🕵️Privacy Policy
We value and respect your right to privacy, and to this end are committed to protecting your personal data provided to us directly or indirectly. This privacy policy sets out our commitment and explains in detail what information we may gather from your visit to our platform and, why and how your personal data may be processed when you use our services.
This policy (the Policy) outlines how we collect, use, store and disclose your personal data. Please take a moment to read about how we collect, use and/or disclose your personal data so that you know and understand the purposes for which we may collect, use and/or disclose your personal data. By accessing the website at https://samudai.xyz (the Website) and the mobile application at https://app.samudai.xyz, you agree and consent to Samudai Technologies Pte. Ltd(the Company), its related corporations, business units and affiliates, as well as their respective representatives and/or agents (collectively referred to herein as us, we or our), to, collect, use, disclose and share amongst themselves the personal data/information and to disclose such personal data/information to relevant third-party providers. This policy supplements but does not supersede nor replace any other consent which you may have previously provided to us nor does it affect any rights that we may have at law in connection with the collection, use and/or disclosure of your personal data. We may from time to time update this Policy to ensure that this policy is consistent with our future developments, industry trends and/or any changes in legal or regulatory requirements. Subject to your rights at law, the prevailing terms of this policy shall apply. For the avoidance of doubt, this Policy forms part of the terms and conditions governing your relationship with us and should be read in conjunction with such terms and conditions.
This policy describes how the company will collect, use, disclose, process and manage your personal data, and will apply to any individual’s personal data which is in our possession or under our control.
By using the Service, you agree to the collection of data and usage of information in accordance with this Privacy Policy.
1.DEFINITIONS.
“Cookies” means small pieces of data stored on your device.
“Device” means any device that can access the services.
“Person” means an individual, association, partnership, corporation, company, future proposed company, other corporate body, trust, estate, and any form of organisation, group, or entity (whether or not having separate legal personality)
“Personal Data” means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession)
“Service” means all the offerings at https://samudai.xyz, the website and the app at https://app.samudai.xyz operated by the company.
“Usage Data” means the data collected automatically, either generated by the use of the Services or from the services infrastructure itself.
“Users” means any person who is the ultimate user of the services.
“Website” refers to https://samudai.xyz and its related subdomains.
2. WHAT PERSONAL DATA IS COLLECTED BY SAMUDAI?
2.1. “Personal data” means data, whether true or not, about an individual who can be identified (i) from that data, or (ii) from that data and other information to which the organisation has or is likely to have access. Some examples of personal data that the company may collect are:
a. personal particulars (e.g., name, contact details, residential address, date of birth, identity card/passport details, social media handles and other social media profile information);
b. financial details (e.g., income, expenses, credit history and/or credit card and bank information);
c. information about your use of our services and the website;
d. usernames and password, third party account credentials (such as your Facebook login credentials, Google login credentials) and IP address;
e. banking information (e.g., account numbers and banking transactions);
f. private or public cryptographic key relating to addresses on distributed ledger networks and/or similar information; and/or
g. personal opinions made known to us (e.g., feedback or responses to surveys)
h. private or public cryptographic key relating to addresses on distributed ledger networks and/or similar information; and/or
i. personal opinions made known to us (e.g., feedback or responses to surveys).
2.2. Personal data may be collected when you interact with our services or use the website, or may be received by the company from third-party databases or service providers that provide business information.
2.3. Third Party Service Providers and Partners. We engage third party service providers and partners to provide us with the information, and we also use publicly available sources, to supplement our user account information to help improve personalization of our services. For example:
2.4. Public and Social Network Sources. We may collect or obtain your personal data from publicly accessible sources like corporate websites, business listings, or social networking platforms. You can opt-out of the third parties’ (such as a social media network or advertiser platform) collection and use of information for ad targeting by updating your account and settings with the third party or by following the instructions regarding Tracking Technologies described in the paragraph below.
