Atrae, Inc, (Company Registration No.6010401060842), a company incorporated under the laws of Japan with its registered address at 106-0045,1-10-10 Azabujuban, Minato-ku, Tokyo, Japan 8th floor, Joule A , its affiliates and subsidiaries (hereinafter referred to as the “Company”, “we”, “us” or “our”) has the highest regard for the privacy and personal data of each user (hereinafter referred to as “user”, “you” or “your”) of the Minglo Applications (defined below) and/or visitors to the Minglo Site (defined below) (the Minglo Applications and the Minglo Site are collectively, the “Minglo Platform”).
We are aware that the success of our services depends on the trust that you have in the way we handle your personal data. By entrusting us with your information, we would like to assure you of our commitment to keep such information private.
We have taken considerable steps to protect the confidentiality, security and integrity of the information shared with us. We encourage you to review the following information carefully before using the Minglo Applications. By using the Minglo Applications, you are deemed to have read, understood and accepted our practices governing the collection, use and disclosure of your personal data in this Privacy Policy.
We are not responsible for the privacy practices of any third-party websites that may be linked to the Minglo Applications. It is your responsibility to check this webpage periodically to see if any terms have been changed or modified. Your continued use of the Minglo Applications constitutes your acceptance of any updates to this Privacy Policy.
This Privacy Policy is drafted in accordance with the Personal Data Protection Act 2012 (“PDPA”) under Singapore law and is intended for use in Singapore and, where applicable, other countries or regions which provide the same level of protection for personal data that is comparable to the standards of the PDPA.
The PDPA recognizes the rights of individuals to protect their personal data (including rights of access and correction) and the requirement for organizations to collect, use or disclose personal data for legitimate and reasonable purposes. Accordingly, this Privacy Policy outlines the personal data that we collect, how it may be used, how it is stored and retained, whom it may be transmitted to as well as our and your responsibilities in relation to such uses and disclosures. We recommend that you read this Privacy Policy and our Terms and Conditions carefully before disclosing any personal data to us or using the Minglo Applications.
Please refer to the Terms and Conditions accessible at https://www.minglo.org/terms-and-conditions ("Terms”) when reading this Privacy Policy. Unless otherwise defined in this Privacy Policy, capitalized terms used herein shall have their meanings ascribed to them under each of the Terms and Conditions specific to each of the Minglo Applications.
Where further details are required on the Minglo Platform, you are advised to peruse the whitepaper of the Platform available athttps://www.minglo.org/whitepaperto familiarize yourself with the Minglo Platform and the Services.
1. INTERPRETATION
1.1. “Data Wallet” refers to the designated wallet on the Minglo Platform that is required to access and use the Minglo Platform and/or the Services.
1.2. “Minglo Application” means any of the product below, and “Minglo Applications” mean all of the products collectively delivered by us below:
(a) Minglo Super App, a mobile application that allows users to engage in wellness activities, manage and monetize their data through the use of blockchain technology including gamification, tokenization and cryptocurrency payments via Non-Fungible Tokens and other Utility Tokens issued or circulated within the Minglo Super App (the “Tokens”);
(b) Third-party apps within the Minglo Super App ecosystem that provide for gamification and incentivization through the Tokens and wellbeing services, applications and incentives hence encouraging users to participate and contribute to the overall richness of data collected on the Minglo Super App (the “Third Party Services”); and
(c) Minglo Software Development Kit (SDK), a toolset designed for the integration and development of decentralized and cryptocurrency functionalities within the Minglo Super App’s ecosystem that governs wallet management, governance mechanisms, token staking and exchange, digital signature data tokenization, data ownership structures, and blockchain exploratory capabilities.
1.3. "Minglo DAO” refers to the Decentralized Autonomous Organization accessible on the Minglo Platform. The Company leverages the transparency, immutability, and automation of blockchain technology to make collective decisions on behalf of the users of the Minglo Platform and/or the Services.
