Legal and Privacy

Privacy Policy

Overview

  • Oobit Technologies Pte. Ltd., a company incorporated in Singapore (UEN 201716443G) with its registered office address at 50 Raffles Place, #37-00, Singapore Land Tower, Singapore 048623 (the “Company”), is the operator of oobit.com (“our Website”), Oobit Pass, Oobit P2P, Oobit xMAP, and Oobit Tools (collectively, the “Platform”, and “Services”). References to “Oobit”, “we”, "our" or "us" refer to the Company. References to “Users” or “you” or their variations refer to any person (including a corporate entity) who wishes to gain or who gains access to Our Website, Platform and Services.

1.2 This Privacy Policy outlines how Oobit collects, uses, maintains and discloses information about you, which may include your Personal Data (as defined in Section 2.1 below) safeguards your Personal Data in accordance with the Singapore Personal Data Protection Act (No. 26 of 2012) (“the Act”). Please take a moment to read this Privacy Policy so that you know and understand the purposes for which we collect, use and disclose your information. This Privacy Policy supplements but does not supersede nor replace any other consents which you may have previously provided to us in respect of your Personal Data, and your consents herein are additional to any rights which we may have at law to collect, use or disclose your Personal Data.

  • This Privacy Policy forms a part of the terms and conditions governing your relationship with us and should be read in conjunction with our “Terms of Service”.

INFORMATION WE COLLECT AND RECEIVE FROM YOU

  • In this Privacy Policy, “Personal Data” refers to any data, whether true or not, about an individual 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, including data in our records as may be updated from time to time.
  • Examples of such Personal Data you may provide to us may include (depending on the nature of your interaction with us) your full name, email address, telephone number, and your location and any other information relating to any individuals which you have provided us in any forms you may have submitted to us, or via other forms of interaction with you.

2.3 In order for us to provide some of our Services to you, we may collect and receive the following information:-

Personal Identification Information

  • We may process your personal identification information such as your full name, email address, telephone number, and your location. The personal identification information may be processed for the purposes of providing our Services, communicating with you, protecting our users from illegal activity, maintaining legal and regulatory compliance and helping us to prevent, detect and investigate fraud, money laundering and/or other criminal activity or misuse of our Services.
  • Processing of your personal identification information will help us to provide a more trustworthy, safe and reliable user experience for our customers. The legal bases for this processing are: the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and the legitimate interests of ours and/or those of third-parties, namely to prevent, detect and investigate fraud, criminal activity and/or other misuse of the Services. The processing of Personal Data is necessary for compliance with the legal obligation should Oobit be required to comply with anti-money laundering and anti-terrorist financing laws.

Corporate Information

  • We may process corporate information which may include information and documentation related to the name, industry, ownership, registration, country of incorporation, business address and financial information of corporate users ("Corporate Information"). Corporate Information may also contain personal identification information related to the company account holders, authorised representatives, agents, beneficial owners and/or members of the board of directors of the company. The Corporate Information may be processed for the purposes of providing our services, ensuring the security of our users and services, communicating with you and to protect our users from illegal activity, maintaining legal and regulatory compliance and to help us to prevent, detect and investigate fraud, money laundering and/or other criminal activity or misuse of our service. The legal bases for this processing are: the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and the legitimate interests on our part and/or by third-parties, namely to prevent, detect and investigate fraud, criminal activity or other misuse of the services. The processing of Corporate Information is necessary for compliance with the legal obligation should Oobit be required to comply with anti-money laundering and anti-terrorist financing laws.

Usage Data

  • We may collect and/or process data about your use of our website and services ("Usage Data"). For example, we may collect website traffic data such as the number of website visitors and the number of website users using a particular service. In this way, we hope to improve our Services and user experience. Usage Data is primarily non-personally-identifying information of the sort that web browsers, servers, and services like Google Analytics typically make available, such as the browser type, language preference, referring site, and the time of each visit. Other non-identifying information that we might have access to includes how you use the service (e.g. search queries), your approximate location, cookies set by our site, etc. Usage data may include: (a) Usage Data that we collect mainly for behaviour statistics, business intelligence and email campaigns, website traffic data that we collect with the help of Google Analytics; (b) Usage Data that we collect mainly for technical, security, fraud prevention and/or for error tracking reasons. We gather data on website errors with the help of software which may occasionally contain Usage Data. We also log certain events from your actions on our website at Oobit.com.