3. PURPOSE FOR COLLECTION, USE AND DISCLOSURE OF YOUR PERSONAL DATA; -
Samudai may collect, use and/or disclose your personal data for its business purposes, including operations for these purposes. These may include, without limitation, the following:
Developing and providing facilities, products or services (whether made available by us or through us), including but not limited to:
sale of digital tokens or virtual currencies;
acting as intermediaries through any blockchain, network or platform developed or managed by us;
recording and/or encryption on any blockchain, network or platform developed or managed by us;
promoting advertisements or marketing material, whether from us or third parties;
various products and/or services (whether digital or not, and whether provided through an external service provider or otherwise);
providing, managing or accessing digital wallets for holding digital assets;
making payments for participation in any blockchain, network or platform developed or managed by us (as applicable);
various products and/or services related to digital assets;
transactions and clearing or reporting on these transactions;
assessing and processing applications, instructions, transactions, or requests from you or our customers.
Your information in relation to your usage of services through your device such as your IP address, the type of device you use to access our platform, device information, browser type, information about your browser, date and time you visit our platform, volume of data transmitted and network operator. This information will either be directly obtained by platform or through third party service providers.
For promoting advertisements or marketing material, whether from us or third parties.
Client relationship management purpose, analyse the services you may be interested in, for internal administrative and operational processes.
We may also send invitation and information from the makers about events, publications.
We would collect analytics for the purposes of developing or improving our services, security, service quality, and advertising strategies.
We ensure that our interface and/or platform is seamlessly accessible for all users around the world, except users in the prohibited jurisdictions.
Communicating with you, including providing you with updates on changes to products, services and banking facilities (whether made available by us or through us) including any additions, expansions, suspensions and replacements of or to such products, services and banking facilities and their terms and conditions.
Managing our infrastructure and business operations and complying with internal policies and procedures
Responding to queries or feedback
Addressing or investigating any complaints, claims or disputes.
Verifying your identity for the purposes of providing facilities, products or services, which would require comparison of your personal information against third party databases and/or provision of such information to third party service providers.
Conducting credit checks, screenings or due diligence checks as may be required under applicable laws, rules, regulations or directives.
Complying with all applicable laws, regulations, rules, directives, orders, instructions and requests from any local or foreign authorities, including regulatory, governmental, tax and law enforcement authorities or other authorities.
Monitoring services provided by or made available through us on the platform.
We may also use personal data for purposes set out in the terms and conditions that governs our relationship with you.
4. HOW WE USE PERSONAL INFORMATION: -
We utilise the personal data we gather through the services in the following ways as required:
For providing the services: We use personal information to operate, maintain, and provide features of the services.
For communicating with you: We use personal information to contact you for administrative and informational purposes, such as to respond to your inquiries, or to invite you to join the services.
For understanding and improving the services: We use personal information to understand and analyse the usage trends and preferences of our users in order to improve the services, and to develop new products, services, features, and functionalities.
For compliance with regulations: We use personal information to comply with financial regulations, including verifying your identity by comparing the personal information you provide against third-party databases and public records. We may use the information we collect to investigate or address claims or disputes relating to use of our services, or as otherwise allowed by applicable laws or as requested by regulators, government entities, and official inquiries.
For safety and security: We may use your information to help maintain the safety, security and integrity of you and our services, including to protect, investigate and deter against fraudulent, unauthorised, or illegal activities; monitor and verify identity or service access, and combat malware and security risks; perform internal operations necessary to provide our services, including to troubleshoot software bugs and operational problems; and enforce our agreements with third parties, and address violations of our terms of use or agreements for other Services.
Other business purposes: We use personal information for compliance, risk management, and other business purposes, such as for applicable laws and regulations, fraud monitoring, and prevention.
5. TRACKING COOKIES DATA: -
5.1. When you access our website and the app, we, or companies we hire to track how our website is used, may place small data files called cookies on your computer or other device. For example, we send a "session cookie" to your computer any time you log in to your account. This type of cookie helps us to recognize you if you visit multiple pages on our site during the same session, so that we don't need to ask you for your password on each page. We use these technologies to recognize you as a user, customise content and advertising, measure promotional effectiveness, and collect information about your computer or other access devices to mitigate risk, help prevent fraud, and promote trust and safety.
5.2. You may set up your web browser to block cookies from monitoring your website visit. You may also remove cookies stored from your computer or mobile device. However, if you do block cookies, you may not be able to use certain features and functions of our website and the app.