1.4. “Minglo Platform” shall mean the collective reference to the entire solution provided by the Minglo Applications and the Minglo Site;
1.5. “Minglo Site” means the website at https://www.minglo.org , associated systems and subdomains thereof, including the mobile-optimised versions of such website;
1.6. “Service” or “Services” shall have the meaning ascribed to it under the Terms and Conditions specific to each Minglo Application. For the avoidance of doubt, non-capitalized reference to “service” or “services” shall have the ordinary meaning of service in this Privacy Policy;
1.7. “Terms and Conditions” refers to the terms and conditions of use of the Minglo Applications.
1.8. “Tokens” refer to cryptographically secured digital assets such as Non-Fungible Tokens (“NFT”) and utility tokens issued, circulated or otherwise used on the Minglo Platform. These Tokens include the DataNFT, $Data, $MGL, and any other digital token that the Company may, from time to time, issue.
1.9. Where you are an EU Data Subject, as defined under the General Data Protection Regulation (“GDPR”), Section 17 shall also apply to you.
1.10. The headings used in this Privacy Policy are for convenience only and shall not affect the interpretation of these provisions.
2. APPLICATION
2.1. This Privacy Policy applies to users when browsing, visiting, accessing and/or using any part of the Minglo Platform.
2.2. This Privacy Policy sets out our commitments and explains the rights that you have with respect to your personal data. If you do not agree to the terms of this Privacy Policy, please do not use the Services or any part thereof.
2.3. You shall not be permitted to use the Services where you do not confirm your acceptance of this Privacy Policy.
3. GROUNDS FOR DATA COLLECTION
3.1. By browsing, visiting, accessing and/or using the Minglo Platform and/or when you provide personal data to us, you consent to the collection, storage, use, disclosure and other uses and processing of your personal data by us in accordance with this Privacy Policy, and such consent shall remain effective unless you otherwise notify us in writing of the withdrawal of your consent and the reason thereto. You shall not use our Services if you do not consent to this Privacy Policy, and you shall immediately cease using our Services if you withdraw your consent for us to process your personal data.
3.2. “Personal data” and other terms defined under the PDPA where used in this Privacy Policy shall have the same meaning defined under the PDPA.
3.3. Processing of your personal data is necessary for the performance of our contractual obligations towards you under the Terms, permitting access to the Minglo Platform, and providing you with the Services, to protect our legitimate interests, and to ensure compliance with legal and financial regulatory obligations. Failure to provide the relevant data to us or the limitation placed on us in the processing of your personal data may affect our ability to allow your access to the Minglo Platform, provide the Services and/or your ability to enjoy the full benefits of the Minglo Applications.
4. HOW DO WE RECEIVE INFORMATION ABOUT YOU?
4.1. The Minglo Platform and/or the Services require registration and provision of your information, including personal data.
4.2. Upon creating a profile or registering with us – where you create an account with us, register a profile, or are issued a Data Wallet for use on the Minglo Platform, you will be asked to provide personal data which will form part of your unique digital identity on the Minglo Platform (your “DataID”).
4.3. For compliance with our Anti-Money Laundering / Counter Financing of Terrorism (“AML/CFT”) measures – the Company complies with its AML/CFT Policy released and updated by the Company on the Minglo Platform from time to time ("AML/CFT”). In accordance with our AML/CFT policy, we may request for your personal data, including information such as identification documents and pictures.
4.4.Whenever you submit information via the Minglo Platform and/or the Services – You may, in the course of interactions with other users on the Minglo Platform and/or the Services (including Third Party Services) accessible via the Minglo Platform, disclose your personal data.
4.5. If you choose to sign up via your social media accounts or other authentication providers – when you sign-up to the Minglo Platform and/or the Services via your social media accounts or other authentication providers (such as Google account or Facebook account), we will have access to basic information made publicly from such account, such as your full name, home address, email address, birthdate, profile picture, friends list, personal description, as well as any other information you made publicly available on such account, or agreed to share with us.
4.6. It is your voluntary decision whether to provide us with any personal data, however if you do not provide the information we require or requested, you may not be able to create a profile or register a digital identity on the Minglo Platform or use the Services. Your use of the Minglo Platform and/or the Services may be severely limited.
