1. Introduction
GOLBEX is committed to protecting customer privacy and takes its responsibility regarding the security of customer information very seriously. We are clear and transparent about the information we are collecting and what we will do with that information.

Unless otherwise defined, all capitalised terms shall have the same meaning as ascribed to it in GOLBEX's Terms of Use (golbex.com/legal). This Privacy Policy supplements our Terms and sets out the processes and procedures by which the information is collected and received by us in the course of your use of our Services.

This Privacy Policy sets out the following, amongst other things:

  • What personal data we collect and process about you in connection with your relationship with us as a User and through your use of our website, mobile applications and online services;
  • Where we obtain the data from;
  • What we do with that data;
  • How we store the data;
  • Who we transfer/disclose that data to;
  • Your access to personal data;
  • How we deal with your data protection rights; and
  • How we comply with the data protection rules.
All personal data is collected and processed in accordance with the Personal Data Protection Act 2012 of Singapore ("PDPA").
2. Information we collect
Personal data means any information (whether true or not) relating to you which allows us to identify you, such as your name, contact details, payment details and information about your access to our website.

We may collect personal data from you when you:
(a) use our Services (either directly or indirectly through our trusted third party partners);
(b) create an Account;
(c) use our Site and/or App and other websites accessible through our Site and/or App;
(d) participate in a survey or competition on our Site or App; or
(e) contact us.

Specifically, we may collect the following categories of information:
a. Name, home address, e-mail address, telephone number, passport or other recognized personal ID card numbers and details, credit/debit card or other payment details, cryptocurrency wallet information;

b. Advance User Information, which includes your name, nationality, date of birth, gender, passport or ID number, expiry date and country of issue;
c. Transaction history and data analytics, including information related to your Transactions;
d. Information about your use of our trusted partners' products and services (if any);
e. Information about your use of our Site and/or App;
f. The communications you exchange with us or direct to us via letters, emails, chat service, calls, and social media; and
g. Location, including real-time geographic location of your computer or device through GPS, Bluetooth, and your IP Address, along with crowd-sourced Wi-Fi hotspot and cell tower locations, if you use location-based features and turn on the Location Services settings on your device and computer.

Personal details about your physical or mental health, alleged commission or conviction of criminal offences are considered "sensitive" personal data under applicable data protection laws. We will process any such data only if you have given your explicit consent, or it is necessary, or you have deliberately made it public.

At all times, you are not under any obligation to provide the information to us. However, in the event that you choose to withhold certain information or to revoke permission for us to receive the information, this may result in us being unable to provide certain aspects of our Services to you.

In the event that you provide us with any information relating to a third party (e.g. information of your spouse, children, parents, and/or employees), you represent and warrant to us that you have sought for and obtained the consent of the relevant third party to provide us with their information for the respective purposes.

3. How we use the information we collect
Your data may be used for the following purposes:

a. Providing products and services you request: we use the information you give us to perform the Services;
b. Contacting you: we send you communications about the Services and any changes to such Services. These communications are not made for marketing purposes and cannot be opted-out of;
c. Credit or other payment card verification/screening: we use your payment information for accounting, billing and audit purposes and to detect and/or prevent any fraudulent activities;
d. Administrative or legal purposes: we use your data for statistical and marketing analysis, systems testing, customer surveys, maintenance and development, or in order to deal with a dispute or claim. Note that we may perform data profiling based on the data we collect from you for statistical and marketing analysis purposes. Any profiling activity will be carried out with your prior consent only and by making best endeavours to ensure that all data it is based on is accurate. By providing any personal data you explicitly agree that we may use it to perform profiling activities in accordance with this Privacy Policy;
e. Security, health, administrative, crime prevention/detection: we may disclose your information to government authorities or enforcement bodies for compliance with legal requirements; and
f. Customer Services communications: we use your data to manage our relationship with you as our customer and to improve our services and enhance your experience with us.

We will process your personal data where we have a legal basis to do so. The legal basis will depend on the reasons we have collected and need to use your personal data for.

In most cases we will need to process your personal data so that we are able to provide you our Services.

4. How we store your data
We will not retain your data for longer than is necessary to fulfill the purpose it is being processed for. To determine the appropriate retention period, we consider the amount, nature and sensitivity of the personal data, the purposes for which we process it and whether we can achieve those purposes through other means.

