Privacy Policy

This Privacy Policy (“Policy”) sets out the basis which Multipolitan Pte. Ltd. (“we”, “us”, or “our”) may collect, use, disclose or otherwise process Personal Data of our customers and users of our website www.multipolitan.com (the “Site”) in accordance with the Personal Data Protection Act (“PDPA”).This Policy applies to Personal Data in our possession or under our control, including Personal Data in the possession of organizations which we have engaged to collect, use, disclose or process Personal Data for our purposes.

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1. Interpretation

1.1. In this Policy the following terms shall have the meaning as described:“Customer”, “you” or “your” means an individual who (a) has contacted us through any meansto find out more about any products or services we provide, or (b) may, or has, entered into anagreement with us for the supply of services or products by us, or (c) connects its wallet withour Site, or (d) has received an invitation code to access our Site; and“PDPA” means Personal Data Protection Act“Personal Data” means data, whether true or not, about a customer who can be identified: (a)from that data; or (b) from that data and other information to which we have or are likely tohave access.“Site” means our website under http://www.multipolitan.com

1.2. Depending on the nature of your interaction with us, some examples of Personal Data that wemay collect from you include your name and identification information such as your Passport/NRIC number, contact information such as your address, email address or telephone number,nationality, gender, date of birth, marital status, photographs and other audio-visualinformation, employment information and financial information such as credit card numbers,debit card numbers or bank account information.1.3. Other terms used in this Policy shall have the meanings given to them in the PDPA (where thecontext so permits).

1.3. Other terms used in this Policy shall have the meanings given to them in the PDPA (where thecontext so permits).1.2. Depending on the nature of your interaction with us, some examples of Personal Data that wemay collect from you include your name and identification information such as your Passport/NRIC number, contact information such as your address, email address or telephone number,nationality, gender, date of birth, marital status, photographs and other audio-visualinformation, employment information and financial information such as credit card numbers,debit card numbers or bank account information.1.3. Other terms used in this Policy shall have the meanings given to them in the PDPA (where thecontext so permits).

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2 Collection, Use and Disclosure of Personal Data

‍2.1. We generally do not collect your Personal Data unless (a) it is provided to us voluntarily by you directly or via a third party who has been duly authorised by you to disclose your Personal Data to us (your “authorised representative”) after (i) you (or your authorised representative) have been notified of the purposes for which the data is collected, and (ii) you (or your authorised representative) have provided written consent to the collection and usage of your Personal Data for those purposes, or (b) collection and use of Personal Data without consent is permitted or required by the PDPA or other laws. We shall seek your consent before collecting any additional Personal Data and before using your Personal Data for a purpose which has not been notified to you (except where permitted or authorised by law).

2.2. Please note that as you interact with us via the Site, we automatically collect technical dataabout your equipment, browsing actions, patterns and wallet addresses (private keys). Suchinformation is collected by using cookies, server logs and other similar technologies. By usingthe Site, you confirm that we are entitled to collect such data from you.

2.3. We may collect and use your Personal Data for any or all of the following purposes:

2.3.1. performing obligations in the course of or in connection with our provision of the productsand/or services requested by you;

2.3.2. verifying your identity;

2.3.3. responding to, handling, and processing queries, requests, applications, complaints, andfeedback from you;

2.3.4.managing your relationship with us;

2.3.5. processing payment transactions;

2.3.6. complying with any applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority;

2.3.7. any other purposes for which you have provided the information;

2.3.8. transmitting to any unaffiliated third parties including our third-party service providers andagents, and relevant governmental and/or regulatory authorities, whether in Singapore orabroad, for the aforementioned purposes; and

2.3.9. any other incidental business purposes related to or in connection with the above.

2.4. We may disclose your Personal Data:

2.4.1. where such disclosure is required for performing obligations in the course of or in connection with our provision of the products or services requested by you; or

2.4.2. to third party service providers, agents and other organisations we have engaged to perform any of the functions listed in clause 1.5 above for us.

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

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3 Withdrawing Your Consent

‍3.1. The consent that you provide for the collection, use and disclosure of your Personal Data willremain valid until such time it is being withdrawn by you in writing. You may withdraw consentand request us to stop using and/or disclosing your Personal Data for any or all of the purposeslisted above by submitting your request in writing or via email to our Data Protection Officer at the contact details provided below.