4.7. To enable us to provide the Minglo Platform and/or the Services to you effectively, the information you provide to us shall be accurate, complete, not misleading and without material omission, and that such information is kept up to date. If you discover that the information is inaccurate, incomplete, misleading, contains material omission or is outdated, please update us with the true, accurate, complete and updated information.
4.8. If you provide us personal data about another person, you confirm that such other person has appointed you to act for him/her, to consent to the processing of his/her personal data by us in accordance with this Privacy Policy and to receive on his/her behalf any data protection notices.
5. WHAT TYPES OF INFORMATION WE COLLECT?
5.1. We collect the following personal data about you:
(a) Profile and Registration information – you will be required to provide your name, email address, gender, birth date, zip code, country of residency, home address and phone number;
(b) Blockchain Data – we may collect and analyse public blockchain data such as transaction ID, transaction amounts, wallet address for the transfer or storage of tokens, timestamps, events or data transactions between parties, smart contracts, AI services, social graph services and data storage, as well as user interactions between users and the Minglo Platform. For the avoidance of doubt, the blockchain is a decentralized ledger and where your data is stored on the blockchain, the data is accessible by the Company, but not controlled by the Company.
(c) Payment information – certain features of the Platform may require payments and/or subscriptions before you are able to utilize these functions. Where payments are required you may be required to provide details of your debit or credit cards, or details associated with payment services that are accepted on the Minglo Platform and/or the Third Party Services.
(d) Voluntary information – when you communicate with us (for example when you send us an email or use a “contact us” form) we collect the personal data you provided us with;
(e) Technical information – we collect certain technical information that is automatically recorded when you use our Services, such as your IP address, device approximate location;
(f) Wellness information – you may provide, through your interactions with the Minglo Applications or through your interactions with software, scripts, Third Party Services or other users of the Minglo Platform, information on your personal characteristics and emotions (collectively your “Wellness Information”) so as to enable the creation of a secure and private virtual representation of you, encompassing your personal, social and well-being attributes;
(g) Medical Histories – To facilitate the generation of your DataID (as defined below), your medical history may be requested to facilitate the creation of a comprehensive digital identify; and
(h) Other Personal Data – you may, in the course of using the Minglo Platform and/or the Services, disclose through videos, posts or other information posted or uploaded on the Minglo Platform, personal data about yourself or third parties. Such information may be stored on our servers.
5.2. We also collect the following information:
(a) Minglo Platform usage data – we collect information about your use of the Minglo Platform. This includes but is not limited to type of computing or mobile device you use, language of your operating system, the Internet browser you are using, geo-location and use of the Minglo Platform.
(b) Technical information – Minglo Platform might also access a list of installed apps on your device. This is done only to ensure proper quality of service, as some apps might interfere with the Minglo Platform’s functionality, such as blocking notifications, and in such cases we will notify you.
6. TRACKING TECHNOLOGIES – COOKIES
6.1. A cookie is a small piece of text that is sent to the Minglo Platform or your browser when you access the Minglo Platform. The Minglo Platform provides this piece of text to your device when you return. We use cookies to help personalize your experience with the Minglo Platform.
6.2. A “persistent” cookie may be used to help save your settings and customizations. Also, if you log in to the Minglo Platform, such a cookie will be used to recognize you as a valid user so you will not need to log in each time you use the Minglo Platform.
6.3. The Minglo Platform automatically accepts cookies however you may to modify security settings so you can approve or reject cookies on a case-by-case basis or reject all cookies.
6.4. Also, you are free to delete any existing cookies at any time. If you delete or disable cookies from the Minglo Platform, some parts or functions of the Minglo Platform may not work properly for you.
6.5. We also use “Google Analytics” to collect information about the use of the Services. Google Analytics collects information such as how often users visit the Services, what pages they visit, when they do so, and what other sites they used prior to coming to the Services. Google Analytics collects only the IP address assigned to you on the date you use the Services, as well as information regarding your operating system, language and information regarding your use of the Services, rather than your name or other identifying information. We do not combine the information collected through the use of Google Analytics with personal data. We use the information we get from Google Analytics only to improve the Services. Google’s ability to use and share information collected by Google Analytics about your use of the Services is restricted by the Google Analytics Terms of Use and the Google Privacy Policy.
