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SPARROW PRIVACY AND DATA PROTECTION POLICY

The use of the Website entails various types of personal data being provided for various purposes. Under the Personal Data Protection Act (No. 26 of 2012) (the “PDPA”), “personal data” means data, whether true or not, about an individual who can be identified from that data; or from that data and other information to which the organisation has or is likely to have access. The PDPA governs and protects the collection, use, disclose and care of personal data. Organisations will have to comply with the PDPA as well as the common law and other relevant laws that are applied in the specific industry that they belong to, when handling personal data in their possession.

Unless expressly provided otherwise, capitalised terms used in this privacy and data protection policy (the “Privacy Policy”) shall bear the respective meanings ascribed to them in the Terms of Use. This Privacy Policy outlines how Sparrow shall collect and manage personal data.

By accessing the Website and creating a user account with Sparrow, Users agree and consent to Sparrow collecting, using, disclosing and sharing amongst themselves personal data, and disclosing such personal data to relevant third party service providers in accordance with the Privacy Policy. Sparrow may engage or use any service providers (including, but not limited to, KYC solution provider(s)) (“Sub-Processor”) for the processing of personal data or permit any third party to process personal data.

If Sparrow appoints a Sub-Processor, Sparrow will ensure that, prior to the processing taking place, there is a written contract in place between Sparrow and the Sub-Processor that specifies the Sub-Processor's processing activities and imposes on the Sub-Processor the same terms as those imposed on Sparrow in this Privacy Policy.

Users are advised to read this Privacy Policy so that they understand the circumstances and purposes under which Sparrow will collect, use and disclose Users' personal data.

  1. COLLECTION OF PERSONAL DATA

1.1 Users may browse the Website anonymously. However, Users will have to create a user account in order to utilise the services on the Website or receive more information on the Website.

1.2 Generally, Sparrow may collect Users' personal data in the following circumstances:

(i) when the User creates an account with Sparrow;
(ii) when Sparrow implements additional measures to authenticate user identity;
(iii) when the User uses the services offered by Sparrow and/or purchases any products offered by Sparrow;
(iv) when the User carries out transactions on Sparrow's platform; and
(v) when the User submits personal data to Sparrow for any other reason.

1.3 Users authorise Sparrow to process and store such personal data for the purposes provided for in paragraph 2.1 and if applicable, verify such credentials with the relevant social media network.

1.4 If Users provide Sparrow with any personal data relating to a third party, by submitting such information to Sparrow, Users represent to Sparrow that they have obtained the consent of the third party to provide Sparrow with such personal data for the purposes stated in paragraph 2.1.

1.5 Users shall ensure that all personal data submitted to Sparrow is complete and accurate. Any omission or failure to do so may prevent Sparrow from fulfilling the purposes stated in paragraph 2.1.

1.6 Users acknowledge that all personal data submitted to Sparrow is in compliance with all applicable laws relating to data protection including without limitation, the PDPA, the General Data Protection Regulation (EU) 2016/679 as well as the common law and other relevant laws (“Applicable Laws”). If Users are in doubt as to their rights in relation to their personal data, they should consult their solicitors or other professional advisors.

  1. USE OF PERSONAL INFORMATION

2.1 In general, Sparrow collects and uses personal data for the following purposes:

(i) to process the User's application for an account;
(ii) to maintain the User's account;
(iii) to verify the User's identity;
(iv) to provide Users with the products and/or services requested;
(v) to collect information in order to comply and enforce know-your-customer policies and regulations and anti-money laundering and countering the financing of terrorism laws and regulations;
(vi) to handle disputes and conduct and facilitate investigations and proceedings;
(vii) to personalise User experience and respond to individual needs;
(viii) to improve and receive feedback on the Website;
(ix) to improve customer service and provide support services;
(x) to process interest in buying or creating Sparrow Options over cryptocurrencies; and
(xi) to send periodic emails, including but not limited to the services, news, updates and related information on the Website.

