TAAS PRIVACY POLICY

Dear Community,

Here at TAAS  Fund Pte. LTD (“TaaS”), we are committed to protecting and respecting your privacy. We take your privacy seriously and will use your personal information (or data) to administer your account and to provide the services only after obtaining your consent to the collection and processing of your personal data on the terms specified below.

This Privacy Policy explains when, where, and why we collect personal information about people who visit TaaS website, go through the Authorization Procedure or use TaaS Service, how we use the information, the conditions under which we may disclose it to others, your rights in respect of your personal information, as well as how we keep it secure.

TaaS may change this Privacy Policy from time to time if doing so will be deemed necessary in order to comply with the applicable laws and actual circumstances of the functioning of Taas Service and website, so please periodically check this page to ensure that you’re satisfied with, and accept any such changes. Additional notifications on any material amendments will be sent to your email address. If under applicable laws your consent is required due to a change to this Privacy Policy, TaaS will first obtain your consent. This can be a case when, for example, the nature of your data processing and purposes for processing change.

Any questions regarding this Policy and our services should be sent to privacy@taas.fund

1. What is TaaS?

We believe that since you chose TaaS you are familiar with the main focus of our services and business, and you are familiar with the TaaS User Agreement. Generally, TaaS or Token-as-a-Service means a service provided by TAASFund Pte. LTD, a company registered at 8 Burn Road #15-13, Trivex, Singapore 369977, 201705584H.

2. What is personal information and what is processing of personal information?

Personal information (or data) is any information about you and that alone or in combination with other pieces of information gives the opportunity to identify you as a person. It can be your first and last name, your email and member id, your location data, or information related to your wallet. Processing of the information means any action with your personal data, for example, collection, recording, organization, structuring, storage, use, disclosure by any means and so on.

3. What type of information is collected from you?

TaaS may collect the following categories of personal data about you:

• ETH wallet address;
• any data displayed on your identification card, passport and/or other identification documents etc;
• a photograph and/or video with you, including facial identifiers;
• full name, address and postcode, date of birth, PEPs and sanctions related data;  and
• any additional information that TaaS may request you to provide in order to comply with applicable laws and regulations that may include but not limited to copy of bank statements, invoices, investment account records or a solicitors’ or accountants’ letter confirming the source of funds; details of the original transaction or transactions, including time, date and transferor/transferee wallet details.

TaaS may also collect online identifiers and cookie identifiers that give the opportunity for TaaS to obtain and analyze the technical information such as frequency of visits to TaaS website, IP address, site pages most frequently accessed, browser type etc. Online and cookies identifiers alone are non-personally identifiable user information; however, such information can be combined with the personal information received from you when you signed up for our services and that is why you need to be aware of the fact that such information is collected and processed. Please see our Cookies Policy for more details on such processing here.

In case you choose not to share certain personal data with us, we may not be able to offer or perform some or all of our services insofar as these personal data are obligatory and/or necessary by the law or for the performance of the contract.

4. Why does TaaS collect information from you? TaaS collects and uses the information to:

• understand your needs and provide services relevant to you;
• ensure that you use the services in the most effective manner;
• administer TaaS website including performing troubleshooting, data analysis, testing, research for statistical, marketing and survey purposes;
• keep TaaS website and TaaS Service safe and secure;
• boost the quality of the services you get from TaaS including via personalization of the accounts and the services;
• generate statistical studies;
• help you to complete a transaction, or provide services or customer support;
• communicate back to you;
• update you on services, information, and products, or, in other words, send you some marketing information and newsletters;
• carry out KYC checks and related actions to meet any legal, regulatory or judicial obligations imposed on us;
• Authorize users; and
• prevent money-laundering and counter-terrorism financing and comply with our Compliance Policy.

If TaaS decides to change the purposes of processing specified above, we will inform you about such changes prior to the use of your personal information for the newly set purposes. The notification on such changes will be sent to your account dashboard and/or your email, and if required, we will ask you to provide your consent for the amended purposes.