7. HOW DO WE USE THE INFORMATION WE COLLECT?
7.1. We collect the following personal data about you:
(a) Provision of Services – we will use your information for the provision and improvement of our Services to you, and for the processing of your requests and queries. For example, data collected automatically on the Services may be used to help diagnose problems with our servers, to make our Services more useful, to customize it and personalize its content for you.
(b) Social Graph – The Minglo Platform enables the creation and management of global mapping of all users and how they are related using decentralized ledgers. This global mapping is commonly known as a social graph (the “Social Graph”). The Social Graph is powered by proprietary technologies used on the Minglo Platform and is generated following analysis of your information.
(c) ID-As-A-Service – Integrating data, including personal data, which you provide us to generate a hash function unique to you and to support secure identity and verification services to external parties, provided that a user is on the Minglo Platform. For example, personal data is safeguarded from internal and external unauthorized access yet permit authentication of users of the Minglo Platform when you are using Third Party Services.
(d) Enriched Personal Profile – The Minglo Enriched Personal Profile (the “Enriched Personal Profile”) is assembled from the aggregation of your personal data from different reliable centralized platforms such as Google, LinkedIn, Facebook, Twitter, and other public data repositories, with rudimentary data which you provide to us. Your Enriched Personal Profile amplifies the value of your DataID, paving the way for tailored, data-driven services that fully cater to individual user requirements.
(e) Data-As-A-Service – Data, including personal data, which you provide on the Minglo Platform and/or the Services may be aggregated with data from other users of the Minglo Platform and/or the Services to be supplied to the Company’s Artificial Intelligence (“AI”) model to create further insights (“Data Insights”). Data Insights, your Enriched Personal Profile or any publicly visible data which you set on the Minglo Platform may be accessed by other organizations across industries such as but not limited to, well-being providers, research and teaching institutions, analytical and market research firms, insurers, hospitals, government, and Non-Governmental Organizations, to search for to find matching users for their requirements.
(f) Well-being and Health Services – Through the access to and/or viewing of your personal data which you have disclosed or provided on the Minglo Platform and/or through the use of the Services, the providers of Third-Party Services may provide hyper-personalised services to you, improve the efficiency of the well-being and health services through facilitating the confidential communication between you and health service providers and utilizing secure methods of payment for healthcare services on the Minglo Platform via the Tokens or any other form of supported payment on the Minglo Platform.
(g) Promoting of socio-political objectives – The Minglo Platform harnesses the power and influence of data, including personal data, to promote the achievement of socio-political objectives, such as but not limited to:
(1) Providing analytical offerings, incorporating trust, personality, and mutual understanding to provide employees with insights into their organizational relationships and deliver actionable improvement strategies for the workplace environment;
(2) Revolutionizing of mental health care by amalgamating your data, including personal data, with the Minglo Platform’s predictive and personalization capabilities to enabling early detection, timely intervention, bespoke treatment plans, support continuous patient monitoring and round-the-clock assistance through chatbots and virtual therapists; and
(3) Permit the creation of substantive social connections to alleviate general well-being and mitigate loneliness through the processing of your data, including personal data, by the Minglo Platform’s AI and other technological capabilities.
(h) Technological integration – The Minglo Platform offers a unique fusion of identity services, notifications, and private data management that can streamline the digitization of city services and resident communications. Your data, including personal data, may form part of or be utilized to test, roll out, elevate or create digital infrastructure centered around identity services, notifications, and private data management.
(i) Enforcement – we may use your personal data for the purpose of enforcing our rights under the Terms or to defend ourselves, including assessing the personal data posted to determine whether content containing such personal data should be deleted.
(j) General communication – we also use your personal data to send you texts, emails or other communications regarding general adherence information, Services maintenance, updates, or changes to this Privacy Policy or any other relevant agreements.
