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PRIVACY POLICY

Last Updated on July 14, 2022


Rario is owned and operated by Digital Collectibles Pte. Ltd. ("Rario” “we” “us” “our” which shall include its affiliates, employees, directors, group companies, parent and subsidiary). 


This privacy policy (“Privacy Policy”) applies to the site https://www.rario.com (“Site”) and as well as to any other media forms, media channels, mobile websites or mobile applications related to the Site (“Services”). This Privacy Policy shall always be read with the terms of use, which are available at https://www.rario.com/terms-of-use, (“Terms of Use”) and governs collection, processing and usage of personal data ("Personal Data”) of the user (“you” or “your”) in compliance with applicable data protection laws (including all guidelines, regulations, notices, circulars of relevant governmental authorities) of Singapore including but not limited to the Personal Data Protection Act 2012 (No. 26 of 2012) (“PDPA”), all such laws collectively being the “Data Protection Laws”. "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 an organisation has or is likely to have access.


Please read the entirety of this Privacy Policy carefully before using the Services. By using or accessing any of the Services through any channel or method, and/or by accepting the Terms of Use, you agree and consent to the use, collection, disclosure and other processing of your Personal Data by us under this Privacy Policy. IF YOU DO NOT CONSENT TO THE PROCESSING OF YOUR PERSONAL DATA AS DESCRIBED IN THIS PRIVACY POLICY, PLEASE DO NOT USE OUR SERVICES OR ACCESS OUR SITE.


This Privacy Policy applies in conjunction with any other notices, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your Personal Data by us. Capitalised terms used in this Privacy Policy and not otherwise defined shall have the meaning ascribed to such term under the Terms of Use.

The Services may contain links to or information about third party websites that are not within our control. We are not responsible for the privacy practices of any external website or mobile application.


THIRD PARTY SERVICE PROVIDERS

We may engage third-party service providers to assist with the provision of the Services. Accordingly, your Personal Data may also be collected, used and processed by our third party service providers. This Privacy Policy therefore applies to your Personal Data collected directly by these service providers in connection with Services. However, this Privacy Policy does not apply to Personal Data collected by third party vendors for their own purposes that is not shared with us. For example, if you submit Personal Data to create an account to access a website operated by the service provider, your Personal Data will be subject to the privacy policy of that particular service provider and not this Privacy Policy.


This Privacy Policy sets out the principles, Rario as a data controller under PDPA follows when collecting, using, disclosing, retaining and removing personal data, and describes other important topics relating to an individual’s privacy.


INFORMATION COLLECTED FROM ALL VISITORS TO OUR SITE

We will obtain Personal Data about you when you visit us. When you visit us, we may monitor the use of the Site through the use of cookies and similar tracking devices. For example, we may monitor the number of times you visit the Site or which pages you go to. This information helps us to build a profile of our users. Some of this data will be aggregated or statistical, which means that we will not be able to identify you individually. This Privacy Policy applies to all visitors to our Site.


ADDITIONAL PERSONAL DATA THAT MAY BE COLLECTED

Rario may collect and receive information from you when you register for an account with us, when you use the features and functions of our Services, when you connect your account to an external third party service/application or when you contact us. The following information may be collected and processed:

  • name;

  • gender; 

  • date of birth;

  • address;

  • e-mail address;

  • phone number; 

  • transaction information (e.g. credit or debit card details, bank account information);

  • username, password, and other identifiers or credentials used to access the  Services; and

  • any other information required by us as determined in our sole discretion and any information provided by you when you contact us or otherwise share with us before, during or after the termination of your account with us.


Please note that in using the Services we may also automatically collect the following information about your computer hardware and software when you use our Site. The information can include: 

  • your IP address;

  • your locations;

  • browser type;

  • domain names; 

  • referring/exit pages;

  • the files viewed on the Site (e.g., HTML pages, graphics, etc.);

  • operating system;

  • date/time stamp;

  • clickstream data;

  • access times;

  • device information (hardware model and serial number);

  • referring website addresses; and

  • any communications between you and another user of our Services.


This information is used by Rario for the operation of the Services, to maintain quality of the Services, and to provide general statistics regarding use of the Site.


USE OF COOKIES

Please note that we use “cookies” to help you personalize your online experience. A cookie is a text file that is placed on your hard drive by a web page server. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you, and can only be read by a web server in the domain that issued the cookie to you.


Cookies on the Site may be used to ensure a smooth user experience, perform analytics, and for showing relevant advertisements. Please note that third parties (such as analytics software) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies. 


Most web browsers automatically accept cookies, but you can usually modify your browser setting to disable, block or deactivate cookies if you prefer. If you choose to decline cookies, you may not be able to access all or parts of our Site or to fully experience the interactive features of the Services or websites you visit.


THIRD PARTY INFORMATION

In the event that you provide information relating to a third party to us, you represent and warrant that you have validly obtained the consent, license and permission of such third party to share and transfer his/her Personal Data to us, and for us to collect, store, use and disclose that data in accordance with this Privacy Policy.


