Getstan Technologies Pte Ltd (“Company”) has built the [●] application as a free-to-use
mobile application, along with the website at [●] (collectively referred to as the
“Platform”), and the offered content therein,
which is provided to users (“User”) at
no cost and is intended for use as is. This page is used to inform website visitors regarding
Company’s policies in relation to the collection, use, and disclosure of personal information of
anyone using Company’s Services through the Platform.
If User chooses to use any of the Services, then User agrees to the collection
and use of information in accordance with this policy. The Personal Information that Company collects is
used for providing and improving the Service. Company does not use or share User’s information with
End User License Agreement (“EULA”), which are
accessible at the [●] application and
- Company will collect Personal Information by lawful and fair
means and, with the knowledge or consent of the User concerned.
- Before or at the time of collecting Personal Information,
Company will identify the purpose for which information is being collected.
- Company will collect and use Personal Information solely for
fulfilling those purposes specified by Us and for other ancillary purposes, unless Company obtains the
consent of the individual concerned or as required by law.
- Company will protect Personal Information by using reasonable
security safeguards against loss or theft, as well as unauthorized access, disclosure, copying, use or
- Company will make readily available to Users/Users information
about Company’s policies and practices relating to the management of Personal Information.
- Company will only retain Personal Information for as long as
necessary for the fulfilment of those purposes.
Please do note that Personal Information and non-personal information may be treated
- Application and Scope
collection, use and disclosure of Personal Information by Company.
Information and to satisfy the relevant and applicable legal requirements. This Policy sets out the
standards, responsibilities, rights and obligations of the Company in respect of any Personal Information
collected, accessed or processed by Company in the course of its business operations and specifies the
obligations of Company that arise from Company’s End User License Agreement (“EULA” available here) (the “Terms”) entered into between
Company and its Users/ Users, whereby Company might handle or have access to Personal Information.
This Policy also governs how Company uses and discloses Personal Information
technologies. If User does not agree with this Policy, then User should not access, or use the Platform and
any related Services.
This Policy is an electronic record in the form of an electronic contract formed
under the applicable laws of Singapore. This Policy does not require any physical, electronic or digital
This Policy is published and shall be construed in accordance with the provisions of
and transfer of sensitive personal data or information.
- Definition of Personal Information: “Personal Information”
means any information about an identifiable individual, including email addresses, contact details,
information regarding User’s transactions on the Platform, User’s financial information,
e-wallet address, internet protocol address, information provided to Company in the course of its
business operations, or which Company may receive from business inquiries and any other items
of “sensitive personal data or information” as such term is defined
under the laws of Singapore, identification code of User’s communication
device which User uses to access the Platform or any other information that User provides during
User’s registration process, on the Platform. Personal Information that is aggregated and/or
de-identified or that cannot be associated with an identifiable individual is not considered to be
- Collection and Use of Personal Information through the Services
When providing the Services, Company only processes Personal Information in
accordance with the EULA and applicable laws. Company generally uses Personal Information from or about its
Users for the following purposes:
- to create, establish and administer User’s account, to process
payments, to respond to User’s inquiries related to his/her account and to contact User about
Company’s Services or account-related
- to provide Services, including to provide Users with access and use
of the Platform and User support;
- to manage and develop Company’s business and
- to measure and analyze User behavior;
- to monitor, maintain and improve Company’s Services or
- to understand how Users interact with Company and ensure
Company’s Services, products or features work correctly;
- to develop new services, products, features, programs and
- to understand Users’ needs and preferences and customize how
Company tailors and markets products, programs and Services to Company’s Users based on their
- to meet legal and regulatory requirements and to allow Company to
meet contractual requirements relating to the Services provided to User;
- to conduct surveys on the quality of Services or to collect
feedbacks on the Services;
- to provide User with offers for additional services, features and
products that Company believes may be of interest to User;
- to send User important information regarding the Platform, changes
in EULA, user agreements, and policies and/or other relevant information;
- to implement information security practices and to determine any
security breaches, computer contaminant or computer virus;
- to investigate, prevent, or take action regarding illegal activities
and suspected fraud;
- to enable a potential buyer or investor to evaluate the business of
- to conduct market or benchmarking research and data analytics by
tracking and analyzing current or previously collected Personal Information; and
- to measure the effectiveness of Company’s marketing.
