as applicable.
If you have any questions about this Privacy Policy or how HTS uses your personal data, please contact HTS through the communication channels set out in the "Contact HTS" section below.
Collection of personal data
Personal data may be collected from you on a voluntary basis for particular purposes or services. Your personal data are collected and held by HTS as explained below:
| Customers | When you apply, subscribe and register for HTS products and/or services or make enquiries to HTS, we will collect personal information about you so that we can process your application, subscription and registration including but not limited to your name, telephone number, mobile phone number, address, email address, facsimile number, gender, date of birth, age, job title, interests and other information you provide via the Site or any other means. We may also collect other personal data you provide as set out in sections of the Site which invite you to provide personal data. |
| Job applicants | We will collect information including but not limited to the below to process your job application with HTS: • your personal details, including your name, telephone number, mobile phone number, address, email address, facsimile number and language proficiency; • your education background, including your level of education and field of study; • personal data contained in your resume attached to your application, transcript or reference letter; and • other personal data you provide in the job application process with HTS. |
| Visitors of HTS' Site (whether an investor, job applicant or other third party) | When you visit the Site, we will record each of your visits and will
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Use of personal data
From time to time, where personal data is provided to HTS, HTS may use the personal data as explained below and such personal data may be transferred to a place outside Singapore:
| Customers | For the purpose of providing products and/or services to you, we will use the information that we have collected about you to: •process your applications, subscriptions and registration for HTS products and/or services; •administer your accounts and providing you with HTS products and/or services; •register you for investor-related events, activities and materials; •design, install and use software apps of HTS from relevant app stores; •respond to and process your enquiries and taking further actions or do follow ups as required; •market and promote existing and future HTS products or services; •provide you with information regarding the market insights in connection with HTS products or services; •provide you with the online services available at the Site and/or through other telecommunication channels; •compile general statistics in relation to the number of visitors to Site and the usage of Site; •conduct research, survey and/or analysis from time to time to better understand your needs, preferences, interests, experiences and/or habits; •use your personal data for AI analytics; •design new and/or enhance existing services, products, activities, and/or other events relating to HTS products or services; •use the information that Site collects about you to improve your experience while using our services; and •for other purposes directly relating to any of the above. |
| Job applicants | For the processing of your job application and administration of our recruitment database, we will use the information that we have collected about you to: • evaluate and process job applications;• keep job application records; • assess suitability of candidates for job positions; • communicate with you in the course of your employment and performing human resource management functions and activities; • communicate with you on other opportunities; and • comply with our legal obligations. |
| Other third parties | For the purpose directly related to the function or activity of HTS, to comply with legal requirements, to carry out obligations arising from the contracts entered between you and HTS, any other applicable purposes as set out in this "Use of personal data"section, and/or any other purpose notified to you at the time of collection of the personal data. |
We will obtain your consent before using your personal date for other purposes, unless otherwise permitted by applicable laws.
Other uses
HTS may be required to retain, process and/or disclose your personal data to agents, contractors or
other third-party service providers, to which HTS does not assume any liability for any loss or damage
that you may sustain, in order to:
1) comply with a court order, subpoena or other legal process (whether in Singapore or elsewhere);
2) comply with applicable laws and regulations;
3) comply with a request by a government authority, law enforcement agency or similar body (whether
situated in Singapore or elsewhere);
4) provide to the third-party database for submitting behaviours concerning anti-money laundering,
terrorism financing, and evading trade and economic sanctions;
5) provide to a third party which provide services (such as legal, financial, management, operation,
market surveillance, analytic or technical services) or is associated or acting as a nominee to HTS;
6) provide to any third party to whom HTS’ businesses or any part of HTS’ businesses will be sold,
assigned or transferred to, if applicable; or
7) HTS may need to retain, process and/or disclose your personal data in order to enforce any
agreement with you, protect HTS’ rights, property or safety, or the rights, property or safety of HTS’
employees.