USE OF PERSONAL DATA

Rario only collects, uses and discloses Personal Data with an individual’s consent or deemed consent or as otherwise permitted under the Data Protection Laws or other applicable laws and regulations. Personal Data will, generally, only be collected and used for the following primary purposes:

  • to operate the Site and deliver the Services;

  • to process, and where necessary, respond to your application, enquiry or request;

  • to gather customer feedback;

  • to inform or update you of other services available from Rario, where you have consented to be contacted for such purposes;

  • to monitor, improve and administer the Site and Services, and to provide general statistics regarding users of the Site;

  • to update you on changes to the Site and/or Services;

  • enabling transactions and sending transaction related communications;

  • identification and verification purposes in connection with any of the Services;

  • to facilitate, confirm and/or provide updates or notifications in relation to any transactions;

  • to verify and process transactions (including payment, collecting and managing the proceeds of the Services) and to arrange for delivery of items;

  • to contact you in cases of emergency;

  • to outsource some operations including the provision of the Services and the collection of service fees;

  • to notify you on updates or changes to this Privacy Policy or the Terms of Use, or any aspect of the Services (including to inform you of any additional terms and conditions applicable to the Services);

  • to protect and ensure the technical functionality, security and integrity of the Services including conducting data analysis, testing, monitoring and analyzing usage and activities and performing network or service enhancement;

  • for accounting, risk management and record keeping purposes;

  • to comply with applicable legal obligations and other rules, regulations, codes of practice and orders and directions of the relevant governmental authorities;

  • to prevent, detect, investigate or monitor any frauds, threats, misconduct or other prohibited content, businesses or activities;

  • to process or resolve any disputes arising from or in connection with the Services;

  • to protect our rights and property and the rights, property and safety of others;

  • transmitting to any unaffiliated third parties including our third party service providers and agents, and relevant governmental and/or regulatory authorities, whether in Singapore or abroad, for the aforementioned purposes; and

any other incidental business purposes related to or in connection with the above. (collectively, the “Purposes”)


The Purposes listed may continue to apply even in situations where your relationship with us has been terminated or altered in any way, for a reasonable period thereafter (including, where applicable, a period to enable us to enforce our rights under any contract with you).


We may use and disclose automatically collected information (including aggregated information), which is not Personal Data, for any purpose, except where we are restricted by applicable law. If we combine any automatically collected information with Personal Data or other information which may be used to identify an individual, the combined information will be treated by us as Personal Data in accordance with this Privacy Policy.


DISCLOSURE OF PERSONAL DATA

Rario will disclose or share your Personal Data, without notice, for the primary Purposes for which it was collected (including use of or access to the Site/Services);

  • for purposes that a reasonable person will consider appropriate in the circumstances; or

  • where the individual has consented; or

  • where permitted under the Data Protection Laws; or 

  • only if required to do so by law or in the good faith belief that any such action is necessary to: 

  • comply with any legal requirements or comply with legal process served on Rario or the Site; 

  • protect and defend the rights or property of Rario; or

  • act under exigent circumstances to protect the personal safety of users of the Site, or the general public visiting the Site.


We may disclose your Personal Data with the following categories of third parties: 

  • Our business partners, service providers, professional advisers, vendors and agents who assist us in performing certain aspects of the Services (including processing transactions, carrying out compliance check, data storage, management and analysis, maintenance of the Services, legal, audit, insurance and marketing services). These parties will only have access to your Personal Data to the extent necessary to perform their functions.

  • Our potential investors, purchasers and commercial counterparties. We may share your Personal Data with any person who wishes to invest in Rario or whom we intend to enter into a business combination with (such as a purchase, sale, lease, merger or amalgamation, or any other acquisition, disposal or financing).

  • Any third party claimants or potential third party claimants.

  • Financial institutions, your card issuing bank or payment service provider in respect of any issues arising from or in connection with a transaction through the Services.

  • Governmental and regulatory authorities: We may share your Personal Data with relevant governmental and regulatory agencies in Singapore or other countries, including investigating officers and judicial authorities in the relevant jurisdictions.


We may also share your Personal Data with other third parties if you have separately consented to such disclosure. In such case, any information which we share with such third parties shall be used for the purposes described when we obtained your consent.


We may disclose your Personal Data if required to do so by law or if we believe that such action is necessary to prevent fraud or crime or to protect the Services or the rights, property or personal safety of any person. We may be prevented from obtaining your consent for, or informing you of, such disclosure. Any information which we share in this circumstance shall be used for the purposes required or permitted under the applicable laws or regulations.


STORAGE OF PERSONAL DATA

Personal Data collected by Rario may be stored and/or processed in Singapore or in any other country where Rario or its service providers maintain facilities. Rario will also be entitled to use service providers such as Amazon Web Services, Freshdesk (for customer risk management), Clevertap (for customer journey management), Onfido (for KYC) and such other service providers as we may add by updating this Privacy Policy for processing and/or storing your Personal Data. The storage location(s) are chosen in order to operate efficiently, to improve performance, and to create probability of errors in order to protect the Personal Data in the event of an outage or other problems. We take steps to ensure that the Personal Data we collect is processed according to the provisions of this Privacy Policy and the requirements of applicable law wherever the Personal Data is located.