5.3. Types of cookies we use: Some of the cookies we use are first-party cookies, which are created by us to help make Samudai work properly and analyse usage. We also allow certain third-party providers to place third-party cookies to enable third-party features or functionalities or to assist us with our analytics and advertising activities.
a. Strictly necessary cookies: These cookies are strictly necessary to provide you with certain features. For example, these cookies allow you to access secure areas that require registration and set your privacy preferences. Because these cookies are essential to providing services to you, they cannot be disabled.
b. Performance Cookies (also commonly known as Analytics Cookies): These cookies allow us or our third-party analytics providers to collect information and statistics on use of our services by you and other visitors. This information helps us to improve our services and products for the benefit of you and others.
c. Functionality Cookies: These cookies provide enhanced functionality, providing chat support, allowing you to more easily complete forms, personalising content to your preferences, and selecting your communications preferences. If you do not enable these cookies, or choose to disable them in the future, that could impact your ability to use certain features.
d. Targeting Cookies: These cookies, provided by our third-party advertising partners, collect information about your browsing habits, as well as your preferences for various features and services. They also provide us with auditing, research, and reporting to know when advertising content has been displayed and how successful the content has been. This information allows us and our third-party advertising providers to display relevant advertising content.
e. Social media cookies: These cookies are used when information is shared through a social media sharing button (such as a “like” button), or when you link your account or engage with our content on or through a social networking site such as Facebook, Twitter, or Snapchat.
6. YOUR RIGHTS: -
6.1. This Privacy Policy grants you certain rights with respect to your personal data as set out below:
Right to Consent: By using our Services and/or on providing your personal data, you agree to allow us to collect, hold, use, and disclose such data in accordance with this privacy policy. You have the right not to consent/provide us any such data, however, if you do so, we may not be able to provide you with the services, or the products and/or services offered through the Platform.
Access: You have the right to request details of your personal data from us.
Data Erasure: You can request for deletion of your personal data. However, if such data is required for the provision of the services, you may be required to delete your profile and/or may not be able to use our services.
Correction: If you believe any personal data held by us is inaccurate, obsolete/outdated, incomplete, irrelevant, or misleading, please contact us to correct such information, or update the same via your account, if allowed.
Concerns and Queries: If you have any concerns and queries on how we process, handle, and keep your personal data, please contact us with full details of your concerns and queries. We will take appropriate steps to address them.
Unsubscribe: To unsubscribe from our e-mail or to opt-out of any communications, please contact us at the address provided in this privacy policy or where available, use the opt-out option.
7. ADDITIONAL RIGHTS-
7.1. General Data Protection Regulation (GDPR) Data Protection Rights-
7.1.1. The company invites you to be fully aware of all your personal data protection rights if you are a resident where the GDPR is applicable. Every such consumer is entitled to the following:
a. The right to access - The consumer has the right to request copies of your personal data. The company may charge additional costs for the same.
b. The right to rectification - The consumer has the right to request that we correct any information you believe is inaccurate. the consumer additionally has the right to request that we complete the information the consumer believes is incomplete.
c. The right to erasure - The consumer has the right to request that the company erases your personal data, under certain circumstances.
d. The right to restrict processing - The consumer has the right to request that the company restricts the processing of your personal data, under certain circumstances.
e. The right to object to processing - The consumer has the right to object to the company’s processing of your personal data, under certain circumstances.
f. The right to data portability - The consumer has the right to request that the company transfers the data that the company has collected to another company/ organisation, or directly to you, under certain circumstances.
If the GDPR is applicable to you, you may make a request, and the Company will endeavour to respond to you within the timeline as per applicable law.
7.2. Data Processing Agreements
7.2.1. Under the GDPR, “data controllers” (i.e. entities that determine the purposes and means of processing data) are required to enter into agreements with other entities that process data on their behalf (called “data processors”). Samudai offers its customers who are controllers of EU personal data. This includes Samudai’s commitment to process personal data consistent with the instructions of the data controller.
