Rivol

Customer personal data is important to TokenPay Pte Ltd and it is our policy to respect the confidentiality of information and the privacy of individuals. This Policy articulates how TokenPay manages and protects customer data we hold in compliance with the Personal Data Protection Act in Singapore (the “Act”) which applies to all divisions in TokenPay Pte Ltd further details of which are available on our website https://rivo.network. We will also comply with local data protection and privacy laws in our operations out of Singapore, as and when required.

As used in this Notice: “customer” means an individual who:

(a) has contacted us through any means to find out more about any goods or services we provide, or

(b) may, or has, entered into a contract with us for the supply of any goods or services by us; and “personal data” means data, whether true or not, about a customer who can be identified:

We may collect and hold personal data of persons/entities including but not limited to:

Examples of such personal data include curriculum vitae, contact details, account information and your preferences, queries, requests and feedback.

The ways in which we may collect personal data include (but are not limited to) collecting directly or indirectly from you or your authorized representatives in the course of:

In general, we may use your personal data for the following purposes:

We will not collect NRIC or other national identification numbers (such as Birth Certificate numbers, Foreign Identification Numbers (FIN), Work Permit numbers and passport numbers), or copies of such documents, unless required by law or where it is necessary to accurately establish or verify the customer’s identity to a high degree of fidelity, to comply with relevant regulatory requirements.

We will only use, disclose and/or transfer customer personal data for the purposes that the customer has been notified of and consented to or which are permitted under applicable laws and regulations.

TokenPay will not sell, or give away personal data to third parties for commercial purposes without customer consent.

Depending on the product or service concerned, personal data may be disclosed or transferred to:

Where personal data is disclosed or transferred to organizations outside of TokenPay Pte Ltd who handle or obtain personal data as service providers to TokenPay Pte Ltd, we require such organizations to acknowledge the confidentiality of such personal data, undertake to respect any individual's right to privacy and comply with the Act and this Policy and use such personal data only for our purposes and otherwise follow our reasonable directions with respect to this data.

TokenPay does not collect sensitive information without the individual’s consent and unless it is specifically relevant and necessary for it’s primary purposes of conducting, improving, maintaining and developing a business relationship.

TokenPay Compliance department is responsible to oversee our management of personal data in accordance with the Act.

We regard breaches of your privacy very seriously and we have implemented measures to secure and protect your information, such as training our employees who handle your personal data to respect the confidentiality of such personal data and your privacy, storing personal data in a combination of secure computer storage facilities and paper based files and other records, taking steps to protect the personal data we hold from misuse, loss, unauthorised access, modification or disclosure.

However, you will appreciate that it is not for us to perfectly secure your personal data from cyber attacks, such as hacking, spyware and viruses. Accordingly, you will not hold us liable for any unauthorized disclosure, loss or destruction of your personal data arising from such risks.

The Act also requires us not to store personal data longer than is required by the data retention policy. We will cease to retain your personal data when we no longer require such personal data for the purposes we originally notified you of or for any business or legal needs.

TokenPay Compliance department is responsible to oversee our management of personal data in accordance with the Act.

We endeavour to ensure that the personal data we hold about you is accurate and up-to-date. We realize that such personal data changes frequently with changes of address and other personal circumstances. We encourage you to contact us as soon as possible in order to update any personal data we hold about you. Please complete the Personal Data Correction Form and send us your updated details. Our contact details are set out below. We may require you to verify your identity in such instances.

However, you will appreciate that it is not for us to perfectly secure your personal data from cyber attacks, such as hacking, spyware and viruses. Accordingly, you will not hold us liable for any unauthorized disclosure, loss or destruction of your personal data arising from such risks.

The Act also requires us not to store personal data longer than is required by the data retention policy. We will cease to retain your personal data when we no longer require such personal data for the purposes we originally notified you of or for any business or legal needs.

To make a request to access the personal data we hold about you, you may contact the TokenPay Pte Ltd compliance department in writing using the Request to Access Personal Data Form. We will require you to verify your identity and to specify what data you require. We may charge a fee to cover the cost of verifying the application and locating, retrieving, reviewing and copying any material requested. If the data sought is extensive, we will advise the likely cost in advance and can help to refine your request if required.

TokenPay Pte Ltd will employ off-chain approaches that store customer personal data in centralised databases / repositories, which will be encrypted and have the necessary access controls in place, while only writing representations of the personal data onto the block chain. Only a hash of the personal data or a hash of the link to the off-chain database would be written on-chain. Hashes are cryptographically generated strings that serve as irreversible, 1-1 representations of the hashed data. Any change in the underlying data will generate a completely different hash. This allows the hash to be used as a digital signature that, if written on-chain, will serve as an immutable verification of the underlying data’s integrity.

