Last Update: Jan 07, 2021
We are AirCarbon Pte. Ltd. (referred to as the “Exchange”, “AirCarbon” “we”, “us” or “our”) and we are committed to protecting our stakeholders’ and customers’ personal data in accordance with the Personal Data Protection Act 2012 of Singapore (“PDPA”) and other applicable data protection laws.
“Personal data” means any data about an individual who can be identified (a) from that data, or (b) from that data and other information to which we have or are likely to have access to, as more specifically defined under the PDPA and other applicable data protection laws.
Information that we collect from you
We collect, use, store and transfer different kinds of personal data about or relating to you, including but not limited to the following:
Identity and contact data, which includes your name, passport or other identification number, telephone number, mailing address, email address, images of your passport or identification document, utility bill or driving license;
Financial data, which includes information about your financial position, status and history, and payment account details (such as bank, credit, payment or other payment details);
Transaction data, which includes details about payments to and from your accounts with us;
Technical data, which includes details about the devices and technology you use including internet protocol address, your login data, and other technology on the devices you use to access our website, products and/or services;
Usage data, which includes information about how you use our website, products and/or services, including cookies, IP address, and account details; and/or
Blockchain data, which includes blockchain addresses and public keys.
How we collect information from you
We collect personal data from or relating to you in various ways, including but not limited to the following:
when you access and/or use our website, products and/or services (or part thereof);
when you submit forms relating to our website and/or any of our products or services;
when you register for or use any of our services on websites owned or operated by us or when you register as a member of websites owned and/or operated by us, or use services on such websites;
when you interact with our personnel such as customer service officers, marketing representatives and agents;
when you request that we contact you;
when you ask to be included in an email or other mailing list;
when you respond to our promotions and other initiatives;
when you enter into agreements with us;
when we receive references from business partners and third parties, for example, where you have been referred by them;
when you submit personal data to us for any other reason; and/or
if you are an AirCarbon Exchange user, AirCarbon or our analytics partner(s), collect and process information on your use of the website. The information collected and processed includes pages visited, links clicked, non-sensitive text entered, and mouse movements, as well as information more commonly collected such as the referring URL, browser, operating system, and Internet Protocol (“IP”) address. We use publicly available sources to approximate your geographic region and Internet Service Provider based on your IP address. We use the term “Usage Data” to refer to this information about your use of the website that we collect. We collect information that may be personally identifiable, such as IP addresses. Also, you may choose to interact with the website or Exchange in a way that results in your providing Personal Information to AirCarbon, such as giving us your name, email address, and username when signing up for a free trial of the Exchange.
Purposes for the Collection, Use and Disclosure of Personal Data
Generally, the Exchange collects, uses and/or discloses personal data and Usage Data, and you consent to such collection, use and/or disclosure by the Exchange, for the following purposes:
to provide products and services to you;
to communicate with you on matters relevant to your relationship with or interest in us;
to assess and improve the products and services that you use or may use;
to selectively send you information about our products, services, activities and/or events that may be relevant to you;
to fulfil the contractual/legal obligations under the contracts or other legal arrangements entered between us and you, or entered into between the Exchange’s related corporations, affiliates, partners and/or representatives and you;
to protect and enforce our contractual and legal rights and obligations;
to verify your identity;
to prevent, detect and investigate crime, including fraud and money-laundering, and analyze and manage other commercial risks;
to conduct audits, reviews, and analysis of our internal processes for action planning and managing commercial risks;
to prevent, detect and investigate crime and manage the safety and security of our premises and services (including but not limited to carrying out CCTV surveillance and conducting security clearances);
to comply with any applicable rules, laws and regulations, codes of practice or guidelines or to assist in law enforcement and investigations by relevant law enforcement agencies, regulatory authorities and other governmental agencies, anywhere in the world; and/or
any other purpose relating to any of the above.
We may share personal data with our related corporations, services providers, agents and other third parties, with your consent for the purposes set out above and any other reasonable ancillary purposes, for legal reasons, or where permitted under the PDPA and other applicable laws, such as in response to law enforcement agencies.
Cross Border Transfers of Personal Data
If we transfer personal data to countries outside Singapore, it will be done in accordance with the relevant provisions under Singapore laws and regulations. We will also comply with the relevant laws and regulations in relation to transfers of personal data outside countries where the personal data is collected.
For our users in the EU, if we transfer your personal data to countries outside the EU, it will be done in accordance with the GDPR and under relevant data processing agreements.
Third Party Data
Other Web Sites
It is in our legitimate interests to process personal data to selectively contact you and/or send you information about our products, services, activities and/or events that may be relevant to you (“Marketing Communications”).