Trade information relating to digital tokens

  • We may collect and/or process data relating to the trades that you conduct through our website or our affiliates’ websites ("trade information"). The trade information may include your trade ID, initiated trades, payment method, advertisement information, buyer username, seller username, trade value (in fiat), trade value (in bitcoin or any other digital currency), bitcoin price, currency, timestamps of trade and trade chats. The legal bases for this processing are: the performance of a contract between you and us and compliance with a legal obligation that Oobit is subject to, namely in order to comply with anti-money laundering and anti-terrorist financing laws and legitimate interests of ours and/or by third-parties, namely to prevent, detect and investigate fraud, criminal activity or other misuse of the Services.

Notification information

  • We may process information that you provide to us for the purpose of subscribing to our email notifications, SMS notifications and/or newsletters, and such notification information may include your email address, phone number, username and full name ("notification information"). The notification information may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is your consent (when required by law), the performance of a contract between you and us and our legitimate interest to communicate with our customers and to perform direct marketing where allowed by law without consent. You can unsubscribe at any point by contacting us (at the email address set out at Section 14 below) or by clicking the unsubscribe link in each email sent by us.
  • We may process any of your personal data when necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or outside the court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.

INFORMATION WE COLLECT AND RECEIVE FROM OUR WEBSITE

  1. We may collect and receive the following information via our Website (including our mobile applications):

IP Address 

  • An IP address is a number that is automatically assigned to your computer when you signed up with an Internet Service Provider. When you visit our website, your IP address is automatically logged in our server. We use your IP address to help diagnose problems with our server, and to administer our website. From your IP address, we may identify the general geographic area from which you are accessing our website however, we will not be able to pinpoint the exact geographic location from which you are accessing our website. Generally we do not link your IP address to anything that can enable us to identify you unless it is required by applicable laws and regulations.

Information on Cookies 

  • A cookie is an element of data that a website can send to your browser, which may then store it on your system. We use cookies in some of our pages to store visitors’ preferences and record session information. The information that we collect is then used to ensure a more personalised service level for our users. You can adjust the settings on your browser so that you will be notified when you receive a cookie, or to disable the cookies associated with our website. Please refer to your browser documentation to check if cookies have been enabled on your computer or to request not to receive cookies. Please note however that you may not be able to enter certain part(s) of our website, and some of the functions and services may not be able to function without cookies. This may also impact your user experience while on our Website.

HOW WE COLLECT OR RECEIVE YOUR PERSONAL DATA

  1. Generally, we obtain your Personal Data in various ways, such as:
  • when you sign up for or use the Platform or our Services or when you register an account at Oobit website;
  • when you submit application forms or other forms relating to the Platform or any of our Services;
  • when you use the Platform or our Services (including but not limited to websites, apps and any online accounts established with us);
  • If you contact us, for example, with a query or to report a problem;
  • when you contact us through various methods such as application forms, emails and letters, telephone calls and conversations you have with our staff. If you contact us or we contact you using telephone, we may monitor or record the phone call for quality assurance, training and security purposes;
  • when you request that we contact you, be included in an email or other mailing list; or when you respond to our request for additional Personal Data, our promotions and other initiatives;
  • from our analysis of your transactions (including but not limited to payment history);
  • when you participate in customer surveys or when you sign up for any of our promotions;
  • when you submit a job application to us;
  • when we receive references from business partners and third parties, for example, where you have been referred by them;
  • when we seek information from third parties about you, for example, from your ex-employer and the relevant authorities;
  • when you sign up for our events; and
  • when you submit your Personal Data to us for any other reasons.