When possible, Company will use Personal Information in an aggregated and/or
de-identified format. Unless required or authorized by law, Company will not use Personal Information for
any other or new purpose without obtaining prior consent.
- Collection and Use of Personal Information through the
Company generally collects and uses Personal Information from or about its Platform
Users as follows:
- For Creation of Account: For
enabling the access to the Services, User needs to create an account. In order to manage such account
from creation to deletion, the Company shall collect and process identification Personal Information
such as User’s first name, last name, username and contact details).
- For use of Services: The Company
collects and processes User’s Personal Information for the use of the Services. This processing
requires the Company to collect and process the following categories of Personal Information:
- for the purchase, transfer, withdrawal and exchange of
Collectibles: username and the blockchain public keys or payment identifier and part of User’s
bank card's digits;
- for the participation in the Stan Trump Game: username, blockchain
public keys and prize winners;
- for leaderboard: username.
- The legal basis on which the Company relies for this purpose is the
performance of a contract to which User is a party.
- Information Provided by Users. In many
cases, Company collects Personal Information directly from Users when they visit or use the Platform.
For instance, Company may collect the following types of information:
- Inquiries and Requests for a Trial or Service. Company may collect Users’ name, contact information, email address and any other
information provided when Users make an inquiry or contact Company through the Platform, when Users sign
up to receive Company’s newsletter/updated about events or when Users submit a request or an order
for a Company trial for Service.
- Personalization of Platform: When Users
visit the Platform, they may, from time to time, be invited to provide information such as User’s
title to help Company personalize or customize the User’s experience when using the
- Payment Processing: In connection with
the payment of any Service on the Platform or through any other linked platform (whether offered by
Company or its partners), Company may seek further information pertaining to the payment
instrument/modes used by the User for payments towards such Service fee.
- Technical Information: When Users visit
the Platform, Company may collect, using electronic means such as cookies, technical information. This
information may include information about visits to the Platform, including the IP address of the
Users’ computer and which browser was used to view the Platform, the Users’ operating
system, resolution of screen, location, language settings in browsers, the site the User came from,
keywords searched (if arriving from a search engine), the number of page views, information entered,
advertisements seen, etc. This data is used to measure and improve the effectiveness of the Platform or
enhance the experience for Users. While most of the time this information is depersonalized, if this
information relates to an identifiable individual, Company will treat this information as Personal
Information. Company may also, without limitations, collect and use the following type of information
when Users visit and/or interact with Company on the Platform:
- Google Analytics: Company uses Google
Analytics which allows it to see information on User Platform activities including, but not limited to,
page views, source and time spent on the Platform. This information is depersonalized and is displayed
as numbers, meaning that it cannot be tracked back to individuals. Users may opt-out of Company’s
use of Google Analytics by visiting the Google Analytics opt-out page.
- HubSpot:[a] Company uses HubSpot which allows it to see
information on Platform activities including, but not limited to, page views, source and time spent on
the Platform. However, this information is not depersonalized and Users may not opt-out of
Company’s use of HubSpot.
- Google AdWords: Company uses Google
AdWords Remarketing to advertise Company across the Internet and to advertise on third party websites
(including Google) to previous visitors of the Platform. AdWords remarketing will display ads to Users
based on what parts of the Platform they have viewed by placing a cookie on the Users’ web
browser. It could mean that Company advertises to previous visitors who haven’t completed a task
on the site or this could be in the form of an advertisement on the Google search results page, or a
site in the Google Display Network. This cookie does not in any way identify the User or give access to
the Users’ computer or mobile device. The cookie is only used to indicate to other websites that
the User has visited a particular page on the Platform, so that they may show the User ads relating to
that page. If Users do not wish to participate in Google AdWords Remarketing, they can opt out by
visiting Google’s Ads Preferences Manager.