(k) Marketing purposes – we will use your personal data (such as your email address or phone number) to communicate with you. We may also send you promotional material concerning our Services or Third Party Services (which we believe may interest you), including but not limited to, by building an automated profile based on your personal data, for marketing purposes.
If you do not want us to use or share your personal data for marketing purposes, you may request us to cease processing your personal data for marketing purposes using the information below under “How to Contact Us”. Please note that even if you opt-out, we may still use and share your personal data with third parties for non-marketing purposes (for example to fulfil your requests, communicate with you and respond to your inquiries, etc.). In such cases, the organisation with whom we share your personal data are authorized to use your personal data only as necessary to provide these non-marketing services.
(l) Analytics, surveys and research – we are always trying to improve our services and think of new and exciting features for our users. From time to time, we may conduct surveys or test features, and analyze the information we have to develop, evaluate and improve these features.
(m) Anonymised data – we may analyse and evaluate your personal data in connection with the Services, anonymise and aggregate our analysis and evaluation, and commercialise such anonymised and aggregated analysis and evaluation in any manner as we think fit.
(n) Protecting our interests – we may use your personal data when we believe it is necessary in order to take precautions against liabilities, investigate and defend ourselves against any third-party claims or allegations, investigate and protect ourselves from fraud, protect the security or integrity of the Minglo Platform and/or the Services and protect the rights and property of the Company, its users and/or partners.
(o) Enforcing of policies – we may use your personal data in order to enforce our policies, including the Terms.
(p) Compliance with legal and regulatory requirements – we may also use your personal data as required by or for the purpose of compliance with law, regulation or other governmental authority, or to comply with a subpoena or similar legal process.
(q) Record-keeping – we will collect and retain your personal data in the ordinary course of our business and for so long as necessary for the fulfilment of the purposes set out in this Privacy Policy or as is required by any legal, regulatory and/or accounting requirements.
(r) Ancillary purpose – we may use your personal data for any purposes in connection with, relating or ancillary to any of the above, provided that they are necessary for the delivery of the Services.
8. WITH WHOM YOUR PERSONAL DATA MAY BE SHARED?
8.1. We may share your personal data with the following persons:
(a) Healthcare stakeholders – we may share your personal data with third parties, such as, but not limited to, research institutes, healthcare systems and healthcare providers, that they may associate with other information that they have about you for purposes including research, analytics and/or for improvement of the Third Party Services. You are informed that such healthcare stakeholders may, via the Minglo Platform and/or the Third Party Services, reach out to you for clinical trials based on your medical history.
(b) Providers of Third-Party Services – your personal data may be shared via the Minglo Platform and/or through the Third Party Services. If you consent to such transfer by us of your personal data to another organisation, please note that the information provided will be subject to such organisation’s privacy practices and shall not be within our control.
(c) Content providers – we may also use your personal data in order to provide you with personalized third-party content or links to third party sites that might interest you. We provide this third-party content and/or links to third party sites for information purposes only and are not liable for such content or sites. For more information see the “Links to other Websites or Apps” section below.
(d) Service providers – we might share your personal data, as is reasonably necessary, with our contractors or consultants, including vendors and suppliers that provide us with development services, technology, services, or content for the operation, development and maintenance of the Minglo Platform and/or our Services or data and analysis on the use of the Minglo Platform and/or our Services. The Company shall impose on such service providers obligations of confidentiality and only share personal data to the extent necessary with such contractors or consultants.
(e) Law authorities – we may share your personal data with law enforcement authorities, courts and tribunals, including with legal advisors and consultants, in case we need to respond to law enforcement requests or other legal requests or pursuant to a requirement imposed by law, order, judgment or decree, or courts in order to protect and defend our rights and property or those of Services users.
(f) Merger, acquisition or sale – we may transfer your personal data to another organisation in the event of a merger, acquisition or sale of all or a portion of our assets.
(g) Auditor, legal and professional advisor – we may share your personal data with our auditor if requested for the purpose of audit on our business. We may also share your personal data with our legal and other professional advisors for the purpose of enforcing our rights or defending any claims against us, or for any other purpose in connection with the Services.
