XTINGLES PTE LTD

531A Upper Cross Street, #04-98

Hong Lim Complex

Singapore 051531

UEN: 202113421N

xtingles Data Privacy Policy

This privacy policy (this “Privacy Policy”) describes how we collect, use, and share data that we obtain through your use of the Internet sites, applications, email and newsletter communications, and online services, including Discord group, (the “Site”) operated by, controlled by, or affiliated with XTINGLES (collectively, “xtingles,” “we,” “us,” or “our”).

By using the Site, you agree to the practices described in this Privacy Policy and any updates posted here from time to time. To make sure you stay informed of all changes, you should check this Privacy Policy periodically. Updates will be referenced by the “Last Modified” date shown above.

This Privacy Policy is governed by and shall be construed in accordance with the laws of the Republic of Singapore and in compliance with the Personal Data Protection Act (2012) of Singapore (the “PDPA”)

Any dispute arising out of or in connection with this Privacy Policy shall be subject to the exclusive jurisdiction of the courts of the Republic of Singapore.

Consent

Please understand that by utilizing the Site and submitting any personal data to us, you consent and agree that we may collect, use and disclose such personal data in accordance with this Privacy Policy and our Terms of Use, and as permitted or required by law. If you do not agree with these terms, then please do not provide any personal data to us. If you refuse or withdraw your consent, or if you choose not to provide us with any required personal data, you not be able to utilize all aspects of the Site.

Collection of Data

The information collected from you may constitute Personal Data under the PDPA. “Personal Data” is defined under the PDPA to mean any data, whether true or not, about an individual who can be identified from that data or from that data and other information to which an organization has or is likely to have access. This would include, without limitation, information such as name, address, telephone number, e-mail address, credit card details and any other personal information.

xtingles will be free to use, collect and disclose information that is freely available in the public domain without your consent. Information that is business contact information such as your name, position name or title, business telephone number, business address, business electronic mail address or business fax number and any other similar information about you, which are not provided by you for personal purposes, will not be regarded as Personal Data under the PDPA. Your consent to us collecting, using and disclosing any business contact information will not be required. Information you voluntarily provide to us through our Site shall be deemed to be collected with your permission. Such information may include any Personal Data or other information necessary to utilize our Site.

In order for you to fully utilize the Site and join the xtingles community, you may need to create a user profile. xtingles provides users many different functionalities and needs to collect and process certain information from you to do the same. Depending on how involved you are in the xtingles community, we may collect the following:

  • Information you provide by completing forms on xtingles, including but not limited to, your name, email and postal addresses, telephone number, country of residence, login, and password details. This information may be requested for use of our Site;
  • Information you provide for identity verification purposes, including but not limited to, your legal name, country of residence, business name and Tax ID for business entities, and date of birth;
  • Details of any transactions from use of the Site. xtingles partners with third parties for certain aspects of our platform, including payments, and the information provided to such third parties is collected and used in accordance with their privacy policies;
  • Information about your activity on and interaction with the xtingles platform, including use of our mobile apps (such as your IP address, the type of device or browser you use, and your actions on the Site);
  • Information about how our community members visit and interact with our Site through traffic analytics. You can always opt out;
  • Communications you send to us (for example, when you ask questions or provide comments, or report a problem);
  • Information that you submit on or to xtingles’s forums in the form of comments, discussions, or messages to other users; and
  • The email address associated with your Facebook or Google accounts, if you choose to sign up using your related credentials. xtingles will also request permission to access your name, profile picture, and friend list (these permissions are governed by the related company’s privacy policies and can be managed through your privacy settings). We never post anything to third-party accounts without your permission.

We gather two types of information about users through the Site:

Non-Personal Information

When users come to our Site, we may track, collect and aggregate Non-Personal Information indicating, among other things, which pages of our Site were visited, the order in which they were visited, when they were visited, and which hyperlinks were “clicked.” We also collect information from the URLs from which you linked to our Site. Collecting such information may involve logging the IP address, operating system and browser software used by each user of the Site. Although such information is not Personal Data, we may be able to determine from an IP address a user’s Internet Service Provider and the geographic location of his or her point of connectivity.