How does HTS use cookies
If you access HTS’ information or services through the Site, you should be aware that cookies are used. Cookies are data files stored on your browsers. The Site automatically installs and uses cookies on your browsers when you access it, which are used to store your preferences, enhance the function of the Site, and facilitate your browsing. HTS does not consider cookies to be personal data as cookies cannot be used independently to identify a specific individual. However, we will deem cookies to be personal data if they are incorporated and used together with personal data. You may refuse to accept cookies on your browsers by modifying the settings in your browsers or internet security software. However, if you do so you may not be able to utilise or activate certain functions available on the Site.
Third party websites
The Site may from time to time contain linkages to other websites. These other websites are independent from the Site. HTS has no control or management over the contents of such other websites or their privacy policies or compliance with the law. You should be fully aware that the provisions of such linkages do not constitute an endorsement, approval, or any form of association by or with HTS and HTS has no control over the personal data submitted by you, if any, to other websites.
Transfer of personal data
For one or more of the purposes specified above, HTS may transfer your personal data to any agents, contractors or other third-party service providers who provide administrative, telecommunications, computer, payment, debt collection, data processing, data storage, data analytics or other services to HTS in Singapore or elsewhere, and other third parties as notified at the time of collection. HTS may share your personal data within its group of companies for providing the products and/or services sought by you for the same purpose or directly related to the purposes at the time of collection. HTS will adopt contractual and/or other means to ensure the agents, contractors or other third-party data processors who process personal data on behalf of HTS will take all reasonable steps to (i) protect the personal data they hold against unauthorized or accidental access, processing, erasure, loss or use; and(ii) ensure that personal data will not be kept longer than necessary.
International transfer of personal data
If you choose to provide us with personal data from outside Singapore, it will be stored in Singapore. HTS may transfer (by any means including sending or allowing access) that personal data across borders, and from Singapore to other countries or jurisdictions. HTS will not transfer any personal data to a country or jurisdiction outside Singapore unless it has taken appropriate steps to ensure that the recipient of such personal data is bound by legally enforceable obligations or recognised certificationsto provide a standard of protection comparable to that under the PDPA.
Corporate reorganisation
As HTS continues to develop its business, it may reorganise its business structure, undergo a change of control or business combination. In these circumstances it may be the case that your personal data is transferred to a third party who will continue to operate HTS’ business or a similar service under either this Privacy Policy or a different privacy policy which will be notified to you. Such a third party may be located, and use of your personal data may be made in connection with such acquisition or reorganisation outside your country of location (i.e. Singapore).
Protection of personal data
HTS will take reasonable and practicable steps to protect your personal data and to prevent
unauthorised or accidental access, erasure, or use for other purposes. All personal data provided to
HTS will be securely stored with restricted access by authorized personnel only. We utilize
encryption/security software for data transmission so as to protect your data via encrypting it in a
secure format to ensure its privacy and security from unauthorised access or disclosure, accidental
loss, alteration or destruction. Furthermore, HTS will establish internal rules for the protection of
personal data and will supervise employees as appropriate to prevent leakage, loss, or damage of
personal data to ensure the safe management of personal data.
In addition, we will adopt contractual or other means to prevent any personal data transferred to HTS'
data processors (i) from being kept longer than is necessary for processing of the data; and (ii) from
unauthorized or accidental access, processing, erasure, loss or use, if HTS is to engage any data
processor. Where personal data is handled by any other subcontractors, HTS will ensure that the
subcontractor is subject to confidentiality obligations or other obligations stipulated by HTS that ensures HTS’s ability to provide the necessary and appropriate supervision to ensure that the subcontractor manages personal data securely.
Nevertheless, the transmission of information via the internet is not completely secure. Although HTS
will do its best to protect your personal data, HTS cannot guarantee the security of data transmitted to
the Site. Therefore, HTS cannot ensure or warrant the security of any information or personal data you
transmit to HTS, and you understand that any information or personal data that you transfer is done at
your own risk.
Once your personal data is received, HTS will use strict procedures and security features to try to
prevent unauthorized access. We use firewalls and secure server software to protect your personal data
from unauthorised access, disclosure, alteration, or destruction. However, this cannot guarantee that
such personal data will never be compromised. If HTS becomes aware of a security breach, we may
notify you electronically so that you can take protective measures, and by agreeing to this Privacy Policy, you
consent to receive such communications.