7.2.2. Privacy Documentation
At its core, the GDPR is focused on transparency, fairness, and accountability. Accordingly, the law requires organizations to maintain documentation about their privacy practices and their decisions about how they handle individuals’ personal data. Samudai shares the GDPR’s commitment to these principles and has included within its ongoing GDPR compliance program documentation about its data collection and processing activities, and the various policies and guidelines it follows pursuant to the GDPR. You can learn more about how Samudai collects, uses, and discloses personal data by visiting Samudai’s Privacy Policy.
7.2.3. Data Security
The GDPR requires organizations to use appropriate technical and organizational measures to protect the security, confidentiality, and integrity of personal data. This means that an independent third party has both validated our processes and practices with respect to these three trust services criteria and confirmed our ability to maintain compliance with the controls we have implemented. We have likewise implemented a variety of safeguards to protect the security of our platform, including encrypting web connections to protect data transmissions, replicating our databases to support reliability of the platform, and controlling access to our facilities and office network. Samudai also offers customers the ability to use additional security controls to further enhance the security of their teams’ data.
7.3. California Consumer Privacy Act
7.3.1. The CCPA, which comes into force on January 1, 2020, is a law that provides California consumers certain rights with respect to their personal information. Specifically, the law requires that businesses subject to the statute grant consumers the ability to request access to and deletion of their data, and the ability to opt out of “sales” of their personal information. The law also restricts how service providers that process personal information on behalf of a business may use that information.
7.3.2. Samudai does not sell its customers’ or users’ personal information. Where a business subject to the CCPA has entered into a services or subscription agreement with Samudai, Samudai will also act as a service provider to that business. Specifically, Samudai will process such customers’ personal information only for the purposes set forth in the applicable agreement, and will cooperate with customers to fulfill deletion or access requests.
7.3.3. Ongoing Compliance and Communication Both the GDPR and CCPA’s requirements are comprehensive, but the law and regulatory guidance continues to evolve when it comes to privacy and data protection – and not just in the EU or the United States. As data protection authorities and regulators interpret and issue guidance on the GDPR, CCPA, and other currently existing data protection laws around the world and as countries pass new data protection laws, we will continue to follow these developments closely and evaluate our program for any changes or enhancements as needed.
7.4. Family Educational Rights and Privacy Act
The Family Educational Rights and Privacy Act (FERPA) is a federal law that requires academic institutions like colleges and universities to protect the privacy of students' educational records. Samudai enables our customers to comply with FERPA by ensuring personal data is kept secure and only used to provide our services as described in our Terms of Service and Privacy Policy. Samudai contractually commits to not disclosing customer data except as directed by the contracting academic institution, as allowed by our terms, or as required by law.
7.5. Act on the Protection of Personal Information
7.5.1. The Act on the Protection of Personal Information (APPI) is the primary data protection law in Japan that regulates the protection of personal information. It applies to business operators handling personal information of individuals in Japan. The APPI has been amended since it was originally enacted in 2003, with the most recent amendments coming into effect April 1, 2022.
7.5.2. Similarly, to the distinction between “data controllers” and “data processors” under the GDPR, the APPI makes a distinction between “business operators” - or entities with the authority to control and make decisions about retained personal information (i.e. Samudai’s customers) and third-party service providers handling personal information on behalf of a business operator (i.e. Samudai).
7.5.3. The APPI also imposes restrictions on cross-border transfers of personal information outside of Japan. Personal information may be transferred to overseas recipients if there are contractual agreements in place that ensure compliance with data protection standards in Japan.
7.5.4. Samudai is committed to processing and safeguarding personal information as required by the APPI and its amendments.
8. LINKS TO OTHER SITES: -
The platform may contain links to other websites. That website s not governed by this privacy policy. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. Please read the privacy policy and terms and conditions of such websites before using such websites or the app. We have no control over and shall not be responsible for the content, privacy policies or practices of any third-party sites or services.
9. FOR MARKETING AND ADVERTISING:
9.1. We may use your personal data to offer you services, including special rewards that may be of interest to you or for which you may be eligible. Such marketing messages may be sent to you in various modes including but not limited to electronic mail, direct mailers, short message service, facsimile and other mobile messaging services. In doing so, we will comply with all applicable data protection and privacy laws.