We also use or may use cookies and/or web beacons to help us determine and identify repeat visitors, the type of content and sites to which a user of our Site links, the length of time each user spends at any particular area of our Site, and the specific functionalities that users choose to use. Essentially, cookies are a user’s identification card for our servers. Web beacons are small graphic files linked to our servers that allow us to track your use of our Site and related functionalities. Cookies and web beacons allow us to serve you better and more efficiently, and to personalize your experience at our Site. Cookies and web beacons are not used to retain Personal Data. From time to time we may also use additional industry standard methods of collecting data.

You should be able to control how and whether cookies will be accepted by your web browser. If you reject our cookies, many functions and conveniences of this Site may not work properly.

Personal Data

We collect Personal Data that you provide to us when you register for an account, update or change information for your account, sign-up for email updates, participate in our public forums, send us email messages, and/or participate in other aspects of our Site. We may use the Personal Data that you provide to respond to your questions, address specific requests, send you updates or other xtingles events, and send you email messages about Site maintenance or updates. xtingles will be the controller of your Personal Data.

Personal Data that may be collected from you may include, but is not limited to, the following:

Account Registration. If you register for an account on our Site, you may be required to provide us with Personal Data such as your name, email or wallet address, telephone number, passport of identification number or any other information required to register an account.

Use of Services. We may receive your Personal Data, including financial information and Site usage history, when you decide to launch or bid on an Auction, or otherwise utilize the Site.

Use of Site. We may receive your Personal Data, including computer/device and connection information, IP address, cookies, usage history, bandwidth, statistics on page views, when you visit our Site.

Updates. xtingles may offer you the ability to receive updates either via email or by posting on portions of the Site only accessible to registered users. In order to subscribe to these services, you may be required to provide us with Personal Data such as your name, wallet and email address.

Forums. xtingles provides public forums, including our Discord server, for our community members to communicate and share comments and thoughts. In order to participate in the forums, you may be required to register with us and/or provide us with Personal Data such as your name and email address. Personal Data shall not include any information posted or sent by or to you via any public forum. Please keep in mind that information you post or make available in forums will be publicly available. Accordingly, you should be careful when posting any personal or sensitive information. Please also reference our Terms of Use and additional information about proper use of our forums.

Communications with xtingles. We may receive Personal Data when voluntarily provided when you send us an email message or otherwise contact us.

Third Party Sites. We may receive Personal Data when you access or log-in to a third party site, e.g., Facebook, from our Sites. This may include the text and/or images of your Personal Data available from the third party site.

Third Party Payment Processing. xtingles provides you with the ability to pay for works or other participation on the Site with a form of payment through a third party payment processing service provider. Please note that these service providers – not xtingles – collects and processes your information.

Use of Collected Data

Non-Personal Information

We use Non-Personal Information to build higher quality, more useful services by performing statistical analyses of the collective characteristics and behavior of our users, and by measuring demographics and interests regarding specific areas of our Site. We may also use it for other legitimate business purposes.

Personal Data

Except as set forth in this Privacy Policy or as specifically agreed to by you, xtingles will not disclose any Personal Data we gather from you on the Site. In addition to the other uses set forth in this Privacy Policy, we may disclose and otherwise use Personal Data as described below. We may also use it for research and other legitimate business purposes, including improving and customizing the Site and the products and services we offer. In any event, use of your Personal data will be governed by what a reasonable person would consider appropriate under the circumstances.

Updates. We use Personal Data collected when you sign-up for our various email or update services to send you the messages in connection with the Site. We may also archive this information and/or use it for future communications with you.

Forums. To facilitate your use of our community forums, we use Personal Data collected during your use of the forums. In addition, we may publish this information via extensions of our Site that use third-party services, like mobile applications. We also reserve the right to reuse public posts containing Personal Data in the future. We may archive this information and/or use it for future communications with you. We may also use or publish posts submitted on the Forums without using Personal Data.

Identity Verification. For services that require identity verification, we use the Personal Data that we collect for verifying your identity, and for authenticating that submissions made on the Site were made by you. This includes due diligence checks in accordance with applicable laws including Know Your Client, Anti-money Laundering and Countering the Financing of Terrorism policies.