5. What are the legal grounds used by TaaS for processing your personal information?

As a data controller, we are obliged to identify the legal grounds for processing your personal information. As a result, we may rely on the following lawful grounds to process your personal information:

• the need to perform our obligations under a contract, or to perform related pre-contractual duties at your request;
• your consent;
• the legitimate interests pursued by us such as enhancing the security of our website or improving the website and the services;
• the need to comply with the legal obligations that are imposed on TaaS due to the nature of its business. Such obligations include but not limited to the maintenance of TaaS’ legal, regulatory and AML/CTF compliance;
• we may be legally obliged by a competent authority to process your data in some instances (including any investigation, litigation or any government or regulatory proceeding relating to any legislation applicable);
• any other ground, as required or permitted by law in the specific particular context.

6. Who will get access to your personal information?

In order to provide high-quality services within TaaS website and provide Services TaaS hires people, enters into the agreements with independent contractors as well as cooperates with other services providers, companies and organizations. For these reasons, some of your personal information can be passed to the persons mentioned. TaaS uses Intercom CRM software (Intercom, Inc., supported by Ambisafe Software Inc.) as well as Amazon Web Services (Amazon Web Services, Inc.), a cloud computing service to store and process information needed to provide services. For marketing analytics purposes, TaaS uses the services provided by Google Analytics (Google LLC) and The Facebook Pixel (Facebook Inc.), We also use MailChimp services (The Rocket Science Group LLC d/b/a MailChimp) for email delivery automation. Finally, we use Onfido (Onfido Inc.) for identities verifications. These well-known software providers ensure your data is processed in accordance with the strictest data protection standards.

Although TAAS Fund Pte. LTD. is registered in Singapore it has contractors and subsidiaries in other countries. As mentioned above, your data may be transferred to companies outside the EU, if engaged by TaaS for provision of the relevant services.

If you are from the EU, it will be important for you to know that the transfer of your data to the recipients in these countries is secured either by the participation of the contractors from the USA in Privacy Shield Program or on the bases of standard contractual clauses adopted by the European Commission and compliant with the EU data protection laws.

By accepting this Privacy Policy and TaaS User Agreement and by using our Service, or going through the Authorization process you agree to such transfer and processing within the purposes set in Section 4 of this Privacy Policy.

In all cases when we pass the information to other persons, we ensure that your information is being protected and used only for the purposes specified in Section 4 of this Privacy Policy. This is achieved by using only certified services and products, signing agreements on protection of personal data with contractors as well as taking technical measures to ensure the information is protected when stored, used and while being transferred.

We may disclose your Personal Data:

• to the extent required by law or if we have a good-faith belief that such disclosure is necessary in order to comply with official investigations or legal proceedings initiated by governmental and/or law enforcement officials, or private parties, including but not limited to: in response to subpoenas, search warrants, or court orders;
• if we sell or transfer all or a portion of our company’s business interests, assets, or both, or in connection with a corporate merger, consolidation, restructuring, or other company change; or
• to our subsidiaries or affiliates only if necessary for business and operational purposes.

If we must disclose your Personal Data in order to comply with official investigations or legal proceedings initiated by governmental and/or law enforcement officials, we may not be able to ensure that such recipients of your Personal Data will maintain the privacy or security of your Personal Data.

7. How long will the personal information be processed and stored by TaaS?

Your personal information will be stored by TaaS within the term of your use of the TaaS Services, and any additional time frames stipulated by the international practices for compliance and integrity.

8. Your rights regarding your personal information TaaS collects and processes

8.1. You have the right to know what personal information TaaS processes and get details of such processing

That means that you have the right to ask TaaS to provide you with the confirmation as to whether or not your personal data is being processed by TaaS, as well as obtain the full information on the terms of such processing, i.e. purposes of collecting and processing, period of processing, third parties that have access to information. You also have the right to obtain your personal data in a structured, commonly used and machine-readable format in order to be able to transmit it to the other controller of data.

8.2. You have the right to request TaaS to rectify your personal information

This means you have the right to ask that all inaccuracies in your personal information be corrected. You can also complete the personal information if you feel there is a need to do so.

8.3. You have the right to request TaaS to erase personal information

You can request TaaS to erase such data if its processing is no longer necessary in relation to the purposes for which it was collected as well as if there are no legal grounds for the processing. In most cases, TaaS will erase it unless otherwise will be required by the applicable legislation.

