Applicability of this Policy
Personal Data We May Collect
- Contact information: Include but not limited to email addresses.
- Financial information: Include but not limited to Blockchain wallet addresses, crypto asset information, transaction history and trading data.
- Transaction information: Any information about the transaction which you’ve made on our Platform such as the type of transaction, transaction amount and timestamp.
- Communication: Include but not limited to feedbacks, questionnaires, survey responses and information provided to our support team via our official communication channels
- Online identifiers: Include but not limited to geographical location, browser fingerprints, browser type & version, and IP addresses
- Usage data: Include but not limited to user preferences and data collected via cookies or similar technologies
- Information from 3rd party sources: Include but not limited to information about you from any other sources as required or permitted by applicable law, such as public databases. We may combines the information collected in order to comply with our legal obligations and limit the use of our services in connection with fraudulent or any other illicit activities.
How We Collect Personal Data
Generally, Personal Data are collected in the following ways:
- when you activate an account on the Site in order to get access to the Platform;
- when you use our electronic services, or interact with us via the Site or use services on the Site;
- when you submit any form, including but not limited to application, declaration, proposal or referral forms;
- when you enter into any agreement or provide other documentation or information in respect of your interactions with or transactions on the Platform;
- 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;
- when you are contacted by, and respond to, our marketing representatives and agents and other service providers;
How We Use Information
Generally, SPROUTIE uses and discloses your Personal Data for the following purposes:
- responding to, processing and handling your complaints, queries, requests, feedback and suggestions;
- verifying your identity;
- create and update user accounts;
- processing transactions;
- managing the administrative and business operations of SPROUTIE and the Platform and complying with internal policies and procedures;
- facilitating business asset transactions (which may extend to any mergers, acquisitions or asset sales) involving SPROUTIE or any of its affiliates;
- matching of any Personal Data held which relates to you for any of the purposes listed herein;
- requesting feedback or participation in surveys, as well as conducting market research and/or analysis for statistical, profiling or other purposes for us to improve our products and services, understand customer behaviour, preferences and market trends, and to review, develop and improve the quality of our Platform and Services;
- including but not limited to preventing, detecting and investigating crime, fraud and other illicit activities;
- providing media announcements and responses;
- organising promotional events;
- in connection with any claims, actions or proceedings (including but not limited to drafting and reviewing documents, transaction documentation, obtaining legal advice, and facilitating dispute resolution), and/or protecting and enforcing our contractual and legal rights and obligations;
- complying with any applicable rules, laws and regulations, codes of practice or guidelines or to assist in law enforcement and investigations by relevant authorities; and/or
- any other purpose relating to any of the above.
These purposes may also apply even if you do not maintain any account(s) with us, or have terminated these account(s).
- In addition, where permitted under the applicable law, SPROUTIE may also collect, use and disclose your Personal Data for the following purposes (which we may describe in our documents and agreements as “Additional Purposes” for the handling of Personal Data):
- providing or marketing services, products and benefits to you, including promotions, loyalty and reward programs;
- 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 products and services, whether by SPROUTIE or other third parties;
- administering contests and competitions, and personalising your experience at SPROUTIE’s touchpoints;
- 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/or
- conducting market research, understanding and analysing customer behaviour, location, preferences and demographics for us to offer you products and services as well as special offers and marketing programmes which may be relevant to your preferences and profile.
- In relation to particular products or 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.
Disclosure of Personal Data
SPROUTIE may share your information in the following circumstances:
- With your consent: Sharing your personal information with others for their own marketing uses, and will be subjected to their privacy policies.
- To comply with legal obligations: To cooperate with the investigation of relevant government regulators, government ministries, statutory boards or authorities and/or law enforcement agencies, and other applicable governmental agencies, to comply with any directions, laws, rules, guidelines, regulations or schemes issued or administered by any of them, or we believe in good faith that the disclosure of personal information is necessary to prevent harm to another person, to report suspected illicit activities, to investigate violations of our User Agreement or any other applicable policies.
- With 3rd party service providers: Who help to facilitate business and compliance operations such as technology and marketing services.
- During a change to our business : Facilitating business asset transactions (which may extend to any mergers, acquisitions, dissolution, bankruptcy or asset sales) involving SPROUTIE or any of its affiliates subject to standard confidentiality arrangements.
- Anonymized Data: Sharing anonymized data with others for their own uses.
- We will take reasonable efforts to protect Personal Data in its possession or its control by making reasonable security arrangements to prevent unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks. However, we cannot completely guarantee the security of any Personal Data we may have collected from or about you, or that for example no harmful code will enter the Site (for example viruses, bugs, trojan horses, spyware or adware).
- You should be aware of the risks associated with using the Site.
- We are not responsible for the intentional or criminal acts of third parties such as hackers or “phishers.”
- While we strive to protect your Personal Data, we cannot ensure the security of the information you transmit to us via the Internet or when you access the Platform via mobile phones, and we urge you to take every precaution to protect your Personal Data when you access such platforms.
- We are not liable for any damages resulting from any security breaches, on unauthorised and/or fraudulent use of your account
To the extent prohibited by applicable laws, we do not allow the use of our Sites and Services by anyone below the age of 18 years old. We will take the necessary steps to close out any such accounts that was found to be unlawfully created with personal data, and with the possible extent of preventing user from continuing the use of our Services.
- In the event where you withdraw your consent to any or all use of your Personal Data, depending on the nature of your request, SPROUTIE may not be in a position to continue to provide its products or services to you or administer any contractual relationship already in place. This may also result in the termination of any agreements you have with SPROUTIE, and you being in breach of your contractual obligations or undertakings. SPROUTIE’s legal rights and remedies in such event are expressly reserved.