Communications with xtingles. When you send us an email message or otherwise contact us, we may use the information provided by you to respond to your communication and/or as described in this Privacy Policy. We may also archive this information and/or use it for future communications with you.

Communications with Third Parties. We may share your Personal Data with third parties and business partners of xtingles so that they may share information about their products and services that may be of interest to you upon obtaining your express consent for such disclosure.

We may share your information with certain trusted third-party services to help us provide, improve, promote, or protect xtingles’s (like when we partner with payment processors). When we share data with third-party services, we require that they use your information only for the purposes we’ve authorized, and that they protect your Personal Data at least to the same standards we do. We may also share information that’s aggregated and anonymized in a way that it doesn’t directly identify you.

Disclosure to xtingles Operations and Maintenance Contractors. We use various service providers, vendors and contractors (collectively, “Contractors”) to assist us in providing our products and services to you. Our Contractors may have limited access to your Personal Data in the course of providing their products or services to us, so that we in turn can provide our products and services to you. These Contractors may include vendors and suppliers that provide us with technology, services, and/or content related to the operation and maintenance of the Site. Access to your Personal Data by these Contractors is limited to the information reasonably necessary for the contractor to perform its limited function for us.

Government Authorities, Legal Rights and Actions. xtingles may share your Personal Data with various government authorities in response to subpoenas, court orders, or other legal process; to establish or exercise our legal rights or to protect our property; to defend against legal claims; or as otherwise required by law. In such cases we reserve the right to raise or waive any legal objection or right available to us. We also may share your Personal Data when we believe it is appropriate to investigate, prevent, or take action regarding illegal or suspected illegal activities; to protect and defend the rights, property, or safety of xtingles, the Site, our users, customers, or others; and in connection with our Terms of Use and other agreements.

Disclosure to Acquirers. xtingles may disclose and/or transfer your Personal Data to an acquirer, assignee or other successor entity in connection with a sale, merger, or reorganization of all or substantially all of the equity, business or assets of xtingles to which your Personal Data relates.

xtingles shall not collect, use or disclose your Personal Data unless:

  • you consent to the collection, use or disclosure of your Personal Data;
  • the collection, use or disclosure of your Personal Data is necessary for us to perform our contractual obligations owed to you and providing services to you;
  • the collection, use or disclosure of your Personal Data is required or authorized under the PDPA or other written law; or
  • the collection, use or disclosure of your Personal Data is in accordance with the protection of our legitimate interests.

xtingles shall not, require consent to such collect, use or disclosure beyond what is reasonable to achieve such purpose. xtingles shall not obtain or attempt to obtain your consent for collecting, using or disclosing Personal Data by providing false or misleading information with respect to the collection, use or disclosure of your Personal Data, or use deceptive or misleading practices.

Additionally, we may use data for marketing purposes to:

Provide you with additional information regarding products, events, promotions, and services from xtingles and third parties that may be of interest to you via email, text message, or through advertising on various social media platforms or websites (both desktop and mobile) that you may visit; and

Develop, improve, and target our promotional messaging to you and others via retargeting, online behavioral advertising, and use of social media platform tools for advertising (such as creation of Facebook Lookalike Audiences).

Third-Party Websites and Services

Through your use of the Site, you may access, directly or indirectly, other websites or services, including from our service providers, business partners, and other third parties, in each case, that are not owned or controlled by us. Data collection and use by those third parties is subject to the privacy policies of those third parties. It is up to you to review the terms of use and privacy policies of those third parties.

Please also note that when you sign up to receive text messages from us, the privacy policy of our conversation platform partner also applies to the submission of your personal information. In addition, you agree to receive recurring text messages (which may be marketing and/or automated) from or on behalf of xtingles at the phone number you provided at opt-in. Your consent to receive such text messages is not a condition of purchase. Message and data rates may apply and are billed by and payable to your mobile service provider. Delivery of messages are subject to the effective transmission by your mobile service provider and any policies or terms established by your mobile service provider.