To the extent that our processing of your personal data for Marketing Communications is subject to the European General Data Protection Regulation, you have the right to object to such processing by us. Please email email@example.com if you wish to exercise this right.
You may opt-out of receiving Marketing Communications by using the unsubscribe link contained in the email communications or by contacting us at firstname.lastname@example.org.
We use different types of cookies on our website to make your interaction with our website easy and meaningful – strictly necessary cookies, performance cookies, functionality cookies, and analytics cookies. The website may include first-party cookies (i.e., cookies that send data directly to AirCarbon and contractors acting on our behalf, including cookies used to monitor, analyze, and administer the website) and third-party cookies (i.e., cookies that send data to our contractors for their commercial use).
Examples of Cookies we use:
Strictly Necessary Cookies: Some cookies are essential to the operation of our services on the website. Without these cookies, we may not be able to provide certain services or features, and the website may not perform as smoothly for you as we would like. Because strictly necessary cookies are essential to operate our services on the website, if you choose to use a product on our website, there is no option to opt out of these cookies.
Performance Cookies: We and our service providers may use analytics cookies, which are sometimes called performance cookies, to collect information about your use of the website and enable us to improve the way it works. Analytics cookies collect information about how you use the website, for instance, which pages you go to most. The information allows us to see the overall patterns of usage, help us record any difficulties users may have while using the website. Note that blocking these cookies may impact the functionality you receive when using our website.
Functionality Cookies: In some circumstances, we may use functionality cookies which allow us to provide enhanced and more personalized content and features, such as customizing a certain webpage or application page. In order to permit your connection to the website, our servers receive and record information about your computer and browser, potentially including your IP address, browser type, and other software or hardware information. All of these features help us to improve your visit and assist in navigation of the website features.
Third Party Cookies: In some circumstances, we may work with third parties to provide services on our websites. For example, we use analytics services supported by third party companies who generate analytics cookies on our behalf. We may not have access to these cookies, although we may use statistical information arising from the cookies provided by these third parties to customize content and for the other purposes described above. These companies may also transfer this information to other parties where required to do so by law, or where such other parties process the information on their behalf.
We may not control these third-party cookies and their use may be governed by the privacy policies of the third parties employing these cookies.
Retention of personal data
We retain personal data about or relating to you for as long as is necessary for the purposes for which such personal data was collected (including the purposes stated in section entitled “Purposes for the Collection, Use and Disclosure of Personal Data” above), and take reasonable measures to destroy any personal data that is no longer necessary to meet those purposes.
All personal data is kept confidential and we take all reasonable measures to protect it from unauthorized or accidental access, processing or loss, by implementing appropriate physical, electronic and supervisory controls.
How you can control your information
If you do not want us to contact you via electronic messaging, you may select the “unsubscribe” option in all our electronic communications with you. We also comply with the Singapore Spam Control Act.
If you want to be removed from our customer database, you may email us at email@example.com.
If you believe we have inaccurate information about you and you want to correct such data, you may email us at firstname.lastname@example.org.
If you wish to know what personal data we have on you in connection with your relationship with us and how your personal data has been used, you may email us at email@example.com.
It is important to note that we use personal data to provide you with the products and services you wish to use. We also comply with various regulatory requirements in doing so, including the requirements for customer due diligence. Withdrawal of consent for the Exchange to collect, use or disclose personal data means that we may need to stop these activities. The absence of certain key personal data, including but not limited to your name, address, email and/or telephone contacts, personal identification numbers or banking information, may cause us to be unable to continue providing the relevant products and services to you.
Your rights regarding your personal data
To the extent that our processing of your personal data is subject to the European General Data Protection Regulation, you may have the following rights:
access to your personal data;
rectification of your personal data;
erasure of your personal data;
restrict processing of your personal data;
object to processing (including object to receiving marketing) of your personal data;
data portability; and
lodge a complaint with a EU supervisory authority.
If you wish to exercise these rights, or have any questions about these rights, you may contact Mr. Thomas McMahon, our Data Protection Officer, via email at firstname.lastname@example.org or write to us at:
AirCarbon Pte Ltd
176 Orchard Road
#05-05, The Centrepoint
Please provide sufficient information for us to verify your identity to ensure that Personal Data is not disclosed to any person who has no right to receive it; specify the right which you wish to exercise and identify the relevant Personal Data for this purpose. We will address legitimate requests as soon as reasonably possible. If your request is particularly complex, we will inform you within 30 days of the progress being made in completing your request.