Neopin Privacy Policy

NEOPIN PTE. LTD. ("we", "our", "us") value the information you have provided us or permitted us to collect. We strive to protect your privacy while providing you with the best service and experience we can provide. All such personal information in our possession is valued and is collected, used, disclosed and protected in accordance with the Singapore Personal Data Protection Act 2012 ("PDPA"). This Privacy Policy applies to all websites on which this Privacy Policy or a link to this Privacy Policy appears, as well as all our activities to the extent that you have been notified that such activities are subject to this Privacy Policy.

This Privacy Policy is intended to apply to all personal data submitted by you, third parties authorised by you via https://neopin.io, its sub-domains, and any other websites, media platforms, and applications operated by us (hereinafter collectively referred to as the "Platforms") and any personal data that we receive from other third parties.

By visiting or using any of the websites on which this Privacy Policy or a link to this Privacy Policy appears, or by signing up to use any of our services, including Crypto Finance, NFT (Non-Fungible Tokens), P2E (Play to Earn) and S2E (Service to Earn) services (hereinafter collectively referred to as the "Services"), you are deemed to agree to the terms of this Privacy Policy. Please review this Privacy Policy carefully prior to visiting or using any such websites, signing up for an account with us or otherwise providing any personal data.

• PERSONAL INFORMATION AND OTHER DATA WE COLLECT

  Personal data as defined in the PDPA refers to data about an individual who can be identified from either that particular data, or from that data and other information which we have or likely have access to. Personal data is collected where reasonably necessary for our functions and activities. Personal data that we may hold include the following:

  • (A) name, address and contact details;
  • (B) date of birth;
  • (C) NRIC number, FIN number, driver's license, passport number, or work permit number (to the extent permitted under applicable law);
  • (D) bank account details;
  • (E) NEOPIN Wallet account details;
  • (F) details of services provided to an individual by us;
  • (G) details of an individual's dealings with us, including telephone records, email and online interactions;
  • (H) details of online accounts on social-media platforms (such as Google or Facebook);
  • (I) details of transactions you enter into using the Services or via the Platforms;
  • (J) credit-related personal information;
  • (K) third-party wallet address and details;
  • (L) photos; and
  • (M) other personal data as may be provided by an individual from time to time.

  We do not hold information about your private key and mnemonic in our database. We strongly recommend that you save this information privately.

  Collection of personal data

  Wherever possible, we will collect personal data directly from you. We will only collect, use and disclose personal data with your consent, your deemed consent (subject to a notification period or otherwise) or as may be otherwise permitted under the PDPA or other applicable laws, such as for purposes of our legitimate interests, business improvement purposes (within our corporate group or otherwise), or research and development purposes benefiting the public.

  In addition to the personal data you provide to us, certain information related to you that is not considered personal data under the PDPA may also be collected. We collect this information to improve our website. Such non-personal data may include information such as your IP address, the internet browser you use, details of your interaction with our website and other types of non-personal data. We may also use “cookies” in order to track your usage of our services. You may choose to accept or decline the cookies by modifying your browser settings.

  When you access or use our Services, we automatically collect information about you. We collect log information about your use of the Services, including the type of browser you use, access times, pages viewed, your IP address and the page you visited before navigating to our Services. We collect information about the computer or mobile device you use to access our Services, including the hardware model, operating system and version, unique device identifiers, and mobile network information. Information Collected by Cookies and Other Tracking Technologies: We use various technologies to collect information, including cookies and web beacons. Cookies are small data files stored on your hard drive or in device memory that help us improve our Services and your experience, see which areas and features of our Services are popular and count visits. Web beacons are electronic images that may be used in our Services or emails and help deliver cookies, count visits and understand usage and campaign effectiveness. For more information about cookies and how to disable them, please see “Cookies” below.