Notice on direct marketing
Where you have given consent and have not subsequently opted out, HTS may from time to time use
your personal data (including your name and contact details) to send you direct marketing or
promotional communications such as emails containing news, promotions, events and marketing offers. The dispatch of such direct marketing communications may be undertaken by third-party service providers.
If you do not wish to receive further direct marketing or promotional materials from HTS, you may opt
out of receiving direct marketing or promotional communications by contacting HTS by one of the
communication channels set out in "Contact HTS" section below.
Retention of personal data
We aim to retain your personal data no longer than is necessary for the fulfilment of the purposes of
collection unless a longer retention period is required or permitted by applicable laws, rules and
regulations.
HTS will take reasonable steps to ensure the accuracy of your personal data held by HTS. If HTS
becomes aware that the personal data is inaccurate, HTS will not use such data and will notify any third
party to which such personal data has been transferred regarding the same.
For personal data for recruitment purposes, HTS will retain such data of unsuccessful job applicant, for
a period not longer than two years from the date of rejecting the applicant, unless there is subsisting
reason that obliges HTS to retain the data for a longer period, such as for compliance with applicable
laws, rules and regulations; or you have given prescribed consent for the data to be retained beyond the
prescribed period.
Access and correction of personal data
Under applicable laws, you may have the right to request for access to your personal data, to obtain a copy of the personal data, to correct any personal data that is inaccurate and to delete or cease the collection, processing or use of any personal data. You may request HTS to inform you of the type of personal data held by HTS, including information on how your personal data has been used or disclosed
When HTS receives a request from you to correct, add, or delete (hereinafter referred to as “correct”) your personal data on the grounds that it is untrue, we will make the necessary investigation without delay to the extent necessary for the fulfilment of the purposes of collection, except in cases where special procedures are prescribed by other laws. Where appropriate, HTS will make the correction as soon as practicable. If the personal data has been disclosed to other organisations within the year prior to the correction, HTS will send the corrected personal data to such organisations, unless you consent otherwise. Where HTS determines that no correction is required, it will annotate the record to reflect that a request for correction was made.
Request for access and correction of personal data or for information regarding policies and practices and kinds of data held by us should be addressed in writing and sent to HTS by post or by email following the details set out in the "Contact HTS" section below.
In accordance with the terms of applicable laws, HTS has the right to charge a reasonable fee for the processing of any data access request.
Termination or cancellation
Should your relationship with HTS be cancelled or terminated at any time, HTS shall cease processing
your personal data as soon as reasonably practicable following such cancellation or termination,
provided that HTS may keep copies of the data as is reasonably required for reasonable purposes, such
reasonable purposes shall include keeping of records, use in relation to any actual or potential dispute,
complying with applicable laws and regulations, and protecting HTS’ rights, property or safety, or the
rights, property or safety of HTS’ employees and agents.
Under applicable laws, you may have the right to request that HTS stop processing and delete your
personal data. If you make such a request on the grounds that your data was used for purposes beyond
those stated in this Privacy Policy, or was obtained by deception or any other wrongful, unlawful, or improper
means, HTS will, upon verifying the identity of the user who made the request, conduct the
necessary investigation without delay, and, based on the result of such investigation, cease using the personal data without charge and notify you to that effect. However, HTS may retain a copy of your
personal data if required or permitted by applicable laws and regulations.
Contact HTS
HTS has appointed a Data Protection Officer (“DPO”) who is responsible for overseeing and ensuring HTS’s compliance with this Privacy Policy. If you have any questions or concerns about this Privacy Policy or how HTS processes your personal data, or if you would like to make a request for access or update of your personal data, please contact HTS’ Data Protection Officer by post or by email at:
Address: 3 Church Street Samsung Hub #28-06, Singapore 049483
Email: In respect of requests pertaining to HTS - askotc@hashkey.com.
If you have any objections to the way in which HTS process your personal data, you have the right to lodge a complaint with Singapore’s Personal Data Protection Commission.
Prevailing Language
Translated versions of this Privacy Policy may be made available in languages other than in English for convenience. The English version of this Privacy Policy is the governing version and in the event of any inconsistency or discrepancy between the English version of this Privacy Policy and any other translated version, the English version shall prevail.
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