PURPOSE OF COLLECTING AND PROCESSING THE INFORMATION

  • Generally, Oobit may collect, use and disclose information for the following purposes:
  • providing our Services to you;
  • communicating with you on matters relating to your account relationship with us or your interest in the Platform or our Services;
  • responding to your queries and requests;
  • providing events to you;
  • managing the administrative and business operations of Oobit and complying with internal policies and procedures;
  • matching any Personal Data held which relates to you for any of the purposes listed herein;
  • resolving complaints and handling requests and enquiries;
  • preventing, detecting and investigating crime, including fraud and money-laundering, and analyzing and managing commercial risks;
  • providing media announcements and responses;
  • complying with applicable Anti-Money Laundering and Countering the Financing of Terrorism regulations;
  • meeting or complying with any other applicable laws, regulations, directives, rules, codes of practice or guidelines issued by any legal or regulatory bodies which Oobit may be subject, whether local or overseas (including but not limited to disclosures to regulatory bodies, conducting audit checks, surveillance and investigation);
  • legal purposes (including but not limited to obtaining legal advice and dispute resolution); and
  • purposes which are reasonably related to the aforesaid.
  • Where permitted under the terms of the agreement which you have entered into with us and as part of the services which we provide to you, we may from time to time and at our discretion also use your contact particulars (including your phone number and email address) to contact you in order to provide you with information and/or updates which you are entitled to receive in accordance with the terms and conditions of our agreement with you on the Platform and/or our Services.
  • If you submit an application to us as a candidate for an employment or representative position, Oobit also collects, uses and discloses your Personal Data for the following purposes:
  • conducting interviews;
  • processing your application (including pre-recruitment checks involving your qualifications);
  • providing or obtaining employee references and for background screening;
  • evaluating and assessing your suitability for the position applied for; and
  • any other purposes reasonably related to any of the above.
  • Where permitted under the Act, Oobit may also collect, use and disclose your Personal Data as follows:
  • administering Services offered (including but not limited to the maintenance, management and operation of the Platform and our Services, communication with clients, and processing of any receipts and/or payments arising under the account relationship);
  • providing cross-referrals to its affiliates or related companies;
  • conducting analytics with regard to the Platform and our Services which you might be interested in;
  • organising promotional events and corporate social responsibility projects (including but not limited to taking pictures and recording your video/audio feedback and testimony in relation thereto);
  • providing Services, useful information and/or notifications to you, including promotions and reward programmes;
  • matching Personal Data with other data collected for other purposes and from other sources (including third parties) in connection with the provision or offering of our Services;
  • sending you details of products, services, special offers and rewards, either to our customers generally, or which we have identified may be of interest to you; and
  • conducting market research, understanding and determining customer location, preferences and demographics for us to review, develop and improve our Services and also develop special offers and marketing programmes.
  • If you have provided your Singapore telephone number(s) and have indicated that you consent to receiving marketing or promotional information via your Singapore telephone number(s), then from time to time, Oobit may contact you using such Singapore telephone number(s) (including via voice calls, text, fax or other means) with information about our Platform and Services (including discounts and special offers).

    In relation to certain Services or in your interactions with us, we may also have specifically notified you of other purposes for which we collect, use or disclose your Personal Data. If so, we will collect, use and disclose your Personal Data for these additional purposes as well, unless we have specifically notified you otherwise.
  • You have a choice to withdraw your consent for receiving marketing or promotional materials/communication. You may contact us using the contact details set out in Section 14 below.
  • Please be aware that once we receive confirmation that you wish to withdraw your consent for marketing or promotional materials/communication, we will require some time to process your withdrawal request. During this period of time you may still receive marketing or promotional materials/communication. Please note that even if you withdraw your consent for the receipt of marketing or promotional materials, we may still contact you for other purposes in relation to the accounts, facilities or Services that you hold or have subscribed to with Oobit.