(h) Data intermediary – we may appoint an organisation to process and/or store personal data on our behalf in connection with the Minglo Platform and/or the Services. In this respect, we will share your personal data to the appointed organisation, who will be required to process your personal data in accordance with this Privacy Policy.
(i) Group companies – we may share your personal data with our group of companies for internal reporting purposes.
8.2. We and/or providers of Third Party Services may, through the Minglo Platform and/or the Services, offer you, from time to time and at our sole discretion, participation in customized programs, based on specified criteria, which could include clinical trials (“Programs”). Participation in Programs may require sharing of your personal data with additional third parties. If you choose to participate, we will provide you with additional information and seek your consent for such sharing.
8.3. While we take great care to keep your personal data confidential and secure, when you share your health or medication information with others or provide feedback regarding health matters, medications and otherwise, including by means of social media sites, or when you participate in a forum on the Services, any information disclosed by you in such way is solely your responsibility. You should exercise caution when disclosing any information (including personal data) in such ways, as you do not know who will access or use such information and for what purposes.
9. USE OF AGGREGATED DATA
9.1. We make every effort to ensure that aggregated data does not include any personally identifiable information. The AI technologies powering the Platform and/or enabling the delivery of the Services may analyze and/or combine all information we receive (as set out under this Privacy Policy), with information from other users to create aggregated data that may be disclosed to and utilized by us, our affiliates and by third parties without restriction, on commercial terms that we can determine in our sole discretion, for purposes such as: content marketing, research purposes, in order to understand behavior patterns, marketing strategies and for entering into commercial contracts in order to provide our users with the Services (including the Third Party Services) as well as to periodically enhance the Platform and/or the Services.
10. ACCESS AND CORRECTION
10.1. You may request access to and correction of, your personal data and limit the processing of your personal data or make any enquiries or complaints in respect of the processing of your personal data, by contacting us at the contact details set out in “How to Contact Us” section below. You are responsible for informing us when your personal data or preferences have changed and require updating. We shall, within a reasonable time frame, attend to your request for access to and correction of your personal data or updating of your preferences.
10.2. You may at any time, in your sole discretion or at the direction of our data protection team, delete content containing personal data which you have posted on the Minglo Platform.
10.3. Where you have burned any DataNFTs in your possession, you acknowledge that the data embodied in the DataNFT may not be retrieved and the Company has no ability to access (or correct) such data.
11. INTERNATIONAL TRANSFERS
11.1. Off Chain Storage: We store information and data on public and/or private cloud, where your data can be stored and/or backed up in any of the jurisdictions where the cloud service providers provide their cloud service. You hereby consent that we may store your personal data on our cloud server, which may be located outside Singapore or the jurisdiction in which the Services was obtained or is used.
11.2. The Company utilizes a network of storage and server resources that is designed to provide the required security and accessibility for the Minglo Platform. The Company shall, in all engagements with data storage solution providers, use service providers who have evidenced the capability to manage the volumes, nature and technology necessary to store the data provided by users of the Minglo Platform and/or the Services.
12. RETENTION
12.1. We will retain your personal data for as long as necessary to provide our services or as required by any legal, regulatory and/or accounting requirements. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our policies. Retention periods will be determined taking into account the type of information that is collected and the purpose for which it is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused information at the earliest reasonable time. Without prejudice to the foregoing, where you do not use our Services for 1 consecutive year, we will delete all your Wellness Information from our records.
12.2. You are informed that where your data is stored on the relevant blockchain used to support the Minglo Platform (“On-Chain Storage”), such data may be accessed, but is not controlled by or held in the possession of the Company. The Company has no ability, nor obligation to, retain or delete data in On-Chain Storage. Blockchain technologies utilize distributed ledger technologies and you, as the owner of Tokens and the Data Wallet is the only party able to control your activity on the blockchain.