- Interest-based Advertising. Company may
also allow a limited number of trusted third parties to install cookies on Users’ hard drive from
the Platform. The Platform may include third-party advertising and links to other websites which may be
used to generate personalized advertisements. Personalized ads, sometimes referred to as interest-based
or behavioral ads, are ads based upon information about Users, such as page views on the Platform,
information requests or purchases on the Platform. Company does not provide any Personal Information to
advertisers or to third party sites that display interest-based ads on the Platform. However,
advertisers and other third-parties (including the ad networks, ad-serving companies, and other service
providers they may use) may assume that Users, who interact with or click on a personalized ad or
content displayed on the Platform are part of the group that the ad or content is directed towards.
Advertisers or ad companies working on their behalf sometimes use technology to serve the ads that
effectiveness of their ads and to personalize ad content. Company does not have access to or control
over cookies or other features that advertisers and third-party sites may use, and the information
practices of these advertisers and third party Platform are not covered by this Policy. Please contact
them directly for more information about their privacy practices.
- Segment: Company uses Segment which
allows it to transmit user Platform activities including, but not limited to, page views, source and
time spent on the Platform to Company’s data
warehouse. This information is depersonalized and is displayed as numbers, meaning that it cannot be
tracked back to individuals. Users may not opt-out of Company’s use of Segment.
- Choice with Cookies. Users can block
consent, or subsequently block cookies, they may not be able to access all or part of the content of the
Platform. Additionally, Users can disable or delete similar data used by browser add-ons, by changing
the add-on’s settings or visiting the Platform.
- Privacy Policies of other Platform:
This Policy only addresses the use and disclosure of information by Company. Other platforms that may be
accessible through the Platform have their own privacy policies and data collection, use and disclosure
- Personal Information from Other Sources: Company may obtain from third parties additional Personal Information about a Platform User
if such User gave permission to those third parties to share its information.
- Sharing of Personal Information
Company will not sell, rent or trade Personal Information to any third party.
However, Company may share Personal Information when authorized and/or required by law or as follows:
- Within Company: Company may share
Personal Information within Company (i.e. between Company’s affiliates and subsidiaries) in
Singapore and overseas for the purposes described in this Policy.
- Service Providers: Company may grant
access to Personal Information to third-party service providers in connection with the performance or
the improvement of its Platform and Services. Before sharing any Personal Information with any of its
third-party service providers, Company will request that the third party maintains reasonable data
management practices for maintaining the confidentiality and security of Personal Information and
preventing unauthorized access. Provided however, the Company shall not be responsible for any misuse or
unauthorized disclosure of any Personal Information by such third party service provider. Company shall
inform the User of such unauthorized disclosure as soon as reasonably possible.
- As Permitted or Required by Law:
Company may disclose Personal Information as required by applicable law or by proper legal or
governmental authority. Company may also disclose information to its accountants, auditors, agents and
lawyers in connection with the enforcement or protection of its legal rights. Company may also release
certain Personal Information when it has reasonable grounds to believe that such release is reasonably
necessary to protect the rights, property or safety of others and itself, in accordance with or as
authorized by law. In the event Company receives a governmental or other regulatory request for any
Personal Information, Company will promptly notify User, unless it is prohibited to do so, in order that
User shall have the option to defend such action. Company shall reasonably cooperate with User in such
- Business Transaction: Company may
disclose Personal Information to a third party in connection with a sale or transfer of business or
assets, an amalgamation, re-organization or financing of parts of Company’s business. However, in
the event the transaction is completed, Personal Information will remain protected by applicable data
protection laws of Singapore. In the event the transaction is not completed, Company will require the
other party not to use or disclose the Personal Information received in any manner whatsoever.
- User Contributions
Company’s User agrees not to host, display, upload, modify, publish,
transmit, store, update or share any information that:
- belongs to another person and to which User do not have any
- includes bodily privacy, insulting or harassing, that is
libelous, racially or ethnically objectionable, relating or encouraging money laundering or gambling, or
otherwise inconsistent with or contrary to the laws in force;
- is harmful to children;
- infringes any patent, trademark, copyright, or other
- violates any law for the time being in force;
- deceives or misleads the addressee about the origin of the
message or knowingly and intentionally communicates any information which is patently false or
misleading in nature but may reasonably be perceived as a fact;
- impersonates another person;
- threatens the unity, integrity, defence, security or
sovereignty of Singapore, friendly relations with foreign states, or public order, or causes incitement
to the commission of any cognizable offence or prevents investigation of any offence or is insulting
other nation; and/or
- contains software virus or any other computer code, file or
program designed to interrupt, destroy, or limit the functionality of any computer resource.