YOUR CONSENT IS IMPORTANT 

  • When you request information or sign up for our Platform and Services, you may be required to provide us with your Personal Data. In doing so, you agree and consent to Oobit and its affiliates or related companies as well as our respective agents, business partners, authorised service providers and relevant third parties collecting, using, disclosing and/or sharing your Personal Data in accordance with this Privacy Policy.
  • You have the choice, at any time, not to provide your Personal Data or to withdraw your consent to Oobit processing your Personal Data. However, do note that failure to provide such Personal Data or a withdrawal of your consent for us to process your Personal Data may result in Oobit being unable to provide you with our Services in an efficient and effective manner.
  • If you should withdraw your consent to the processing or handling of your Personal Data in respect of any purpose which we may reasonably consider to be essential in order for us to provide you with the Services requested / applied for, we may not be in a position to continue to provide our Services to you or administer any contractual relationship which may be in place between us. Furthermore, we shall be entitled to treat such withdrawal as termination of your account and/or any agreement which you may have with us, without prejudice to any rights and remedies which we may have at law against you.
  • Notwithstanding the generality of the foregoing and for avoidance of doubt, upon the termination or expiry of your contractual relationship with us (howsoever caused), we may still continue using or disclosing your Personal Data as may be necessary, required, authorised or permitted for compliance with applicable law or as may be requested by the relevant regulatory bodies, government agencies, statutory boards, administrative bodies, authorities or law enforcement agencies to comply with any laws, rules, guidelines and regulations or schemes to which we may be subject, whether situated locally or overseas.
  • In addition, there may be circumstances under applicable laws where we are permitted to collect, process and disclose your Personal Data without your consent.

TO WHOM DO WE DISCLOSE YOUR PERSONAL DATA? 

7.1 Your Personal Data held by us shall be kept confidential. However, in order to provide you with effective and continuous Services, and for the purposes listed above (where applicable), your Personal Data may be disclosed to the following parties:

  • affiliates or related companies of Oobit;
  • companies providing services relating to insurance and/or reinsurance to Oobit;
  • agents, contractors or third party service providers who provide operational services to Oobit, such as courier services, telecommunications, information technology, payment, payroll, processing, training, survey, market research, storage, archival or other services to Oobit;
  • vendors and other third party service providers in connection with promotions, online campaigns, and Services offered by Oobit;
  • credit bureaus and credit reporting agencies;
  • any business partners, other financial institutions and their respective service providers;
  • our professional advisers such as financial advisors, auditors and lawyers;
  • relevant regulatory bodies, government agencies, statutory boards, administrative bodies, authorities or law enforcement agencies to comply with any laws, rules, guidelines and regulations or schemes to which Oobit may be subject, whether situated locally or overseas;
  • counterparties, billing organisations and their respective banks in relation to fund transfers, payments and drawing of cheques;
  • brokerage houses, fund houses, registrars, custodians, external banks and investment vehicles in relation to any custodial services and settlement processing;
  • external business, referral and charity partners in relation to the marketing and promotion of products, gift redemptions and corporate promotional events; and
  • any other party to whom you authorise us to disclose your Personal Data to.

7.2 In addition, to the extent that we may need to transfer Personal Data outside of Singapore, whether to our affiliates, related companies, business partners, authorized agents or third party service providers or simply to data storage facilities, we shall endeavour to do so in accordance with the Act to ensure that we provide a standard of protection to Personal Data so transferred that is comparable to the protection under the Act.

HOW DO WE PROTECT YOUR DATA? 

8.1 The security of your Personal Data is our priority. Oobit takes all necessary measures needed to safeguard Personal Data. We will use all reasonable efforts to protect your information in a highly secure data centre, adhering to strict computer security standards. We have put in place, privacy protection control systems designed to ensure that our customers’ information remain safe, secure and private. However, you should be aware that the use of the Internet is not entirely secure and for this reason we cannot guarantee the security or integrity of any Personal Data which is transferred from you or to you via the Internet.