13. LINKS TO OTHER WEBSITES OR APPS
13.1. Our Services may link to or refer to websites or mobile device services that we do not control. Any personal data you provide on the linked pages is provided directly to this third party and is subject to this third party’s provider’s privacy policy. This Privacy Policy does not apply to such other websites or mobile device services, and we are not responsible for the privacy practices or content of any website or mobile device service not controlled by us. If you have any concerns, we urge you to review the terms of those other websites or mobile device services for more information about their applicable policies.
14. HOW WE PROTECT YOUR INFORMATION
14.1. We have implemented administrative, technical, and physical safeguards to help prevent unauthorized access, use, or disclosure of your personal data. Your information is stored on secure servers and isn’t publicly available. We limit access of your information only to those employees or partners that need to know the information in order to enable the carrying out of the agreement between us.
14.2. You need to help us prevent unauthorized access to your account by protecting your password appropriately and limiting access to your account (for example, by signing off after you have finished accessing your account). You will be solely responsible for keeping your password confidential and for all use of your password and your account, including any unauthorized use.
14.3. While we seek to protect your information to ensure that it is kept confidential, we cannot absolutely guarantee its security. You should be aware that there is always some risk involved in transmitting information over the internet. While we strive to protect your personal data, we cannot ensure or warrant the security and privacy of your personal data or other content you transmit using the Services, and you do so at your own risk.
14.4. You are further informed that On Chain Storage is utilized by the Company. Data stored on the relevant blockchain supporting the Platform and/or the Services does not belong to the Company and is situated on a decentralized ledger. On Chain Storage is used to store data that can be used to verify users’ identities and ensure data integrity.
14.5. Off Chain Storage is also utilized by the Company to store data you disclose to us. All the data stored in Off Chain Storage is encrypted at rest and in transit. The off-chain data will be stored in secure, scalable, and highly available cloud services which are directly integrated with the Minglo DAOs' smart contracts to facilitate data access.
14.6. We shall, in the event of a compromise of personal data:
(a) Assess the extent to which personal data collected by us has been compromised and put in place appropriate measures to contain the breach of personal data and minimize any harm to you arising from the breach of personal data;
(b) Analyze and determine the cause of the data breach;
(c) Ascertain if the data breach are notifiable data breaches under any data protection and privacy laws applicable to the Company;
(d) Report the data breach to any relevant governmental data protection body or agency, including the Singapore Personal Data Protection Commission if the data breach is a notifiable data breach;
(e) Ascertain if you are required to be informed of the data breach having regard to relevant rules, regulations, advisories, orders wheresover applicable, including but not limited to the Personal Data Protection (Notification of Data Breaches) Regulations 2021 and the Advisory Guidelines on Key Concepts in the PDPA;
(f) Inform you if you are required to be notified of the data breach; and
(g) Take continuing action to prevent further harm to you arising from the breach of personal data, including but not limited to reviewing measures taken to contain breaches of personal data and protect personal data.
14.7. We shall, in managing data breaches, have regard to the Guide on Managing and Notifying Data Breaches under the PDPA (“Guide”). Subject to our compliance with the Guide in the event of a breach of personal data, by continuing to use the Platform following such an event of breach, you confirm that you accept the adequacy of measures taken by us following an event of breach of personal data.
14.8. We shall be entitled to all rights of indemnity against you as a user of the Minglo Platform in the case where you posted content containing personal data and acted in breach of the Terms of the Minglo Platform.
14.9. You acknowledge that notwithstanding the Company’s security measures, malicious actors, scripts, viruses, codes, software and other damaging factors including the evolution of hacking technologies, may result in the compromise of the personal data which you have provided to the Company.
14.10. To the fullest extent permitted, you waive any claim against the Company for any, loss, liability, damage and/or cost incurred (“Damage”), howsoever such Damages arise and whether such losses are direct or indirect losses, where such data breaches do not arise out of the negligence, fraud or wilful default of the Company.
15. CHILDREN
15.1. Our Services are intended for use by corporations or legal entities duly organised, validly existing and in good standing in the jurisdiction which they are incorporated, or established in. We have no control over the personal data protection policies adopted within these organizations or entities and by agreeing to the Privacy Policy, you accept that the personal data which you, as an individual using the Minglo Platform, provided to such corporations or legal entities at your own risk and that we have no control over, and accept no liability thereto, for the personal data which you provide at your own discretion.
