Privacy Policy

Modified on Feb 28, 2023

Neobrix Pte Ltd (hereinafter referred to as "we", "our", "us" and “Singularity” and shall include any affiliates) are committed to protecting the information and data shared by all of our users (hereinafter referred to as “you”, “yourself” and “user”). In light of the same, we have created this privacy policy (“Privacy Policy”) in compliance of all applicable laws. The Privacy Policy applies and has effect in respect of all use of our proprietary technology platform “Singularity”, websites and applications (collectively “Platform”) and services provided by Singularity on its own or through integration with its clients services (“Services”). This policy does not cover data that our clients collect and manage themselves.

This Privacy Policy explains the basis on which personal information we collect from you will be processed by us or on our behalf. Where we decide the purpose or means for which personal data you supply through the Platform or Services is processed, we are the “data controller.”

Please read this Privacy Policy carefully as by accessing or using the Platform and Services, you agree to be bound by the terms described herein and all the terms incorporated by reference. Any information provided to us is subject to this Privacy Policy. If you do not agree to any or all of these terms, do not use the Platform or the Services. Should you continue to access and use the Platform or Services and provide your personal information, such act would constitute your consent to the terms contained herein.

Terms which are capitalized but not defined herein shall have the meaning assigned to them in the Terms of Service. Please also read our Terms of Service (the “Terms of Service”), which describe the terms under which you use the Platform and Services and where this Privacy Policy shall be deemed to be incorporated by reference.

1.1 A prerequisite for obtaining access to the Platform and usage of the Services is the acceptance of this Privacy Policy. This Privacy Policy shall apply to all users and App Developers. You grant your consent to be bound by the terms of this Privacy Policy by:

(i) accessing or logging into the Platform in the manner as provided for in the Terms of Service;

(ii)submitting any information to Singularity;

(iii) using the Services offered by Singularity;

1.2 As part of providing our Services to you, we may need to send routine communications to you through the Platform. By providing your information for accessing and using the Platform, you also consent to us to periodically sending promotional content on the Platform that could be of interest to you which you may opt out of by following the process mentioned in the promotional communication.

1.3 You must ensure to provide us with the correct or up-to-date personal information at the time of registration and during the use of our Services to ensure that the Services can be properly utilized by you.

1.4 If, at any time, you want to access, update, modify or eliminate any information provided by you or which forms a part of the account created with Singularity, you may do so by writing to us on [e-mail]. You may also withdraw your consent for use of your personal information and stop using the Services and Platform for which consent is required. Singularity reserves the right to stop providing any Services to which consent has been withdrawn.

2. Information that may be collected

2.1 By downloading and accessing and Platform and Services of Singularity you agree that Singularity may collect relevant information for the purposes as set forth in this Privacy Policy. This may include “Personally Identifiable Information” which allows someone to identify you individually, for example, your email address or name and “Non-Identifiable Information” which is non-identifiable data that, when taken alone, cannot be used to identify a specific individual. Personally Identifiable Information and Non-Identifiable Information shall collectively be referred to as “Information”. The information Singularity collects includes the following:

A. Information you provide us

• Contact information (such as your name and email address)

• Blockchain address, which may become associated with Personally Identifiable Information when you use our Services.

• Your Profile Picture

• Information that you provide when seeking help from our customer service (such as chat logs, emails, contact details such as your phone number and email address if necessary to resolve your request) and other information you provide to us.

• Any other information that is provided to us by you, including, without limitation, financial information for making any transactions on the Platform

B. Information we automatically collect directly from you when you use our Services

• Information about your blockchain wallet: When you use our Platform or Services to sign into an App Developers platform, we may create a new blockchain wallet address for you, depending on how you choose to use our Services. This feature is provided to allow you to use our Services and Platform from any device or browser and on any of App Developers applications by simply re-logging into them using your preferred login method. In such cases, as part of the Services you have opted for, you agree to us storing part or all of the encrypted backups of your blockchain keys, in a way that they are encrypted by the login method that you choose and can be decrypted only by your successful login as recovery feature available with the Services. This is Non-Identifiable information is stored in such an encrypted manner that it can only be accessed by successfully logging into our Services or Platform by using the login method that you have chosen. We may also provide multi-factor authentication techniques to further encrypt this information. You may request deletion of this backed up information at any time.