We must also consider periods for which we might need to retain personal data in order to meet our legal obligations or to deal with complaints, queries and to protect our legal rights in the event of a claim being made.

When we no longer need your personal data, we will securely delete or destroy it. We will also consider if and how we can minimize over time the personal data that we use, and if we can anonymise your personal data so that it can no longer be associated with you or identify you, in which case we may use that information without further notice to you.

We follow strict security procedures in the storage and disclosure of your personal data, and protect it against accidental loss, destruction or damage. The data you provide to us is protected using SSL technology. SSL is the industry standard method of encrypting personal information and credit card details so that they can be securely transferred over the Internet.

All payment and Transaction details are transmitted over SSL across dedicated network infrastructure and stored in compliance with Payment Card Industry Data Security Standards (PCI DSS).

We may disclose your information to third parties for the purposes set out in this Privacy Policy. We require all third parties to have appropriate technical and operational security measures in place to protect your personal data, in line with the PDPA.

5. Who we disclose/transfer your data to
Your personal data may be shared with the following third parties for the purpose(s) described in this Privacy Policy:

a. Government authorities, law enforcement bodies and regulators for compliance with legal and regulatory requirements;
b. b. Service providers we are using to run our business including but not limited to call centers providing assistance to our customers, cloud service and e-mail marketing service providers assisting our marketing team with running customer surveys and providing targeted marketing campaigns;
c. Credit and debit card companies which facilitate your payments to us, and anti-fraud screening, which may need information about your method of payment to process payment or ensure the security of your payment transaction;
d. Legal and other professional advisers, courts and law enforcement bodies in all countries we operate in in order to enforce our legal rights in relation to our contract with you; and
e. Potential partners, investors and other parties in the event that we are engaging in discussions and/or negotiations with such parties regarding a potential business partnership, collaboration, joint venture or otherwise in furtherance of our business.

You acknowledge, agree and consent to us disclosing certain of your personal information (e.g. name, email address, age, gender, marital status, employer, industry, geographical location) to third parties in the furtherance of our business, subject to us (where possible) having entered into similar privacy policies with them. [KLG to Client: What personal data will you be requesting?]

We also collect non-personal information, being data in a form that does not permit direct association or identification of any specific individual. We may collect, use, transfer and disclose non-personal information for any purpose.

In particular, we may disclose and/or provide data and aggregate statistics (including aggregate information derived from your personal information) about Users of our Services and sales to prospective partners, advertisers, sponsors and other reputable third parties in order to describe our Services, deliver targeted advertisements or for other lawful purposes, but other than as set out above, such data and statistics will not include information which can be used to identify you.

Where we transfer your personal data outside of Singapore, we offer the same level of protection awarded by PDPA to the data transferred outside of Singapore.

You have the right to make a complaint at any time to GOLBEX in respect of this Privacy Policy.
6. Access to your personal data
Subject to applicable laws, you may request information about whether we hold personal information about you, and, if so, what that information is and why we are holding/using it.

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

Where you have provided personal information about yourself to us, the responsibility falls on you to provide us with accurate, not misleading, complete and up-to-date information about yourself, and to update this personal information as and when such information becomes inaccurate, misleading, incomplete or out-of-date.

In the event that you wish to:

(a) apply for a copy of the information we possess about you; or
(b) withdraw the consent you previously provided to us to use, collect or disclose the information we hold about you.

please contact our Personal Data Protection Officer whose contact details are set out in paragraph 9 below.

7. Changes to this Privacy Policy
Our Privacy Policy may change from time to time and any changes to the statement will be communicated to you by way of an e-mail or a notice on our Site and/or App. Please note that it is your responsibility to review and take note of the changes which we make to this Privacy Policy. At all times, your continued use of our Services constitutes your acceptance of the updated Privacy Policy, as the case may be.
8. Third party sites and resources
Our Services may, from time to time, contain links to external sites or resources which are operated by third parties. Do note that we have no control over the content and privacy practices of such sites or resources. You are strongly advised to review the privacy policies of these sites and resources operated by third parties and understand how your information may be used by those third parties.
9. Contact us
If you have questions or concerns regarding this Privacy Policy, or if you have a complaint, you should contact us writing to: support@golbex.com
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© 2018 GOLBEX
a pioneer delivering transparency to the cryptocurrency exchange market