8.2 Employee access is only limited to authorised employees who are fully trained in handling your Personal Data. These authorised personnel are required to ensure the confidentiality of your Personal Data and to respect your privacy at all times. Employees who have access to your Personal Data will be subjected to disciplinary action should they fail to observe this Privacy Policy and other guidelines, codes or policies which we may issue to them from time to time.

8.3 Should we disclose any of your Personal Data to our business partners, authorised agents or service providers, we will require them to appropriately safeguard the Personal Data provided to them.

HOW LONG MAY WE RETAIN YOUR PERSONAL DATA? 

  1. We will only retain your Personal Data for as long as necessary to fulfil the purpose(s) for which it was collected or to comply with legal, regulatory and internal requirements.

RETAINING AND DELETING PERSONAL DATA

 

10.1. This Section 10 sets out our data retention and deletion policies, which are designed to help ensure that we comply with our legal obligations in relation to the user’s right to be forgotten.

10.2. Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

10.3. Users may request the deletion of their account through our website at Oobit.com.

10.4. We will retain and delete your Personal Data as follows:

  • for all users who have deleted their account:
  • personally-identifiable analytics data shall be removed within 30 days of account deletion.
    • for users who have not conducted or initiated any trades or bitcoin transactions to their wallet, we will delete all Personal Data within 30 days after the approval of your account deletion request.
    • for users who have conducted or initiated any trades or sent or received any bitcoin transactions using their wallet and whose account deletion request has been approved by us, our data deletion policy is as follows:
  • your profile [and listings] will be removed after you delete your account.
  • your Personal Data, personal identification information, Corporate Information, Usage Data, trade information, and notification information will be deleted 12 months after you delete your account.
  • your transaction information will be removed 24 months after you delete your account, with the exception of available information on such transactions on the respective blockchain protocols (viz. bitcoin, ether, ripple etc.).

10.5 In some cases it is not possible for us to specify in advance the periods for which your Personal Data will be retained. In such cases, we will determine the period of retention based on the period we need to access the data for the provision of services, receiving payment, resolving your customer support issue or other issues or for any other auditing or legal reasons.

10.6 Notwithstanding the other provisions of this Section 10, we may retain your Personal Data where such retention is necessary for compliance with a legal obligation to which we are subject to, or in order to protect your vital interests or the vital interests of another natural person.

CHANGES TO PRIVACY POLICY 

  1. We may update our Privacy Policy from time to time to comply with changes in industry trends, legal and/or regulatory requirements, and we will notify you by posting a notice of such changes on our website at Oobit.com or by sending you a notification directly.

ACCURACY, ACCESS AND CORRECTION OF YOUR DATA 

12.1 You should ensure that all Personal Data submitted to us is complete, accurate, true and correct. Failure on your part to do so may result in our inability to provide you with access to the Platform and the Services you have requested / applied for.

12.2 If there are any changes to your Personal Data or if you believe that the Personal Data we have about you is inaccurate, incomplete, misleading or not up-to-date, please contact us using the contact details set out in Section 14 so that we may take steps to update your Personal Data.

12.3 You have the right to access your Personal Data. If you would like to request access to your Personal Data, please contact us using the contact details set out in Section 14 below. Please note that depending on the information requested we may charge a small fee. We may also take steps to verify your identity before fulfilling your request for access to your Personal Data. However, in exceptional circumstances, we reserve the right to deny you access to your Personal Data and may provide an explanation as required or unless permissible by applicable laws.

GOVERNING LAWS 

  1. Note that as we are a Singapore registered company, this Privacy Policy has been drafted solely in accordance with the laws of Singapore. We do not represent or warrant that this Privacy Policy complies with the privacy laws of any other jurisdiction and accordingly, you shall not construe this Privacy Policy as such.

QUESTIONS AND CONTACT INFORMATION

  1. If you need to contact us or have any questions on our Privacy Policy, you may contact us as follows: 

Email: dpo@oobit.com

Attention to: Data Protection Officer