16. SPECIFIC PROVISIONS RELATED TO THE EUROPEAN UNION GENERAL DATA PROTECTION REGULATION
16.1. We acknowledge that the GDPR will apply if we process or hold any personal data of individuals residing in the EU or if we offer goods or services to individuals in the EU (“EU Individuals”).
16.2. We understand that we may lawfully process personal data if consent is provided by the EU Individual for the processing for specific purposes, if it is necessary for the performance of a contract of if it is necessary for our compliance with a legal obligation.
16.3. We understand that personal data must be processed lawfully, fairly, and transparently, be collected and applied only for specified, explicit and legitimate purposes, must be limited to only what is required, must be accurate, not be kept in personally identifiable form for longer than is necessary and must be secured and protected pursuant to the GDPR.
16.4. Sensitive personal data, or special categories of personal data as defined under the GDPR, which includes data about an individual’s race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, health information as well as genetic and biometric data, are collected by us. The processing of such sensitive personal data is limited to the purposes and uses set out under this Privacy Policy.
16.5. We acknowledge and agree that the GDPR affords EU Individuals with rights such as:
(a) Right to access and obtain a copy of the EU Individuals’ personal data, including the purposes of processing and who the personal data has been disclosed to;
(b) Right to rectify inaccurate personal data concerning the EU Individual;
(c) Right to erasure of personal data concerning the EU Individual in certain circumstances;
(d) Right to restriction of processing of personal data in certain circumstances, such as where the accuracy of the personal data is contested, or the processing is unlawful;
(e) Right to data portability by receiving personal data concerning the EU Individual or data which has been provided to us, in a structured, commonly used and machine-readable format, and the right to transmit that data to another organisation;
(f) Right to object to the processing of personal data in certain circumstances, including for the purposes of direct marketing; and
(g) Right not to be subject to automated decision-making (including profiling) where this has a legal effect on the EU Individual or significantly affects him.
16.6. We agree that we will act on a request from an EU Individual without undue delay (within one month). We will maintain records of how we process personal data, acknowledge the need to conduct data protection impact assessments and the need to apply careful consideration in the adoption and engagement of our data processors.
16.7. Where you are an EU individual, we are required to:
(a) investigate any reported actual or suspected data security breach;
(b) where applicable, make the required report of a data breach to any relevant supervisory authority without undue delay and, where possible within 72 hours of becoming aware of it, if it is likely to result in a risk to the rights and freedoms of individuals; and
(c) notify the affected individuals if a data breach is likely to result in a high risk to their rights and freedoms and notification is required by law.
16.8. By proceeding with or continuing with the use of the Platform, you agree that this Privacy Policy and the Terms and Conditions of the Minglo Platform provide sufficient protection to your personal data rights under the GDPR. You also agree that where the company has acted on your request in accordance with clause 17.5, the action by the company is in all respects, compliant with the GDPR.
17. MODIFICATIONS OF THIS PRIVACY POLICY
17.1. We reserve the right to update or modify this Privacy Policy at any time and from time to time. By continuing to use the Services after any such changes, you agree to follow and be bound by this Privacy Policy as changed. For these reasons, we encourage you to periodically review this Privacy Policy for the latest version.
17.2. We may, from time to time, modify or update this Privacy Policy where required under or by any data protection laws applicable to the Minglo Platform and/or the Services.
18. HOW TO CONTACT US
18.1. If you have any questions, comments, requests, or concerns related to this Privacy Policy or the privacy practices for our service, please contact us at:
ATRAE, INC 106-00451-10-10 Azabujuban, Minato-ku, Tokyo, Japan8th floor, Joule A Attention: Chief Data Protection Officer
Email: privacy@atrae.co.jp
You may also contact our Data Protection team: Security Project Team
19. ENGLISH VERSION AND OTHER LANGUAGES
19.1. If there is a conflict between this English version of the Privacy Policy and the corresponding versions in other languages, the terms in this English version shall prevail.