• USE OF YOUR PERSONAL DATA

  We collect personal data from our users for various reasons. Without limitation, these purposes include:-

  • (A) providing and improving our Services which you have subscribed or purchased;
  • (B) to facilitate transactions and payments with us or via our Platforms;
  • (C) to understand and analyze how you use our Services;
  • (D) to communicate to you any marketing material;
  • (E) to communicate with you and provide customer support;
  • (F) supplying you with information or processing information that is relevant to your existing relationship with us;
  • (G) to verify information provided by you to process your registration as an account holder with us and/or your subscription to our Services;
  • (H) to process any complaints made by you;
  • (I) to carry out and comply with applicable anti-money laundering, counter terrorism, and sanction screening laws, regulations and requirements;
  • (J) for fraud prevention and detection; or
  • (K) in our sole discretion, in exceptional circumstances such as national emergency, security concerns, or other situations in which we deem that such disclosure is prudent and reasonable.
  
  

  We may, for the above purposes, contact you via mail, electronic mail, telephone, SMS, facsimile or other forms of communication through mobile applications. Should you wish to opt-out of our contact list for any reason, please refer to the below paragraph 7 for the relevant procedure.

• SHARING YOUR PERSONAL DATA

  In the course of providing our services and products to you, we may need to disclose your personal data with external organisations or individuals. The reasons for which we may disclose your personal data are set out under paragraph 2 above. The possible parties we may share your personal data with include other users of the Platforms, our group companies, our affiliates, partners, principals, third party service providers (for the purpose of providing us administrative or marketing support), advertisers, and governmental or regulatory authorities. If any of our businesses are sold or transferred to another entity, your personal data may be transferred along with the business.

  In the event that any of the above parties receiving your personal data are located or are operating outside of Singapore, we will take reasonable steps to ensure that the overseas recipient provides a standard of protection to your personal data so transferred that is comparable to the protection under the PDPA.

• THIRD PARTY LINKS

  Our Platforms may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. Please note that these websites and any services that may be accessible through them have their own privacy policies and that the Company does not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services. Please check these policies before you submit any personal data to these websites or use these services.

• SECURITY

  We will protect your personal data using industry standard precautions to prevent nauthorized access, collection, use, disclosure, copying, modification, or disposal of personal data in our possession or control. While the transference of electronic data over the internet has inherent risks, we use reasonable precautions to ensure your personal data is not subject to unnecessary risks. Examples of our reasonable precautions taken to protect your persona data include: -

  • (A) conducting quarterly self-audits to ensure that the use of personal data is proper;
  • (B) designating employees who will handle the personal data and limiting its use to those employees;
  • (C) establishing an internal data security procedure for the safe handling of personal data;
  • (D) controlling access to personal data by managing the access rights to the database system;
  • (E) employing an intrusion prevention system to prevent unauthorised access from the outside; and
  • (F) engaging Amazon Web Service (AWS), a cloud service, as user data storage.

• RETENTION

  We will retain your personal data for as long as necessary in order to fulfil the purpose for which it was collected, or as required by the relevant laws. Should we be required by any relevant laws to retain your personal data after the withdrawal of your subscription, we will store your personal data in a separate database where it would be preserved until such time the law requires. We may extend the retention of your personal data should any complaints be made by you on the use of your personal data prior to the withdrawal of your subscription for a period up to 3 years since the date of complaint being made.

  In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

• ACCESS, UPDATE, WITHDRAWAL OF CONSENT

  You may contact our Data Protection Officer if you subsequently decide to request access of, update or withdraw your consent for us to collect, use and/or disclose your personal data, or to request information relating to the use or disclosure of your personal data within the past year. For details on how to make such request, please contact us via the details provided under paragraph 11. Please note that subject to applicable law, we may not be able to accede to some of your requests, such as if they are frivolous or involve information subject to legal privilege. We will endeavour to respond within 30 days upon receipt of your request. Once your request to withdraw your personal data is accepted by our Data Protection Officer, we will proceed to remove your personal data from our service by: (1) permanently deleting any electronic files; and (2) destroying any physical documents which discloses your personal data.

• Cookies

  Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of our Services.

  What are Cookies?