- Log Data
Whenever User uses Service, Company collects data and information (through third
party products) on User’s phone called Log Data. This Log Data may include information such as
User’s device Internet Protocol (“IP”) address, device name, operating system version, the
configuration of the app when utilizing Service, the time and date of User’s use of the Service, and
- Cross-border data transfer
Personal Information that Company holds about User may be transferred to countries
his/her consent for transfer of such Personal Information outside Singapore. Any Personal Information will
- Security and Consent
Company has in place physical, electronic and administrative safeguards to protect
User’s Personal Information. User’s posting and sharing of Personal Information through the
Platform constitutes User’s acceptance of the risk that Company cannot guarantee absolute security,
and User hereby agrees to waive any claims that User may have against us and any right to seek legal relief
from us due to any misuse of the Personal Information in the manner aforesaid.
Company will store and process the Personal Information in a manner consistent
with industry security standards, and as long as necessary for the purposes described in this Policy, unless
a longer retention is required by law. Company has implemented technical, organizational and administrative
systems, policies, and procedures to help ensure the security, integrity and confidentiality of Personal
Information and to mitigate the risk of unauthorized access to or use of Personal Information, including:
(i) appropriate administrative, technical and physical safeguards and other security measures designed to
ensure the security and confidentiality of the Personal Information it manages; (ii) a security design
intended to prevent any compromise of its own information systems, computer networks or data files by
unauthorized Users, viruses or malicious computer programs; (iii) appropriate internal practices including,
but not limited to, encryption of data in transit; using appropriate firewall and antivirus software;
maintaining these countermeasures, operating systems and other applications with appropriate reasonable
up-to-date virus definitions and security patches so as to avoid any adverse impact to the Personal
Information that it manages; (iv) appropriate logging and alerts to monitor access controls and to assure
data integrity and confidentiality; and (v) permitting only authorized users access to systems and
applications (together, “Security Program”). However, Company understands that as effective as Company’s security measures
are, no security system is impenetrable. Thus, Company cannot guarantee the security of Company’s
database, nor can Company guarantee that information User supplies will not be intercepted while being
transmitted to Company over the internet.
Company maintains adequate training programs to ensure that its employees and any
others acting on its behalf are aware of and adhere to its Security Program.
User has the right to withdraw his/her consent at any point, by contacting Company
at [●]. Once consent is withdrawn, Company will be unable to provide User with the Service.
- Links to Other Sites[c]
This Service may contain links to other sites. If User clicks on a third-party
these websites before proceeding to avail any services or engaging in a transaction with such third-party
websites. Company has no control over and assume no responsibility for the content, privacy policies, or
practices of any third-party sites or services.
- Children’s Privacy
The Services do not address anyone under the age of [●]. Company does not
knowingly collect personally identifiable information from children under the age of [●]. In the event
that Company discovers that a child under the age of [●] has provided Company with Personal
Information, Company shall immediately delete such Personal Information from Company’s servers. If
User is a parent or guardian and User is aware that User’s child has provided Company with Personal
Information, please contact Company so that Company is able to take necessary actions.
review this page periodically for any changes. Company will notify User of any changes by posting the new
after they are posted on this page. User’s continued use of this Platform, Company’s Services or
providing Company with User’s Personal Information shall signify consent and acceptance of the terms
- Governing Law
jurisdiction of courts in Singapore.
- Grievance Redressal Mechanism
In accordance with the [Name of Singapore Information Technology Law] and its
Company’s Grievance Officer as provided below:
The Grievance Officer shall acknowledge receipt of User’s complaint
within [●] hours and shall dispose of the same within [●] days of receipt.
Company at [●].
- Data Deletion
Account Deletion Instructions can be found in this link.
[a]To be retained, if applicable
[b]To be confirmed by Getstan