Data Transfer Consent

Consent to Data Transfer

Individual Clients 

1. Consent to Data Transfer

I, [name of individual], of passport/ID number [number], consent to HashKey Technology Services Pte Ltd (UEN: 201936036M), (“Transferor”) disclosing my personal data specified in Section 2 (“Data”) of this consent (by itself or with the assistance of a data intermediary), to related and/or affiliated companies of the Transferor (collectively, the “Transferee”), for the purposes described in Section 3 of this consent.

2. Personal Data

I agree that all Data that have been provided to the Transferor pursuant to the Application may be transferred by the Transferor to the Transferee. This may include my full name, date of birth, national identifiers (such as NRIC, FIN, or passport number, collected only where required and permitted by law for identity verification), proof of address, contact information, financial information, biometric data for liveness checks, device and connection information, blockchain wallet addresses, and transaction data, including originator and beneficiary information required under applicable “Travel Rule” regulations.

3. Purposes of Processing

I agree that the Transferee may process the Data for the following purposes of allowing the Transferee to:

• process the registration for accessing the products and services of the Transferee, including without limitation conducting Know-Your-Client (KYC) due diligence procedures or any other due diligence/identification checks required by any applicable laws and regulations;
• provide its products and services, administering the accounts in relation to such products and services, and giving effect to any orders or instructions relating and to any transactions thereunder;
• provide notices, surveys, product alerts, communications and other marketing materials in relation to the products and services offered by the Transferee;
• where necessary, conduct investigations and proceedings required by applicable laws and regulations (for example, anti-money laundering/combating the financing of terrorism laws), meet its obligations to any relevant regulatory authority or comply with any sanction requirements;
• protect or enforce its legal or contractual rights;
• fulfil its record-keeping obligation or otherwise to comply with any applicable legal and regulatory obligations;
• where necessary, make any disclosure as may be required for any of the above purposes; and
• any other purpose reasonably related to the foregoing.

4. Cross-Border Transfer

I  agree that the Data may be processed and transferred outside of the jurisdiction from which the Data is collected, to the Transferee’s agents situated in Singapore, Hong Kong, Japan, the United Arab Emirates, and the Cayman Islands, where there may or may not be in place data protection laws which are substantially similar to, or serve the same purposes as, the applicable laws in the jurisdiction from which the Data is collected. I understand that this means that the Data may not be protected to the same or similar level in the jurisdictions from which the Data is collected.

5. Data Retention

I agree that the Transferee may retain the Data for as long as it is necessary to fulfil the purposes for which it was collected. This includes retention for the duration of our business relationship and thereafter for a period required by applicable laws, such as the minimum five-year retention period for transaction records under anti-money laundering regulations. Data no longer required for legal or business purposes will be securely destroyed or anonymized.

6. Withdrawal of Consent

I understand that I may withdraw the  consent for the collection, use, and disclosure of the Client’s Personal Data by providing reasonable notice to the Transferor, but withdrawing consent for purposes essential to the provision of services to the Client (such as for KYC/AML and transaction processing) will result in inability to continue to provide the Client with such services, and Transferor may need to terminate the Client’s account.

7. Safeguard

I understand that the Transferee shall endeavor to implement the appropriate administrative and security safeguards and procedures in accordance with the applicable laws and regulations to prevent the unauthorized or unlawful processing of the Data and any accidental loss or destruction of, or damage to the Data.

8. Lawfulness of Data

I acknowledge that my withdrawal of consent does not affect the lawfulness of the processing of the Data before its withdrawal.

Consent

I have read and understood this consent and its provisions and expressly agree to the transfer of the Data to the Transferee, and the processing of the Data set out in this Section 2 for the purposes listed in Section 3, in accordance with the remainder of this consent.

I further consent to the transfer of the Data (where applicable) outside the jurisdictions from which the Data is collected, where such jurisdictions include without limitation, Singapore, Hong Kong, Japan, the United Arab Emirates, and the Cayman Islands.

_____________________

Name: [name]

Passport Number: [Number]

Date: [date]

For any questions regarding this consent, please contact [e-mail]