9.2. In respect of sending telemarketing messages to your telephone number via short message service, facsimile and other mobile messaging services, please be assured that we shall only do so if we have your clear and unambiguous consent.
9.3. For marketing and advertising the project onto various launchpads and in market, the company and its subsidiary venture, shall be on board to co-ordinate the productions and preparation of all advertising, promotional and general publicity materials including artwork, photography, brochures, videos and printing and arrangement for the display, publications, transmission or telecast of the said advertising, promotional and publicity materials in various advertising media.
9.4. You may at any time request that we stop contacting you for marketing purposes via selected or all modes. To find out more on how you can change the way we use your personal data for marketing purposes, please contact us. Nothing in this section shall vary or supersede the terms and conditions that govern our relationship with you.
10. DATA RETENTION: -
You are aware that your personal information will continue to be stored and retained by us or by a third-party processor engaged by us if any KYC verification takes place while using or accessing our platform and the services, and/or after the usage of the services for a reasonable period of time stipulated under the applicable law.
11. QUERIES, ACCESS/CORRECTION REQUESTS AND WITHDRAWAL OF CONSENT: -
If you:
have queries about our data protection processes and practices;
wish to request access to and/or make corrections to your personal data in our possession or under our control; or
wish to withdraw your consent to our collection, use or disclosure of your personal data,
please submit a written request (with supporting documents, (if any) to our Compliance Officer at: compliance@samudai.xyz. Our Compliance Officer shall endeavor to respond to you within 30 days of your submission. Please note that if you withdraw your consent to any or all use or disclosure of your personal data, depending on the nature of your request, we may not be in a position to continue to provide our services or products to you or administer any contractual relationship in place. Such withdrawal may also result in the termination of any agreement you may have with us. Our legal rights and remedies are expressly reserved in such an event.
We may charge you a fee for processing your request for access. Such a fee depends on the nature and complexity of your access request. Information on the processing fee will be made available to you.
12. DATA SECURITY: -
Without prejudice to the inherent risk of sharing and accessing data over the internet, we will use appropriate security measures (organisational and technical) to prevent your personal data from being accidentally lost, used, damaged, or accessed in an unauthorised or unlawful manner, altered, or disclosed. In addition, we will allow access to your personal data only to those employees, agents, contractors and other third parties who have a legitimate business need to know and are subject to a duty of confidentiality. Despite the fact that we have implemented appropriate security measures, we cannot guarantee that your personal data collected will not be shared/disclosed in a way that is inconsistent with this Privacy Policy.
13. CHANGES TO OUR PRIVACY POLICY: -
We reserve the right to update this privacy policy at any time and at our sole discretion. Any changes to or modifications of this privacy policy shall be in effect as of the “last updated date” referred to at the top of this page. We encourage you to periodically review this privacy policy. If you do not agree, either partially or wholly with the revised privacy policy, you should discontinue accessing or using our services. Your continued access to and use of our services after any changes to this privacy policy constitutes your consent to any changes and your agreement to continue using the services.
14. ACCEPTANCE OF THE PRIVACY POLICY: -
By accessing, connecting, clicking on, using, or engaging in Our Services, you indicate and confirm that you have consented and agreed to the terms of this Privacy Policy. We will not use your Personal Information for any other purpose that has not been covered in this Privacy Policy or the T&C’s without providing you prior intimation or obtaining your consent. If you do not agree, either partially or wholly, to this Privacy Policy, you must immediately discontinue accessing, connecting, using, or engaging in our services and the platform. This Privacy Policy does not apply to services offered by other companies or service providers or other websites inked from our platform.
15. MINOR: -
As provided in our T&C’s, our services are not intended for anyone under the age of 18 or minor under the law of the country where the services are accessed (“Minor”). We do not intend to or knowingly collect any personal data related to a minor. If you believe that personal data of any minor has been collected or provided to us, please contact us.
16. CONTACT DETAILS: -
For queries on any aspect of this privacy policy or to provide any feedback, please contact our office at: compliance@samudai.xyz.
Last Updated on 2nd September 2022
Last updated