• Information about your device/connection: We may collect device-specific information when you use our Services. This may include your IP address, device type, browser type, operating system, device ID, timezone information, blockchain address, wallet type.

• Information from Cookies: Like many web applications, we may use Cookies to analyze how users interact with our Platform and Services, improve our product quality, and provide users with a more personalized experience.

• Location information: We collect information about your device's location, which can be either precise or imprecise depending on the type and settings of the device you use to access our Services and the permissions you grant to our Services. You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device. However, if you choose to opt out, you may not be able to use certain aspects of the Services.

• Metrics and Performance Data: We may log and collect service-related, diagnostic, and performance information. This includes high level information about your activity (such as how you use our Services and how you interact with others using our Services), and diagnostic, crash, website, and performance logs and reports.

• Details of the assets being transacted, amount of transaction on the Singularity Platform

• We may also store information about the App Developers’ applications you use our Platform and Services on, and certain activity details on these App Developers’ applications such as login status, NFT purchases and last login time.

C. Information collected from public or 3rd party sources

• 3rd Party affiliates: We may receive Personally Identifiable and/or Non-Identifiable Information about you from service providers that offer their products and/or services for use in conjunction with our Services or whose products and/or services may be linked from our Services. For example, third-party wallet providers provide us with your blockchain address and certain other information you choose to share with those wallets providers.

• Third Party access data: we may collect and process details about when you access the Platform via a third-party service provider such as Facebook, Google, Apple etc., we may collect and store personal and non-personal information which is made available by that third party service provider, such as your Facebook name, your profile picture, Google play store information, and other public data that is provided by such third service providers. We will also receive technical data in order to ensure the Platform connects to the correct third-party service provider account. You will also be able to use your account to log in on multiple devices. We recommend that you review the privacy policies of such third-party service providers to identify how your data is being processed and shared by them as well.

• Public blockchain information: We collect information from activity that is publicly visible and/or accessible from your blockchain activity. This may include blockchain addresses and information regarding purchases, sales, or transfers of NFTs, which may then be associated with other data you have provided to us.

D. Information collected by embedded third party applications

• Our Services may embed or contain links to third-party applications/websites, such as fiat to crypto onramp solutions or external wallets.

• Such entities may collect Personally Identifiable Information from you. We have no control over, and cannot be responsible for these third-party websites or their content. Please be aware that the terms of this Privacy Policy do not apply to these third-party applications or their content, or to any collection of your Information by such applications. We encourage you to read the privacy policies of every such application you use.

2.2 As our Platform and Services are provided through integration with applications of App Developers, your information may be collected by such App Developers when you are using their applications. We have no control over such collection and processing of data and you should ensure that you read the privacy policies of such App Developers to understand the nature of data collected and the manner in which the same is used. Singularity shall have no liability for collection and use of data by such App Developers on their applications.

3. Use of the data collected

3.1 The primary purpose in collecting information is to help us operate our business and provide, improve, customize, support, and market our Platform and Services. We may use your information to:

• Provide the Platform and Services to you

• Provide customer support you may request

• Troubleshoot problems

• Facilitate the creation of and secure your account and identify you as a user in our system

• Investigate and address conduct that may violate our Terms of Service, including the detection and prevention of fraud, violations of our terms or policies, or potentially prohibited or illegal activities

• Comply with applicable laws, cooperate with investigations by law enforcement or other authorities of suspected violations of law, and/or to pursue or defend against legal threats and/or claims

• Deliver targeted marketing and service update notices based on your communications preferences

• To perform such other functions as otherwise expressly set out in this Privacy Policy or as required by law.

3.2 In addition to the above, we and our third-party service providers use data collected about you to send you marketing communications about our Platform and related Services based on your interests.