The personal data TaaS processes can be divided into two categories which are crucial in respect of your right to request erasure of your data. The first category comprises information that is not stored in blockchains. This information includes all the personal data specified in Section 3 of this Privacy Policy. The other category of information which is processed and can be associated with you is the data that is stored in blockchains. This refers to your wallet address and history of your wallet transactions for example. The second category of data is inextricably connected with the first category of your data. Furthermore, the second category of data is stored in blockchain permanently and there are no technical means to delete it or it is almost impossible to do so.

Hence, there are two aspects of your right to erasure:

(i) The second category of data stored in blockchains remains personal identifiable information only as long as it can be related to the first category of data processed by TaaS. Once the first category of data is erased upon your request the second category will no longer be determined as personal.

(ii) The request to erase the second category of data alone will require the erasure of the first category of data thus making the second category of data to be no longer classified as personal information as there will be no other data available in accumulation to identify a user.

Please note that the erasure of data that falls within the first category will inevitably cause your inability to use TaaS Service.

8.4. You have the right to request TaaS to restrict the processing of your personal information

You have the right to request the restriction of processing of your personal data in cases provided by the applicable law. For instance, if you want to verify whether the data processed by TaaS is accurate, the processing of your data may be restricted for the period of time TaaS will require to verify your personal data at your request.

8.5. You have the right to withdraw consent

You can withdraw your consent to the collection and processing of your personal information by TaaS at any time, without affecting the lawfulness of processing based on consent before its withdrawal. After we at TaaS receive such withdrawal request from you, we will process it in a timely manner and no longer process your personal information unless the obligation to proceed with processing is set by the applicable law. The phrase “in a timely manner” is deciphered below.

Here you have to know that there are different purposes for which your data is being processed (Please see Section 4 of this Privacy Policy). You can withdraw from one of them not affecting the other. For example, if you want to withdraw consent to the processing of your personal data for sending you marketing information, TaaS may still process your personal data if you want to retain Authorisation status in case you specify this in your request for withdrawal.

However, if you withdraw your consent to the processing of your personal data for the purposes of primary TaaS services, TaaS will also erase your data with the effects mentioned in Section 7 of this Privacy policy.

If you will face any issues regarding the processing of your personal data or have questions on the same matter, please inform TaaS and we will take all reasonable efforts to resolve the issue. If you have any such issues, please drop us a line at privacy@taas.fund. You can also address any of your complaints to the data protection controlling bodies.

9. Data Protection

TaaS has implemented and will maintain technical, organizational, and physical security measures that are reasonably designed to help protect personal information from unauthorized processing, such as unauthorized access, disclosure, alteration, or destruction.

10. Time for reply and reaction

TaaS will make all reasonable efforts to timely address your requests pertaining to the rights described above; however, you should expect our response not later than one month from the date of filing such request. Our response time may be extended by two further months if TaaS is overwhelmed with the number of requests from users. TaaS will inform you of such extension within one month of receipt of the request, together with the reasons for the delay.

11. Cookies

What are cookies? These are tiny pieces of code that remain in your computer or mobile device when you visit a website. These pieces then enable the server to provide you with the information that is customized to your needs when you use a website as a returning user.

If you visited our website and came here, to the Privacy Policy, cookies consent message was the first message that you likely saw that prompted you about the fact that cookies are used and active on our website. Please see the detailed information on how we use cookies in our Cookies Policy here. Cookies Policy is an integral part of this Privacy Policy.

12. Are you already 18 years old?

The privacy of children is one of our major concerns. At TaaS we can provide services only in case if you as the user are aged 18 or older. TaaS does not intentionally collect personal data of those under 18 years’ old. If you are under 18 years’ old please do not send us or our partners your personal data (for example, your name, address and email address,passport, ID, selfie).

13. We hope this Privacy Policy helped you understand how your personal information is dealt with at TaaS.  TaaS will undertake its best effort to make your personal data protected. Should you have any questions, please email us at privacy@taas.fund. We will be glad to receive any information or comment from you to make our services better for our users and community.

Yours faithfully,

Token-as-a-Service