PLEASE READ THIS PRIVACY POLICY CAREFULLY BEFORE USING THIS WEBSITE/APPLICATION.
1. INFORMATION ABOUT THE COMPANY
1.1 Sovereign Wallet Network Pte. Ltd is a private limited company incorporated under Singaporean law with registration number 201538998Z (the "Company").
1.2 The Company’s registered address is 1 Fullerton Road, #02-01, One Fullerton, Singapore 049213.
1.3 The Company is committed to protecting and respecting your privacy when you use the Company’s website at www.sovereignwallet.network (the “Site”) and/or the Company’s MUI MetaWallet application (the “MUI MetaWallet App ”)
(together, the “Online Tools”).
2. SCOPE OF PRIVACY POLICY
2.1 This privacy policy (the “Privacy Policy”) applies to:
2.1.1 any users of the Online Tools;
2.1.2 any users of the Company’s services; and
2.1.3 anyone who contacts or otherwise submits information to the Company via the Online Tools.
3. SOVEREIGNWALLET NETWORK’S PRIVACY POLICY
3.1 This Privacy Policy sets out the basis upon which the Company will process any Personal Information that the Company collects from you, or that you provide to the Company.
3.2 Please read this Privacy Policy carefully to understand the Company’s views and practices regarding your Personal Information and how the Company will treat it.
3.3 By accessing and using the Online Tools and/or providing us with Personal Information, you acknowledge and agree that you:
3.3.1 understand and unconditionally accept and agree to this Privacy Policy; and
3.3.2 consent to the Company processing / using your Personal Information in the manner set out in this Privacy Policy.
3.4 If you do not accept and agree to this Privacy Policy, please do not provide your Personal Information to the Company and do not interact with or use the Online Tools.
3.5 The Company recommends that you print a copy of this Privacy Policy for future reference.
4. OUR PROMISE
4.1 We promise:
4.1.1 to keep your Personal Information safe and private;
4.1.2 unless otherwise agreed with you, not to sell your Personal Information; and
4.1.3 to give you ways to manage and review your choices regarding Personal Information usage restrictions at any time.
5. WHO WE ARE
5.1 The Company’s group may be made up of a mix of companies set up as different legal entities.
5.2 We will let you know which you have a relationship with when you engage with a particular entity.
5.3 You can find out more about the Company’s group at Our Site and on Our MUI MetaWallet App
6. PERSONAL INFORMATION WE COLLECT
6.1 The Company may collect Personal Information including:
6.1.1 your nationality and your national identity card or passport;
6.1.2 your photograph or other biometric information;
6.1.3 your full name;
6.1.4 your address and/or proof of address;
6.1.5 your email address;
6.1.6 your phone number and/ormobile phone number;
6.1.7 your birthdate;
6.1.8 your valid credit card details;
6.1.9 your income status; and
6.1.10 any other information we may request from you from time to time.
7. WHERE WE COLLECT PERSONAL INFORMATION FROM
7.1 The Company may collect Personal Information when:
You give us data, including:
7.1.1 when you talk to us on the phone;
7.1.2 when you send us emails or letters;
7.1.3 when you take part in our competitions or promotions;
7.1.4 when you create or update your account with the Company;
7.1.5 when we conduct background checks;
7.1.6 when you request services through the Online Tools;
7.1.7 when you access third party products and services through the Online Tools;
7.1.8 when you contact the Company, for example to provide feedback or to request for assistance;
7.1.9 when you contact other users through the Company’s services;
7.1.10 when you complete surveys sent to you by the Company or on its behalf;
7.1.11 when you enable features that require the Company’s access to your address book or calendar;
7.1.12 when you provide the Company with payment information;
7.1.13 when you provide the Company with access to your public profiles (i.e. Facebook); and
7.1.14 when you enable features or utilise services requesting location data;
You use The Company services / Online Tools, including
7.1.15 your precise or approximate location information as determined through data such as GPS, IP address, Wifi and any other location-based technology we may use;
7.1.16 information about transactions made via use of the Online Tools;
7.1.17 information about how you interact with the Online Tools;
7.1.18 information about how you interact with our services and third party products and services through our Online Tools, including preferences expressed and settings chosen;
7.1.19 Access Device Information; and
7.1.20 Usage Information;
We receive data from other sources, including
7.1.21 payment service providers;
7.1.22 financial service providers;
7.1.23 insurance providers;
7.1.24 advertising networks;
7.1.25 analytics providers;
7.1.26 search information providers;
7.1.27 the issuer of digital tokens (and any of their service providers) that We elect to host on Our platform for the purpose of providing services;
7.1.28 other users of the Company’s services and/or third party products and services provided through the Online Tools; and/or
7.1.29 other third parties.
8. COOKIES
8.1 COOKIES POLICY
We understand that your privacy is important to you and are committed to being transparent about the technologies we use. In the spirit of transparency, this policy provides detailed information about how and when we use cookies on our Site.