3.3 Non-Identifiable Information, exclusively owned by Singularity may be used in an aggregated or non-personally identifiable form for internal research, statistical analysis and business intelligence purposes including those for the purposes of determining the number of visitors and transactional details, and Singularity may sell or otherwise transfer such research, statistical or intelligence data in an aggregated or non-personally identifiable form to third parties and affiliates

3.4 We process personal data for our legitimate interests of ensuring that any use of the Services is lawful and non-fraudulent, does not disrupt the operation of our Platform and Services, does not harass our staff or other individuals, to enforce our legal rights and to comply with our legal obligations.

3.5 Where we reasonably believe that you are or may be in violation of any applicable laws or our terms of use, we may share your Personally Identifiable Information with relevant law enforcement agencies in relation to such alleged violation.

3.6 Singularity shall not be responsible in any manner for the authenticity of the personal information supplied by the user to Singularity. If a user provides any information that is untrue, inaccurate, not current, or incomplete (or becomes untrue, inaccurate, not current, or incomplete), or Singularity has reasonable grounds to suspect that such information is untrue, inaccurate, not current, or incomplete, Singularity has the right to suspend or terminate such access to the Platform or Services at its sole discretion

3.7 We may use automated decision-making methods which do not involve human involvement to process your information only in the ways that are described in this Privacy Policy.

3.8 If you are based out of the EU, we rely on the following basis for processing your personal information:

a. Legitimate interest, which means our interest in conducting and managing our business to enable us to provide you with the best Services, and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal information for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

b. Performance of a contract, which means we process your information where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

c. To comply with a legal obligation, which means processing your Personally Identifiable Information where it is necessary for compliance with a legal obligation that we are subject to.

4. Sharing of your data

4.1 We may share your data in the manner as set out herein below

• Transaction information: If you use our Platform or Services to engage in a transaction with another user or business, that user/business will have access to your transaction information. Users/businesses with whom you interact with may store or re-share your information with others, on or off of our Services.

• Third Party Service Providers: We work with third-party providers to help us operate, provide, improve, customize, support, and market our Platform and Services. We may share your information with such third party service providers to provide technical infrastructure services, provide fiat to crypto on-ramping and off-ramping services, conduct quality assurance testing; analyze how our Platform and Services are used, prevent and detect, and respond to unauthorized activities, provide technical and customer support. Further your information may be shared with third party payment service providers as per their requirements for ensuring that payments made are processed.

• Affiliates: We may share some or all of your Personally Identifiable Information with any subsidiaries, joint ventures, or other companies under our common control (“Affiliates”), in which case we will require our Affiliates to honor this Privacy Policy and maintain your Personally Identifiable Information as per applicable laws.

• Corporate Restructuring: We may share some or all of your information in connection with or during negotiation of any merger, financing, acquisition, or dissolution transaction or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of our business or assets. In the event of an insolvency, bankruptcy, or receivership, your information may also be transferred as a business asset. If another company acquires our company, business, or assets, that company will possess the information collected by us and will assume the rights and obligations regarding your Identifiable and Non-Identifiable Information as described in this Privacy Policy.

• Law enforcement: We may share your information with law enforcement, government officials, or other third parties when we are compelled to do so by a subpoena, court order, or similar legal procedure; or we believe in good faith that the disclosure of personal information is necessary to prevent physical harm or financial loss, to report suspected illegal activity or to investigate violations of our Terms of Service.

5. Data retention, access and control

5.1 Data retention: We will retain your Information for as long as needed as part of our Services, or to comply with legal and regulatory obligations (e.g., audits, regulatory obligations), dispute resolutions and for the establishment, exercise or defence of legal claims in the countries where we do business. This is also the case for any third party with which we share your Information when they carry out services on our behalf. If you opt-out of using our Services or delete your account with us, some of your Information (e.g. transaction information) may be retained for up to ten (10) years in accordance with applicable laws. When we no longer need your information and there is no need for us to keep it to fulfil the purposes described in this Policy, we will either remove it from our systems or anonymize it so that it cannot identify you.