Sharing of Collected Data

We may share the data we collect as follows:

With our current and future parents, affiliates, subsidiaries, and other companies under common control and ownership;

With our service providers that perform services for us (such as e-mail and mobile marketing, analytics, and web hosting);

With our sponsors, promotional partners, or event partners in connection with certain contests, sweepstakes, promotions, or ticketed events;

With our third-party vendors and partners that sell items, offer promotions, or provide services to you through our services (either alone or jointly with us);

To comply with a court order or other legal obligation, to enforce the Site terms of use, and to protect the rights, property, or safety of our users and other third parties;

With government or law enforcement officials or private parties (including our legal or other professional advisors) as we determine, in our sole and absolute discretion, is necessary or appropriate to respond to claims or to comply with legal processes, laws, regulations, or ordinances, or to prevent or stop illegal, unethical, or actionable activity;

In connection with, or during negotiations of, any merger, acquisition by another company, or sale of all or substantially all of our business or assets; and

With your consent or at your direction.

Updating or Deleting Your Personal Data

You can access your Personal Data and confirm that it remains correct and up-to-date or choose whether or not you wish to receive material from us or some of our partners by logging into the Site. You may also contact us via hello@xtingles.io. We try to answer every email promptly, but may not always be able to do so. Keep in mind, however, that there will be residual information that will remain within our databases, access logs and other records, which may or may not contain your Personal Data.

If you have any privacy-related questions, unresolved problems, or complaints you may contact us via hello@xtingles.io.

Transfer of Collected Data

The Site is operated in Singapore. If you are located in another jurisdiction, please be aware that the data we collect will be transferred to, stored, and processed in Singapore. By using the Site and/or providing us with any data, you consent to this transfer, processing, and storage of your data in Singapore, a jurisdiction in which the privacy laws may not be as comprehensive as those in the country where you reside or are a citizen such as the European Union. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Notice. We will take all steps reasonably necessary to ensure that your data is subject to appropriate safeguards and ensure that your data is treated securely and in accordance with this Privacy Policy.

Where your Personal Data is to be transferred out of Singapore, we will comply with the PDPA in doing so. This includes obtaining consent from you to transfer your Personal Data overseas, and before you give consent, providing you with a reasonable written summary on the extent of the protection offered to the Personal Data to be transferred overseas, and/or taking appropriate steps to ascertain that the foreign recipient organization of the Personal Data is bound by legally enforceable obligations to provide to the transferred Personal Data a standard of protection that is at least comparable to the protection under the PDPA.

Data Security

We use commercially reasonable technical and organizational measures to help secure and safeguard your data in our possession. However, no data transmission over the Internet is completely secure and no security mechanism is impenetrable. Therefore, although we take steps to protect your data, we cannot guarantee the security of the data that we collect from you or the security of our servers or the Site. By accessing the Site, any transmission of data is at your own risk and you agree to assume all risk in connection with data sent to us or collected by us.

Data Retention

We retain your data only as long as necessary in light of the purpose(s) for which it was originally collected. Please note that we may retain your data for longer periods of time as necessary to comply with our legal obligations or respond to governmental authorities.

We also collect and maintain aggregated, anonymized or pseudonymized information which we may retain indefinitely to protect the safety and security of our Site, improve our Services or comply with legal obligations.

Children and Parents

We respect children’s privacy. We do not target or knowingly or intentionally collect personal data from children under the age of 13. By using the Site, you have represented and warranted that you are either at least 18 years of age or using the Site with the supervision of a parent or guardian. If you are under the age of 13, you may not use the Site. If you become aware that your child has provided us with personal data without your consent, please Contact Us

Your Data Preferences

Cookies, Pixel Tags, and Other Similar Tracking Technologies

You may remove or reject cookies by adjusting settings on your browser, and thus opt-out of certain features of the Site and the Site’s automatic collection of certain data. These tracking technology opt-out tools are device and browser specific so you must repeat the opt-out from each of your devices and browsers. Please note that removing or rejecting cookies could affect the functionality of the Site.