2.2 The purposes listed in paragraph 2.1 are not exhaustive and Sparrow may collect and/or use personal data for additional purposes which Users will be notified of, in accordance with the applicable terms and conditions. Further, these purposes may continue to apply even in situations where the relationship between Sparrow and the Users (for example, pursuant to a contract) has been terminated or altered in any way, for a reasonable period thereafter (including, where applicable, a period to enable Sparrow to enforce its rights under any contract with the Users).

  1. DISCLOSURE

3.1 Sparrow may disclose personal data to third party service providers for the purposes including but not limited to those listed in paragraph 2.1, on the condition that the disclosed personal data is kept confidential and not further disclosed.

3.2 In particular, Sparrow may disclose personal data for legal purposes (including but not limited to compliance, enforcement of legal rights and obligations and to obtain legal advice).

3.3 Sparrow employs security measures to protect personal data, including but not limited to the following:

3.3.1 all personal data collected on the Website shall be transmitted via Secure Socket Layer (SSL) technology and then encrypted into the gateway provider's database only to be accessible by those authorized with special access rights who are required to keep the personal data confidential; and

3.3.2 all personal data shall be encrypted on the server.

3.4 Users 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, Sparrow strives to protect the security of the Users' information and is constantly reviewing and enhancing its information security measures.

  1. COOKIES

4.1 Cookies are small files that a website or service provider transfers to computer hard drives through a web browser that enables the website or service provider's systems to recognize the browser and record certain information.

4.2 Sparrow uses cookies on the Website to record Users' usage patterns and trends and customize User experience. Sparrow may engage third party service providers to assist in such purposes. However, such third party service providers may not disclose personal data obtained in the course of their engagement to any other parties.

4.3 Users may disable the processing of cookies on their web browsers but this may prevent Users from maximising the services provided by Sparrow.

  1. THIRD PARTY WEBSITES

Sparrow shall not be responsible for the collection, use, disclosure and care of personal data by any third party websites linked to the Website.

  1. WITHDRAWAL OF CONSENT

6.1 Users may contact Sparrow at [email protected] to withdraw their consent to the use of personal data by Sparrow, following which Sparrow shall cease to further collect, use and disclose personal data of that User.

6.2 Users should be aware that the withdrawal of consent may prevent them from utilising the services provided by Sparrow.

  1. ACCESS TO AND CORRECTION OF PERSONAL DATA

7.1 If Users wish to make (a) an access request for access to a copy of the personal data which Sparrow holds about the respective User or information about the ways in which Sparrow uses or discloses such personal data, or (b) a correction request to correct or update any of such personal data which Sparrow holds, the Users may submit their request via email at [email protected].

7.2 Please note that a reasonable fee may be charged for an access request. Sparrow shall inform the Users of the fees before processing the request.

  1. ACCURACY OF PERSONAL DATA

Sparrow generally relies on personal data provided by the Users (or their authorised representative). In order to ensure that the personal data is current, complete and accurate, User should update Sparrow if there are changes to personal data via email at [email protected].

  1. TRANSFER OF PERSONAL DATA OUTSIDE OF SINGAPORE

Users consent to the transfer of their personal data to countries outside of Singapore. Sparrow shall take steps to ensure that Users' personal data continues to receive a standard of protection that is at least comparable to that provided under this Privacy Policy.

  1. RETENTION OF PERSONAL DATA

10.1 Sparrow may retain Users' personal data for as long as it is necessary to fulfil the purposes stated in paragraph 2.1, or as required or permitted by Applicable Laws.

10.2 Sparrow shall cease to retain Users' personal data, or remove the means by which the data can be associated with the Users, as soon as it is reasonable to assume that such retention no longer serves the purposes stated in paragraph 2.1, and are no longer necessary for legal or business purposes.

  1. CHANGES TO PRIVACY POLICY

Upon any amendments to the Privacy Policy, Sparrow shall update the Website and notify Users accordingly.

  1. FEEDBACK

Users may contact Sparrow at [email protected] if there are any questions or feedback regarding the Privacy Policy.

  1. EFFECT OF POLICY

This Privacy Policy applies in conjunction with any other policies, notices, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of the User's personal data by Sparrow.

  1. GOVERNING LAW AND JURISDICTION

The Privacy Policy shall be governed by and in accordance with the laws of Singapore.