5.2 D‍ata access and control: If you would like to manage, limit, or delete your information, you may do so by logging into your account and going to the Settings section. You may delete your account with us at any time. Please remember that when you delete your account, it does not affect the information other users or our Clients have of you, if any, relating to their interactions with you.

5.3 Blockchain data: If you delete your account, make sure you have a copy of your blockchain address’s private key elsewhere so that you may continue to access the assets on your blockchain address. Deleting your account with us does not impact any information stored on your blockchain address.

5.4 EU residents: If you are a user in the European Economic Area or United Kingdom, you have certain rights under the respective European and UK General Data Protection Regulations (“GDPR”). These include the right to (i) request access and obtain a copy of your personal data; (ii) request rectification or erasure; (iii) object to or restrict the processing of your personal data; and (iv) request portability of your personal data. Additionally, if we have collected and processed your personal data with your consent, you have the right to withdraw your consent at any time. If you wish to exercise these rights, please contact us by emailing us at [e-mail] with your specific request.

5.5 California residents: If you are a state of California (United States of America) resident, you have certain rights under the California Consumer Privacy Act (“CCPA”). These include the right to (i) request access to, details regarding, and a copy of the personal information we have collected about you and/or shared with third parties; (ii) request deletion of the personal information that we have collected about you; and (iii) the right to opt-out of sale of your personal information. If you wish to exercise these rights, please contact us by emailing us at [e-mail] with your specific request.

5.6 All users: Regardless of where you live, you can ask us to provide you with a copy of any Identifiable Information that we keep about you. You can also ask us to update and/or correct any outdated or inaccurate Information that we keep about you. Please reach out to [e-mail], and we will use any reasonable efforts to accommodate your request.

6. Data protection

6.1 Singularity takes careful precaution to protect our user's Information from unauthorised access, improper use or disclosure or unauthorised modification. To prevent unauthorised access, we have put in place the latest industry-standard security technology and procedures to safeguard the Information we collect online including technical, operational, and physical security controls. Your personal information is encrypted and is protected with the most secure encryption software, which encrypts all information you input. We store your personally identifiable information on the computer servers placed in a secure environment. The measures taken by us include internal reviews of our data collection, storage and processing practices and standard measures, sensitive information is transmitted via Secure Socket Layer (SSL) technology, making our systems accessible only by those authorized with special access rights to such systems, and are required to keep the information confidential. Although we have taken significant steps to protect your personally identifiable information, no company, including Singularity can fully eliminate security risks associated with Information. We further disclaim any responsibility for any intercepted information sent via the internet, and you hereby release us from any and all claims arising out of or related to the use of intercepted Information in any unauthorized manner. If we learn of a security system’s breach, we shall notify you electronically by posting a notice on the Services or Platform or sending an e-mail to you where you have shared your contact details.

6.2 You are responsible for the security of your blockchain wallet, its keys and its contents, and we urge you to take steps to ensure that it is secure.

7. Your Rights

7.1 Access to your personal data: You may ask us whether or not your Personally Identifiable Information is being processed and access following information:

a. the purposes of the processing;

b. the categories of Personally Identifiable Information concerned;

c. the recipients or categories of recipient to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations;

d. where possible, the envisaged period for which the Personally Identifiable Information will be stored, or, if not possible, the criteria used to determine that period;

e. where the Personally Identifiable Information are not collected from you, any available information as to the source of Personally Identifiable Information;

f. the existence of automated decision-making;

g. if Personally Identifiable Information is transferred to a third country or to an international organisation, information regarding safeguards.

7.2 Rectification and Erasure: You may request for rectification of inaccurate Personally Identifiable Information and completion of incomplete Personally Identifiable Information. Further, you may request erasure of your Personally Identifiable Information on the following ground:

a. the Personally Identifiable Information is no longer necessary in relation to the purposes for which Personally Identifiable Information was collected or otherwise processed;

b. withdrawal of consent for processing Personally Identifiable Information for one or more specific purposes and there is no other legal ground for processing such Personally Identifiable Information;

c. objection to processing Personally Identifiable Information (as provided below) and there is no overriding legitimate ground for processing Personally Identifiable Information;

d. the Personally Identifiable Information have been unlawfully processed;

e. Erasure for compliance with legal obligations Singularity is subject to;

However, the right to erasure of Personally Identifiable Information is not absolute and we may refuse erasure of Personally Identifiable Information when processing of Personally Identifiable Information is necessary:

a. for compliance with a legal obligation to which Singularity is subject;

b. for the performance of a task carried out in the public interest or in the exercise of official authority vested in Singularity;

c. for the establishment, exercise, or defence of legal claims.

