Privacy Policy
Introduction
The Cold Fusion Wallet (Singapore) Co. Ltd (collectively "CFW", "We" or "Our") has established a vision to respect, protect, and promote privacy. We are committed to safeguarding your privacy and strive to maintain your trust and confidence when handling your personal or financial information.
This Privacy Policy (the "Policy") explains how we collect, use, store, share, delete, and protect your personal data when you interact with us in any of the following ways:
- Using and accessing our mobile application and services (the "Services")
In this Policy, "personal data" refers to information that can identify you directly or indirectly, whether true or not. The use of our Services requires the provision of various types of personal data for different purposes. According to Singapore's Personal Data Protection Act 2012 (the "PDPA"), personal data refers to information about an individual that can be identified. This Policy describes your choices regarding your personal data and how to contact us for more information about our privacy practices.
We encourage you to read this Privacy Policy carefully to help you make informed decisions when enjoying our services.
Collection and Use of Personal Data
Registering as Our Member
With your consent, we will use your data to communicate with you, process your requests, and provide products or services. Before this, you need to register as our member and provide the following:
- Account Information:
- password
To provide product features, analyze performance, resolve errors, and ensure the basic usability and stability of the product, we address operational errors or product issues you encounter during use based on your consent and our legitimate interests in improving the experience and security.
- Automatically Collected Technical Data:
- Device type, model, and related operating system
- Language and time zone settings
- Diagnostic data: crash logs
Identity Verification
We provide services for individual and institutional clients and collect different types of data. Before conducting any transactions or using related services, we need to verify identity and address in accordance with KYC (Know Your Customer), AML (Anti-Money Laundering), and CFT (Countering the Financing of Terrorism) laws and regulations. We need to collect this data to fulfill our contractual obligations with you and comply with regional financial laws or regulations. Such data will be used for identity verification purposes, such as onboarding and two-factor authentication (2FA) unbinding. The data we collect and use may include:
- Contact Data:
- Phone number
- Email address
- Biometric Data:
- Facial biometric data (photos or videos). Used for automated biometric verification and identification.
- Identity Data (Individual Clients):
- Name
- Gender
- Date of birth
- Country and region
- Postal address
- Occupation
- Source of Income
- Government identification documents (residence permit, passport, driver's license, national ID, etc.)
- Proof of address (e.g., utility bills)
- Institutional Data (Corporate Clients):
- Certificate of incorporation
- Headquarters location (e.g., utility bills and office address)
- Names of affiliated entities
- List of official directors and beneficial owners
- Articles of association
- Organizational ownership chart
- Financial history and details (investment activities, bank statements, balance sheets, etc.)
Our Policy Towards Children
Our services are not directed at children, and we restrict the use of our services to individuals who are 16 years of age or older, or the legal age of majority in their respective jurisdictions. We do not knowingly or intentionally collect or process any data related to children.
Without conducting the KYC process, we are unable to identify if children have provided us with personal data. If we become aware that a child has provided us with personal data, we will take steps to delete such information as soon as possible.
International Data Transfers
We operate globally and may need to transfer your personal data internationally. Your personal data may be processed outside your country of residence. Data protection laws vary by country, with some providing more protection than others. Regardless of where your personal data is processed, we apply the same protection measures described in this policy. We transfer your personal data in accordance with the legal frameworks required by different jurisdictions. Recipients of personal data must agree to provide data protection and at least the same level of privacy safeguards as required by applicable data protection laws.
Retention of Your Personal Data
We will retain your personal data for as long as necessary to fulfill business and legal purposes, including financial, tax, and accounting purposes, or as otherwise notified to you. The specific retention period varies depending on the nature of the information, its use, and whether it has been anonymized. We also consider the minimum necessary retention periods prescribed by applicable laws, industry-standard recommended retention periods, and the retention periods specified in contracts and other legal obligations.
Personal data collected for the purpose of fulfilling contracts or complying with legal obligations under financial or anti-money laundering laws may be retained after the completion of transactions, typically required to be kept for 5 to 10 years, depending on the relevant laws or regulations in different jurisdictions.
Based on your consent, we address operational errors or product issues encountered during your use to improve experience and security.
Additionally, personal data we collect will be retained for up to 2 years after you cancel your membership. You may also request deletion according to the "Your Rights and Choices" section below.
Your Rights and Choices
Depending on your jurisdiction, you may have different rights as described below. Regardless of your jurisdiction, you can always contact our Data Protection Officer (DPO) at dpo@cfwpro.com to exercise your data protection and privacy rights. We will respond to your request within 15 working days after verifying your identity or within the time frame specified by local laws.
Jurisdictions with Applicable PDPA and Equivalent Protection Laws:
- Right to Information: You have the right to know how your personal data is being collected and used. This policy aims to fulfill that purpose and will notify you of any changes to this policy.
- Right to Access: You have the right to request a copy of your personal data that we hold.
- Right to Rectification: You have the right to request correction of any information you believe is inaccurate. You also have the right to request us to complete information you believe is incomplete. Some corrections can be made directly through our app, such as changing your login password, while other corrections may require you to contact us, such as updating your KYC documents.
- Right to Erasure: You have the right to request the deletion of your personal data. However, we are required to retain certain data to comply with legal obligations, and such data cannot be deleted during the retention period. For example, in South Korea, the Electronic Commerce Act requires companies to retain data related to payment transactions for 5 years.
- Right to Deletion: If you no longer use our application, you can delete your account. Additionally, you need to manage any assets in your account before deletion; otherwise, they will be considered abandoned.
- Right to Object to Processing: In certain circumstances, you have the right to object to the processing of your personal data. Please note that if you object to the processing of certain data, you may not be able to perform any transaction activities, as such data is necessary for contract fulfillment or compliance with our legal obligations.
- Right to Restriction of Processing: You have the right to request the restriction of processing your personal data. Note that when you restrict the processing of certain data, you may be unable to perform any transaction activities, as such data is necessary for contract fulfillment or compliance with our legal obligations.
- Right to Withdraw Consent: When we process your personal data based on your consent, you have the right to withdraw that consent at any time. For example, if you request account deletion, the service will automatically restore your rights if you log in within 14 days after the deletion request.
- Right to Data Portability: In certain circumstances, you have the right to request the transfer of your personal data to you or a third party of your choice.
Data Protection Officer
We have appointed a Data Protection Officer (DPO) who is responsible for overseeing enquiries in relation to this Privacy Policy. If you have any enquiries or feedback about this Privacy Policy, our privacy practices or if you wish to make any request pertaining to your rights in respect of your personal data, please contact our DPO Team in the following manner: Email: dpo@cfwpro.com
Changes and Notifications of This Policy
We may update this privacy policy from time to time. Any such changes will not reduce your rights under this privacy policy. We will always indicate the date of the last update and make archived versions available for your review. If the changes are significant, we will provide a more prominent notice, including but not limited to, notifications on the product front end, email notifications, and/or SMS notifications. We encourage you to regularly review our privacy policy to stay informed about our data protection practices.