8.2 Do we use Cookies?
Yes. We and our marketing partners, affiliates, and analytics or service providers use cookies, web beacons, or pixels and other technologies to ensure everyone who uses the Site has the best possible experience.
8.3 What is a Cookie?
A cookie (“Cookie”) is a small text file that is placed on your hard drive by a web page server. Cookies contain information that can later be read by a web server in the domain that issued the cookie to you. Some of the cookies will only be used if you use certain features or select certain preferences, and some cookies will always be used. You can find out more about each cookie by viewing our current cookie list below. We update this list periodically, so there may be additional cookies that are not yet listed. Web beacons, tags and scripts may be used in the Site or in emails to help us to deliver cookies, count visits, understand usage and campaign effectiveness and determine whether an email has been opened and acted upon. We may receive reports based on the use of these technologies by our service/analytics providers on an individual and aggregated basis.
8.4 Why do we use Cookies?
We generally use Cookies for the following purposes:
• To recognize new or past customers.
• To store your password if you are registered on our Site.
• To improve our Site and to better understand your visits on our platforms and Site.
• To integrate with third party social media websites.
• To serve you with interest-based or targeted advertising.
• To observe your behaviors and browsing activities over time across multiple websites or other platforms.
• To better understand the interests of our customers and our website visitors.
Some Cookies are necessary for certain uses of the Site, and without such Cookies, we would not be able to provide many services that you need to properly use the Site. These Cookies, for example, allow us to operate our Site so you may access it as you have requested and let us recognize that you have created an account and have logged into that account to access Site content. They also include Cookies that enable us to remember your previous actions within the same browsing session and secure our Sites.
We also use functional Cookies and Cookies from third parties for analysis and marketing purposes. Functional Cookies enable certain parts of the site to work properly and your user preferences to remain known. Analysis Cookies, among other things, collect information on how visitors use our Site, the content and products that users view most frequently, and the effectiveness of our third party advertising. Advertising Cookies assist in delivering ads to relevant audiences and having our ads appear at the top of search results. Cookies are either “session” Cookies which are deleted when you end your browser session, or “persistent,” which remain until their deletion by you (discussed below) or the party who served the cookie. Full details on all of the Cookies used on the Site are available at our Cookie Disclosure table below.
8.5 How to disable Cookies.
You can generally activate or later deactivate the use of cookies through a functionality built into your web browser. To learn more about how to control cookie settings through your browser:
Click here to learn more about the “Private Browsing” setting and managing cookie settings in Firefox; Click here to learn more about “Incognito” and managing cookie settings in Chrome;
Click here to learn more about “InPrivate” and managing cookie settings in Internet Explorer; or Click here to learn more about “Private Browsing” and managing cookie settings in Safari.
If you want to learn more about cookies, or how to control, disable or delete them, please visit
http://www.aboutcookies.org for detailed guidance. In addition, certain third party advertising networks, including Google, permit users to opt out of or customize preferences associated with your internet browsing. To learn more about this feature from Google, click here.
To control flash cookies, which we may use on our Site from time to time, you can go to this link because Flash cookies cannot be controlled through your browser settings. Please note that if you decline the use of Cookies, some functions of the website may be unavailable and we will not be able to present personally tailored content and advertisements to you.
8.6 We may link the information collected by Cookies with other information we collect from you pursuant to this Privacy Policy and use the combined information as set forth herein. Similarly, the third parties who serve cookies on our Site
may link your name or email address to other information they collect, which may include past purchases made offline or online, or your online usage information. If you are located in the European Economic Area, you have certain rights that are described above under the header “Notice to EU Data Subjects”, including the right to inspect and correct or delete the data that we have about you.
9. YOUR PROTECTIONS UNDER THE LAW
9.1 As well as under this Privacy Policy, the privacy of your Personal Information is protected
by law in relevant jurisdictions.
This Clause 9.1 explains generally how
that
works.
9.2 The EU General Data Protection Regulation (“GDPR”) specifies that a data controller is only allowed to use your Personal Information if it has a proper reason to do so. This includes sharing it outside of the data controller’s organisation.