If you consider that any action of TokenPay Pte Ltd breaches the Act or this Policy, you can make a complaint to the TokenPay Pte Ltd Compliance department by completing the Complaint Form. We will endeavour to act promptly in response to a complaint.

We generally do not collect your personal data unless:

(a) it is provided to us voluntarily by you directly or via a third party who has been duly authorised by you to disclose your personal data to us (your “authorised representative”) after (i) you (or your authorised representative) have been notified of the purposes for which the data is collected, and (ii) you (or your authorised representative) have provided written consent to the collection and usage of your personal data for those purposes, or

(b) collection and use of personal data without consent is permitted or required by the PDPA or other laws.

We shall seek your consent before collecting any additional personal data and before using your personal data for a purpose which has not been notified to you (except where permitted or authorised by law).

We may collect and use your personal data for any or all of the following purposes:

(a) performing obligations in the course of or in connection with our provision of the goods and/or services requested by you;

(b)verifying your identity;

(c)responding to, handling, and processing queries, requests, applications, complaints, and feedback from you; managing your relationship with us; processing payment or credit transactions; sending your marketing information about our goods or services including notifying you of our marketing events, initiatives and promotions, lucky draws, membership and rewards schemes and other promotions; complying with any applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority; any other purposes for which you have provided the information; transmitting to any unaffiliated third parties including our third party service providers and agents, and relevant governmental and/or regulatory authorities, whether in Singapore or abroad, for the aforementioned purposes; and any other incidental business purposes related to or in connection with the above.

We may disclose your personal data: (a) (b) 7. where such disclosure is required for performing obligations in the course of or in connection with our provision of the goods or services requested by you; or to third party service providers, agents and other organisations we have engaged to perform any of the functions listed above for us.

The purposes listed in the above clauses may continue to apply even in situations where your relationship with us (for example, pursuant to a contract) has been terminated or altered in any way, for a reasonable period thereafter (including, where applicable, a period to enable us to enforce our rights under any contract with you).

The consent that you provide for the collection, use and disclosure of your personal data will remain valid until such time it is being withdrawn by you in writing. You may withdraw consent and request us to stop using and/or disclosing your personal data for any or all of the purposes listed above by submitting your request in writing or via email to our Compliance department at the contact details provided below. Upon receipt of your written request to withdraw your consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us. In general, we shall seek to process your request within ten (10) business days of receiving it. Whilst we respect your decision to withdraw your consent, please note that depending on the nature and scope of your request, we may not be in a position to continue providing our goods or services to you and we shall, in such circumstances, notify you before completing the processing of your request. Should you decide to cancel your withdrawal of consent, please inform us in writing in the manner described in clause 8 above.

Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclose without consent is permitted or required under applicable laws.

If you wish to make

(a) an access request for access to a copy of the personal data which we hold about you or information about the ways in which we use or disclose your personal data, or

(b) a correction request to correct or update any of your personal data which we hold about you, you may submit your request in writing or via email to our Compliance department at the contact details provided below.

Please note that a reasonable fee may be charged for an access request. If so, we will inform you of the fee before processing your request. We will respond to your request as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days after receiving your request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to your request. If we are unable to provide you with any personal data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the PDPA).

To safeguard your personal data from unauthorized access, collection, use, disclosure, copying, modification, disposal or similar risks, we have introduced appropriate administrative, physical and technical measures such as up-to-date antivirus protection, encryption and the use of privacy filters to secure all storage and transmission of personal data by us, and disclosing personal data both internally and to our authorised third party service providers and agents only on a need-to-know basis. You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.

We generally rely on personal data provided by you (or your authorised representative). In order to ensure that your personal data is current, complete and accurate, please update us if there are changes to your personal data by informing our Compliance department in writing or via email at the contact details provided below.

We will cease to retain your personal data, or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purpose for which the personal data was collected, and is no longer necessary for legal or business purposes.

As a general policy requirement, both customer personal data and customer transaction data will be held for a minimum period of 5 years, after account closure or termination of relationship.

This Notice applies in conjunction with any other notices, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your personal data by us. We may revise this Notice from time to time without any prior notice. You may determine if any such revision has taken place by referring to the date on which this Notice was last updated.

We generally do not transfer your personal data to countries outside of Singapore. However, if we do so, we will obtain your consent for the transfer to be made and we will take steps to ensure that your personal data continues to receive a standard of protection that is at least comparable to that provided under the PDPA.

This Policy will be reviewed from time to time to take account of new laws and technology, changes to our operations and practices and the changing business environment.

Our website may contain links to websites operated by third parties. If you visit such third party websites, this Personal Data Protection Policy may not apply.