7.3 Restrict processing of Personally Identifiable Information: You may ask us to stop processing Personally Identifiable Information if:

a. the accuracy of the Personally Identifiable Information is contested by you, for a period enabling us to verify the accuracy of the Personally Identifiable Information;

b. the processing is unlawful, and you oppose the erasure of the Personally Identifiable Information and instead request the restriction of use of Personally Identifiable Information;

c. we no longer need the Personally Identifiable Information for the purposes of the processing, but Personally Identifiable Information is required by you for the establishment, exercise, or defence of legal claims;

d. you have objected to processing Personally Identifiable Information, pending the verification whether our legitimate grounds override your rights.

7.4 Data Portability: Upon your request, we shall provide your Personally Identifiable Information in a structured, commonly used, and machine-readable format and transmit such Personally Identifiable Information to another data controller where:

a. Processing of Personally Identifiable Information is based on consent (i) for one or more specific purposes; or (ii) performance of contract to which you are party or in order to take steps at your request prior to entering into a contract.

b. Processing is carried out by automated means

7.5 If you do not agree with the way, we have processed your Information you may approach our Grievance Officer for further recourse.

7.6 We shall aim to comply with or respond to any requests made under this section without undue delay, but no later than 30 days from the date of receipt of such request. All requests may be sent to [e-mail]. Singularity reserves the right to take additional steps to verify the identity of the person making the request to ensure safety and security of your Information.

8. Minors

8.1 Our Terms of Service require all users to be at least 18 years old. If you are at least 13 years old but under 18 years old, you may only use our Service and Platform through a parent or guardian's Account and with their approval and oversight. That account holder is responsible for your actions using the Account. It is prohibited to use our Service or the Platform if you are under 13 years old.

9. Amendment of Privacy Policy

9.1 Singularity may update or amend this Privacy Policy at any time, with or without advance notice. In the event there are significant changes in the way Singularity treats the user's Personally Identifiable Information, Singularity may display a notice on the Platform or send user’s an email.

9.2 Notwithstanding the above, Singularity shall not be required to notify the users of any changes made to the privacy policy. Should you have any concern or reject the changes in the Privacy Policy you can refuse to accept the amendments and opt for withdrawing your personal information by writing to the Grievance Officer.

10. Grievance Officer

10.1 If you have any compliant or grievances or concerns with respect to Platform or the Services or this Privacy Policy, please inform such matters to the designated Grievance Officer as mentioned below in writing or through electronic mail:

Name: Aditya Gupta

Contact Details: [e-mail]

Designation: CEO

11. International Data Transfers

11.1 It is possible that your personal information may be transferred outside of your countries jurisdiction by Singularity or third-party service providers. You hereby agree and accept that such data transfer is required for the provision of the Services by Singularity. Where these service providers are located within the European Union, we ensure that they are contractually obligated to comply with the European Union data protection rules. We also ensure in our contracts with these organisations that they only process your personal information in accordance with our instructions and in order to provide the agreed services and protect the integrity and confidentiality of your personal data entrusted to them.

11.2 In case of international data transfers, we have agreements in place with those parties which include standard data protection clauses adopted by data protection regulators and approved by the regulatory authorities to ensure that appropriate safeguards are in place to protect your personal data. Please note that laws vary from jurisdiction to jurisdiction, so the privacy laws applicable to the places where your personal is transferred to or stored, used, or processed in may be different from the privacy laws applicable to the place where you are residing.

11.3 Please feel free to contact our Grievance Office for additional information on third country data transfers as well as our safeguards and supplementary security measures.