9.3 Whilst we operate outside of the European Union, we have chosen to generally align with the standards of the GDPR.
10. HOW WE USE DATA / INFORMATION
10.1 The Company may use information held about you in the following ways:
10.1.1 to carry out the Company’s obligations and to provide you with the information and/or services that you request from the Company;
10.1.2 to provide you, or permit selected third parties to provide you with information about services the Company offers or feels may interest you;
10.1.3 to notify you about changes to the Company’s services;
10.1.4 to ensure that content from the Online Tools is presented in the most effective manner for you and for your device;
10.1.5 to administer the Online Tools and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
10.1.6 to allow you to participate in interactive features of the Online Tools, when you choose to do so;
10.1.7 as part of the Company’s efforts to maintain the safety, security and integrity of the Company’s Online Tools and services;
10.1.8 to deliver relevant advertising to you and measure or understand the effectiveness of the same;
10.1.9 to provide appropriate assistance to you when you contact the Company’s customer support;
10.1.10 fortesting, research, analysis and product development;
10.1.11 to comply with our legal and regulatory obligations;
10.1.12 to verify information you have provided to us for our “Know Your Client” purposes;
10.1.13 where we have a Legitimate Interest; and
10.1.14 to investigate or address claims or disputes relating to your use of the Company’s services and/or the Online Tools in accordance with Applicable Law.
10.2 If you have any questions or want more details about how we use your Personal Information, you can ask us via email at wallet@sovereignwallet.network.
11. LEGITIMATE INTEREST
11.1 In relation to Clause 10, our reasons for which we may use your Personal Information include where:
11.1.1 we have your consent;
11.1.2 we are fulfilling a contract with you;
11.1.3 we are under a legal duty to do so (e.g. KYC); and/or
11.1.4 we have a Legitimate Interest to do so.
11.2 For the purposes of this Privacy Policy, “Legitimate Interest” means where we believe that processing your Personal Information is necessary for:
11.2.1 keeping our records up to date;
11.2.2 working out which of our products and services may interest you and telling you about them;
11.2.3 developing products and services, and what we charge for them;
11.2.4 defining types of customers for new products or services;
11.2.5 seeking your consent when we need it to contact you;
11.2.6 efficiently fulfilling our legal and/or contractual duties; and/or
11.2.7 complying with Applicable Law and rules and guidance from regulators.
12. DISCLOSURE OF YOUR DATA / INFORMATION
12.1 The Company may share / disclose your information with selected third parties and in certain circumstances, including:
12.1.1 people who the Company works with, including affiliates, employees, suppliers and sub-contractors to deliver your services and for the performance of any contract the Company enters into with you;
12.1.2 advertisers and advertising networks that require the data to select and serve relevant adverts to you and others;
12.1.3 analytics and search engine providers that assist the Company in the improvement and optimisation of the Online Tools;
12.1.4 where the Company sells or buys any business or assets, in which case we may disclose your information to the prospective seller or buyer of such business or assets;
12.1.5 where the Company is under a duty to disclose or share your information in order to comply with Applicable Law, or any legal or regulatory obligation or order;
12.1.6 in order to enforce or apply any of the Company’s terms and conditions; and/or
12.1.7 to protect the rights, property or safety of any of the Company’s employees or customers.
13. WHERE THE COMPANY STORES YOUR PERSONAL DATA / INFORMATION
13.1 The information that the Company collects from you may be transferred to, and stored at, a destination outside Singapore.
13.2 Your information may be processed by people outside Singapore who work for the Company or for one of our suppliers, pursuant to a data processing agreement entered into with us, which is compliant with this Privacy Policy. Such staff may be engaged in, among other things:
13.2.1 the provision of services;
13.2.2 the processing of your payment details; and/or
13.2.3 the provision of support services.
13.3 By submitting your information, you agree to the information transfer, storing or processing referred to in this Privacy Policy.
13.4 Unfortunately, the transmission of information via the internet is not completely secure and any transmission of data / information is at your own risk.
13.5 The Company will use reasonable efforts to ensure that your information is treated securely and in accordance with this Privacy Policy.
13.6 Notwithstanding Clause 13.5, the Company cannot guarantee the security of your information transmitted to the Online Tools.
13.7 Where you have a password which enables you to access certain parts of the Online Tools, you are responsible for keeping this password confidential and agree not to disclose it to anyone.
14. HOW LONG WE KEEP YOUR PERSONAL INFORMATION
14.1 We will keep your Personal Information for as long as you maintain an account with the Company or such other period as may be required by Applicable Law.
14.2 After you terminate your account with the Company, we may keep your Personal Information for up to 3 years for one of these reasons:
14.2.1 to respond to any questions or complaints;
14.2.2 to show that we treated you fairly;
14.2.3 to maintain records according to rules that apply to us.
14.3 We may keep your Personal Information for longer than 3 years if we cannot delete it for legal, regulatory, or technical reasons. We may also keep it for research or statistical purposes. If we do, we will make sure your privacy is protected and only use it for those purposes.
15. IF YOU CHOOSE NOT TO GIVE US PERSONAL INFORMATION
15.1 We may need to collect Personal Information as required by Applicable Law, or to enter into or fulfil a contract we have with you.
15.2 If you choose not to give us this Personal Information, it may:
15.2.1 delay or prevent us from fulfilling a contract we have with you;
15.2.2 delay or prevent us from doing what we must do by Applicable Law;
15.2.3 mean that we cannot run your accounts and/or policies; and/or
15.2.4 mean that we decide to cancel any account you have with us.