3.2. Upon receipt of your written request to withdraw your consent, we may require reasonabletime (depending on the complexity of the request and its impact on our relationship with you)for your request to be processed and for us to notify you of the consequences of us acceding tothe same, including any legal consequences which may affect your rights and liabilities to us. Ingeneral, we shall seek to process your request within twenty (20) business days of receiving it.

3.3. Whilst we respect your decision to withdraw your consent, please note that depending on the nature and scope of your request, we may not be in a position to continue providing our products or services to you and we shall, in such circumstances, notify you before completingthe processing of your request. Should you decide to cancel your withdrawal of consent, please inform us in writing in the manner described in clause 3.1 above.

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

Access to and Correction of Personal Data

‍4.1. If you wish to make (a) an access request for access to a copy of the Personal Data which wehold about you or information about the ways in which we use or disclose your Personal Data,or (b) a correction request to correct or update any of your Personal Data which we hold aboutyou, you may submit your request in writing or via email to our Data Protection Officer at thecontact details provided below.

4.2. Please note that a reasonable fee may be charged for an access request. If so, we will informyou of the fee before processing your request.

4.3. We will respond to your request as soon as reasonably possible. Should we not be able torespond to your request within thirty (30) days after receiving your request, we will inform youin writing within thirty (30) days of the time by which we will be able to respond to your request.If we are unable to provide you with any Personal Data or to make a correction requested byyou, we shall generally inform you of the reasons why we are unable to do so (except where weare not required to do so under the PDPA).

Protection of Personal Data

‍5.1. To safeguard your Personal Data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, we have introduced appropriate administrative, physical and technical measures such as up-to-date antivirus protection, encryption and the use of privacy filters to secure all storage and transmission of Personal Data by us, and disclosingPersonal Data both internally and to our authorised third party service providers and agentsonly on a need-to-know basis.

5.2. You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive toprotect the security of your information and are constantly reviewing and enhancing ourinformation security measures.

5.3. Please note that we have no power over third-party applications and plug-ins that collect your Personal Data.

Accuracy of Personal Data‍

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

Retention of Personal Data

‍7.1. We may retain your Personal Data for as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws.

7.2. We will cease to retain your Personal Data, or remove the means by which the data can beassociated with you, as soon as it is reasonable to assume that such retention no longer servesthe purpose for which the Personal Data was collected, and is no longer necessary for legal orbusiness purposes.

Transfers of Personal Data Outside of Singapore

‍8.1. We generally do not transfer your Personal Data to countries outside of Singapore. However, if we do so, we will obtain your consent for the transfer to be made and we will take steps toensure that your Personal Data continues to receive a standard of protection that is at leastcomparable to that provided under the PDPA.

8.2. This Site uses functions of the web analysis service Google Analytics. The provider of this service is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.Google Analytics enables us to analyse the behaviour patterns of you while on the Site. To thatend, we receive a variety of user data, such as pages accessed, time spent on the page, theutilized operating system and the user’s origin. This data is assigned to the respective end deviceof the user. An assignment to a user-ID does not take place.

Third Party Links

‍9.1. Our Site includes links to third-party websites. By clicking on such links and visiting the linkedwebsites, you may allow third parties to collect or share data about you. We are not in controlof any data you share willingly or unwillingly with such third-party websites and recommendyou to read the third party’s privacy policies to better understand their use of your data.

Data Protection Officer

‍9.2. You may contact our Data Protection Officer if you have any inquiries or feedback on ourPersonal Data protection policies and procedures, or if you wish to make any request, under thefollowing email address: dpo@Multipolitan.com

Effect of Policy and Changes to Policy

‍11.1. This Policy applies in conjunction with any other notices, contractual clauses and consentclauses that apply in relation to the collection, use and disclosure of your Personal Data by us.

11.2. We may revise this Policy from time to time without any prior notice. You may determine if any fsuch revision has taken place by referring to the date on which this Notice was last updated.Your continued use of our services constitutes your acknowledgment and acceptance of suchchanges.

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