  Cookies are small text files that are placed on your device when you visit a website. They are widely used to make websites work more efficiently and to provide information to the owners of the site.

  Types of Cookies We Use:

  • Essential Cookies:
    1. These cookies are necessary for the proper functioning of our website. They enable you to navigate our site and use its features.
  • Performance Cookies:
    1. We use performance cookies to collect information about how visitors use our website. This includes data about page visits, load times, and other website performance indicators. These cookies help us understand and improve the user experience.
  • Third-Party Cookies:
    1. We may also use third-party cookies, such as Google Analytics, to gather information about website performance. These cookies are provided by third-party service providers and are subject to their privacy policies.

  How We Use Cookies:

  We use cookies to:

  • Ensure the proper functioning of our website.
  • Collect information about website performance to analyze and improve user experience.
  • Compile aggregate data about site traffic and interactions to better understand user preferences.

  Your Cookie Choices:

  You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser settings to decline cookies if you prefer. However, this may prevent you from taking full advantage of our website.

  Data Security:

  We are committed to ensuring the security of your information. Cookies used for performance indicators do not contain personally identifiable information.

  Changes to this Cookie Policy:

  We may update this Cookie Policy from time to time. Any changes will be posted on this page with an updated effective date.

  Contact Us:

  If you have any questions about our Cookie Policy, please contact us at help@neopin.io. By using our website, you consent to the use of cookies as described in this policy.

• DATA BREACHES

  In the event of any data breach incidents, we will take reasonable and expeditious steps to assess nature of such breach and will make notifications to the Personal Data Protection Commission of Singapore (and, if required by applicable law, to affected individuals) from time to time as may be required. We will notify the Personal Data Protection Commission of Singapore as soon as practicable if and when we assess that a data breach has occurred which: (a) results in, or is likely to result in, significant harm to an affected individual; or (b) is, or are likely to be, of a significant scale (i.e., affecting 500 or more individuals).

• DATA PORTING

  We will, in accordance with the PDPA (and subject to the PDPA requiring the same), upon your request transmit a copy of your personal data retained by us to another organisation in a machine-readable format. Please note that subject to applicable law, we may not be able to accede to some of your requests, such as if they are frivolous or involve information subject to legal privilege.

• RIGHTS TO AMEND THIS PRIVACY POLICY

  We reserve the right to amend this Privacy Policy at any time. We will keep our updated Privacy Policy posted on our website, at https://neopin.io and date stamped. In the event that any of our changes result in material changes to your rights, advance notice of at least 30 days shall be given (either directly to you or by an announcement on any of the Platforms) before such changes become effective Your continued use of the Platform and acceptance of our services after any changes to this Privacy Policy constitutes your consent to any such changes, to the extent such consent is not otherwise provided.

• CONTACT US

  If you have comments or questions about this Privacy Policy, or wish to submit a request pursuant to paragraph 7 above to us, please contact our data protection officer (attn: Data Protection Officer) at: support@neopin.io(+65 86906170)

• EU DATA SUBJECTS ONLY

  Please note that we further strive to comply with the European Union’s General Data Protection Regulation (“GDPR”) to protect in particular the personal information of data subjects in the European Union. Notwithstanding the above, please note that when you provide personal data to us (or a third party on our behalf) it may accordingly be accessed and used in countries outside of the European Economic Area (“EEA”) . In relation to such transfers, you acknowledge that you have been made aware that (i) such countries may not be deemed to have an adequate level of protection for personal data as determined by the European Commission; (ii) some countries outside the EEA provide levels of protection of personal data which are substantially poorer than those of countries within the EEA and (iii) in respect of such countries it is possible that this personal data might be intercepted and accessed by governmental and other authorities / agencies in those countries.

• GOVERNING LAW AND JURISDICTION

  Nothing in this Privacy Policy shall limit your rights under the Personal Data Protection Act 2012 of Singapore, or any other data protection or privacy related law that is applicable to you. This Privacy Policy shall be governed by the laws of the Republic of Singapore and you agree to submit to the exclusive jurisdiction of the Singapore courts.