15.3 We sometimes ask for information that is useful, but not required by Applicable Law or a contract. We will make this clear when we ask for it. You do not have to give us these extra details and it won't affect the products or services you have with us.
16. HOW TO GET A COPY OF YOUR PERSONAL INFORMATION
16.1 You can obtain a copy of your Personal Information that we hold by writing to us at wallet@sovereignwallet.network.
17. HOW TO CORRECT YOUR PERSONAL INFORMATION
17.1 You have the right to question any Personal Information that we have about you, which you think is wrong or incomplete. Please contact us at wallet@sovereignwallet.network if you want to do this.
17.2 Where you submit a request pursuant to Clause 17.1, we will take reasonable steps to check the accuracy of your Personal Information and make any necessary corrections.
18. REQUESTING THAT WE CEASE USING YOUR PERSONAL INFORMATION
18.1 You have the right to object to our use of your Personal Information, or to ask us to delete, remove or stop using your Personal Information.
18.2 We want you to tell us if you think that we should not be using your Personal Information. But please note there may be legal or other official reasons why we need to still retain and/or use your Personal Information and that we reserve our rights as per Clause 14.
18.3 We may sometimes be able to restrict the use of your Personal Information. This means that the Personal Information would only be used for certain things, such as legal claims or to exercise legal rights.
18.4 Where Clause 18.3 applies, we would not use or share your Personal Information in other ways while it is restricted.
18.5 You can ask that we restrict the use of your Personal Information if:
18.5.1 it is not accurate;
18.5.2 it has been used unlawfully but you do not want us to delete it;
18.5.3 it is not relevant anymore, but you want us to keep it for use in legal claims; or
18.5.4 you have already asked us to stop using your Personal Information but you are waiting for us to tell you if we are allowed to keep on using it.
18.6 The Company will usually inform you (before collecting your information) where it intends to:
18.6.1 use your data for marketing purposes; or
18.6.2 disclose your information to others for marketing purposes.
18.7 If you want to object to how we use your Personal Information or ask us to delete it or restrict how we use it, please contact us at wallet@sovereignwallet.network.
19. THIRD PARTY WEBSITES
19.1 The Online Tools may, from time to time, contain links to and from third party websites.
19.2 If you follow a link to / from any third party websites, you do so at your own risk, and subject to whatever privacy policy / website terms that govern the use of such websites.
19.3 The Company does not accept responsibility or liability for the content of third party websites, or any information you provide to them.
20. CHANGES TO OUR PRIVACY POLICY AND YOUR ACCEPTANCE
20.1 Any changes the Company may make to this Privacy Policy will be posted on this page. Please check back frequently to see any updates or changes.
20.2 Your continued use of the Online Tools will confirm your understanding and acceptance of this Privacy Policy and any changes made to it from time to time.
21. HOW TO WITHDRAW YOUR CONSENT
21.1 You can withdraw your consent to this Privacy Policy at any time. Please contact us if you wish to do so.
21.2 If you withdraw your consent, you acknowledge and agree that you are required to cease using the Online Tools and that we may no longer be able to provide or enable the provision of any certain products or services to you.
22. HOW TO COMPLAIN
22.1 Please let us know if you are unhappy with how we have used your Personal Information. You can contact us at wallet@sovereignwallet.network.
23. CONTACT
23.1 Please let us know if you are unhappy with how we have used your Personal Information. You can reach us at wallet@sovereignwallet.network.
23.2 You also have the right to complain to a relevant privacy regulator, and to potentially lodge an appeal if you are not happy with the outcome of a complaint. We hope that that won’t be ever required though.
23.3 Any other questions, comments and requests regarding this Privacy Policy should also be sent to wallet@sovereignwallet.network.
24. DEFINITIONS
24.1 For the purposes of this Privacy Policy, the following terms shall have the following meanings:
24.1.1 “Access Device Information” means technical information about the devices you use to access the Company’s services, including hardware models, operating systems and versions, software, file names and versions, preferred languages, unique device identifiers, advertising identifiers, serial numbers, device motion information and mobile network information.
24.1.2 “Applicable Law” means all national, state, local, municipal legislation, regulations, statutes, by-laws, approvals and/or other laws and any other instrument having the force of law as may be issued and in force from time to time (and any amendment or subordinate provisions) relating to, or connected with, the activities contemplated under this Privacy Policy wherever so located or performed.
24.1.3 “Personal Information” means data relating to a living individual who is or can be identified either from the data or from the data in conjunction with other information that is in, or is likely to come into, the Company’s possession.
24.1.4 “Usage Information” means information about your use of the Online Tools, including your device IP address, access dates and times, app features or pages viewed, app crashes and other system activity, type of browser, and the third party site or service you were using before interacting with the Online Tools.