You may also remove certain tracking technologies and opt-out of online behavioral advertising messaging by using the opt-out tools available from the Digital Advertising Alliance (DAA Opt-Out Tool) and the Network Advertising Initiative (NAI Opt-Out Tools).

Advertising Preferences

You may adjust your advertising preferences on various social media websites by adjusting your Settings on the particular platform. For example, you may adjust the types of Facebook ads you receive on Facebook and the types of Google ads you receive on Google.

Your Rights

Right to Access. You have the right to obtain confirmation from xtingles as to whether or not xtingles processes your Personal Data and, where xtingles does so, access to the Personal Data and information including, the details of the purposes of the processing, the categories of Personal Data concerned and the recipients of the Personal Data. xtingles will, at your request, endeavor to provide you with copy of your Personal Data in xtingles’s possession or control within a reasonable period of time.

xtingles may charge you a reasonable fee for administrative costs. However, please note that your right to obtain a copy of your Personal Data is subject to the rights and freedoms of others, and xtingles may have to deny your request should your request adversely affect the rights and freedoms of others.

Right to Rectification. You have the right to have any inaccurate Personal Data about you rectified. In addition, when there are any changes to your Personal Data, xtingles highly encourages you to inform xtingles of any such changes so that xtingles may have an accurate record of your Personal Data.

Right to Erasure. You have the right to request xtingles to delete or remove your Personal Data where your Personal Data is no longer relevant to the original purposes for processing, where xtingles may have processed your information unlawfully, where you have withdrawn your consent to xtingles processing your Personal Data or where xtingles is required to delete or remove your Personal Data pursuant to relevant legislation and regulations. However, please note that xtingles may have deny your request where xtingles is legally required to retain your Personal Data for, inter alia, reasons of public interest or for the establishment, exercise or defense of legal claims.

Right to Restriction of Processing. You have the right to request xtingles to suspend the processing of your Personal Data where you want to establish the accuracy of your Personal Data, where the processing of your Personal Data is unlawful but you do not want xtingles to erase your Personal Data, where xtingles no longer requires your Personal Data for the purposes of processing but you require xtingles to retain your Personal Data for the establishment, exercise or defense of legal claims or where you have objected to xtingles’s processing of your Personal Data but xtingles needs to verify whether xtingles has an overriding legitimate grounds to use your Personal Data.

Right to Object. You have the right at any time to object to xtingles processing your Personal Data on the grounds that there is something about your particular situation that makes you want to object. In addition, you also have the right to object to the processing of your Personal Data for direct marketing purposes. However, in some instances, xtingles may demonstrate that xtingles has compelling legitimate grounds to processing your Personal Data which may override your objection.

Right to Data Portability. You have the right to request xtingles to transfer your Personal Data to you or to a third party of your choosing, in a structured, commonly used, machine-readable format. This right shall only be applicable where the processing of your Personal Data is carried out by automated means, and provided that the request does not affect the rights and freedom of others.

Right to Lodge a Complaint. You have the right to lodge a complaint at any time to the relevant supervisory authority. The relevant authority in Singapore is the Personal Data Protection Commission. However, xtingles endeavors to provide you with the best user experience and therefore would appreciate the opportunity to deal with any concerns you may have before you seek the assistance of the Personal Data Protection Commission.

Right to Withdraw Consent. You have the right to withdraw your consent at any time to xtingles processing your Personal Data. However, the withdrawal of your consent shall not affect the lawfulness of xtingles’s processing of your Personal Data that was based on your consent prior to your withdrawal. You may also withdraw your consent for specific forms of communication and on specific communications via the unsubscribe options as stated on xtingles’s email or other marketing messages.

Please note that in withdrawing your consent, you acknowledge that xtingles may not be able to provide or continue providing certain services to you and that xtingles may cease such provision accordingly without any liability.

To exercise any of your rights as explained above, kindly send your requests to hello@xtingles.io.

We hope that we can fulfill your requests within 30 days. In cases where we may take longer than 30 days, we will notify you and keep you updated. Notwithstanding the foregoing, you agree and acknowledge that there may be circumstances where we may be unable to accede to your request due to legal or contractual obligations.