TRANSFER OF PERSONAL DATA

Your Personal Data may be transferred to other countries for processing, and by using any part of the Services, you consent to the transfer, use and processing of your Personal Data to countries outside of Singapore which may have different Personal Data protection rules than in Singapore. However, the level of protection that will be applied to the transferred Personal Data will be at least comparable to the protection provided under this Privacy Policy and the PDPA and its regulations.


RETENTION OF PERSONAL DATA

We may retain your Personal Data for as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws. We will cease to retain your Personal Data, or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purpose for which the Personal Data was collected, and is no longer necessary for legal or business purposes.


NON-DISCLOSURE

Rario does not sell, rent, lease, or release your Personal Data to third parties unless your consent has been given or if so permitted or required under the Data Protection Laws or other applicable laws and regulations. Rario may, from time to time, contact you on behalf of external business partners about a particular offering that may be of interest to you. In those cases, your unique Personal Data is not transferred to the third party without your explicit consent. In addition, Rario may share data with trusted partners to help us perform statistical analysis, send you email or provide customer support. All such third parties are prohibited from using your Personal Data except to provide these identified services to Rario, and they are required to maintain the confidentiality of your Personal Data.


There may be other situations where we may collect and use Personal Data, which are outside a person’s reasonable expectation. When this occurs, Rario is committed to providing the individual with an explanation for the possible use of the Personal Data when asking for the individual’s consent.


ACCESS TO, CORRECTION OF, AND DELETION OF PERSONAL DATA

Subject to the exceptions referred to in section 21(2) of PDPA, if you wish to make an access request for access to a copy of the Personal Data which we hold about you or information about the ways in which we use or disclose your Personal Data, or a correction request to correct or update any of your Personal Data which we hold about you, you may submit your request via email to our Data Protection Officer at dpo@rario.com.


Please note that a reasonable fee may be charged for an access request. If so, we will inform you of the fee before processing your request.


We want to ensure that your Personal Data is accurate and up to date. If any of the information that you have provided to Rario changes, for example if you change your email address, name or contact number, please let us know the correct details by sending an email to dpo@rario.com. You may ask us, or we may ask you, to correct information you or we think is inaccurate, and you may also ask us to remove information which is inaccurate.


We will respond to your request as soon as reasonably possible. In general, our response will be within thirty (30) business days. If we are not able to respond to your request within thirty (30) business days after receiving your request, we will inform you in writing within thirty (30) business days of the time by which we will be able to respond to your request. If we are unable to provide you with any personal data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the PDPA).


You have the right to ask us not to collect, use, process, or disclose your Personal Data in any of the manner described herein. We will usually inform you (before collecting your Personal Data) if we intend to use your Personal Data for such purposes or if we intend to disclose your Personal Data to any third party for such purposes. You can give us notice of your intention to halt the collection, use, processing, or disclosure of your Personal Data at any time by contacting us at dpo@rario.com.  


You may request Rario to delete your Personal Data by contacting us at dpo@rario.com and including "Please delete my Personal Data" in the subject line. Rario will verify your ability to access that email, then delete the Personal Data associated with your email address. We will use reasonable efforts to respond to your request within thirty (30) days of our receipt of the request.


We do not intentionally gather Personal Data from visitors who are under the age of thirteen (13). If a child aged under thirteen (13) submits Personal Data to Rario and we learn that the Personal Data is the information of a child under the age of thirteen (13), we will attempt to delete the Personal Data as soon as possible. If you believe that we might have any Personal Data from a child aged under thirteen (13) years, please contact us at dpo@rario.com.


WITHDRAWAL OF CONSENT 

You may withdraw your consent for the collection, use or disclosure of Personal Data by giving Rario reasonable notice by sending a written request (a) by email to the Data Protection Officer at dpo@rario.com. Rario shall inform the individual of the likely consequences of the withdrawal of the consent. 


Upon receipt of the written request to withdraw the consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us. In general, we shall seek to process your request within ten (10) business days of receiving it.


We will cease to collect, use or disclose the Personal Data upon such withdrawal unless otherwise permitted or required by the PDPA or Data Protection Laws or other applicable laws and regulations.


Please note that withdrawing consent does not affect our right to continue to collect, use and disclose Personal Data where such collection, use and disclose without consent is permitted or required under applicable laws (including Data Protection Laws).


SECURITY OF YOUR PERSONAL DATA

We strive to maintain the safety of your Personal Data.  Once we have received your information, we will use strict procedures and security features as per industry standards and the Data Protection Laws to try to prevent unauthorised access.


While we strive to protect your Personal Data, we cannot completely guarantee the security of any Personal Data we may have collected from or about you, or that no harmful code will enter the Site (for example viruses, bugs, trojan horses, spyware or adware). You should be aware of the risks associated with disclosing any information or transacting over the internet or when using online portals, and we urge you to take every precaution when using the internet to disclose your Personal Data to us, including using strong passwords, changing your password regularly and using a secure browser.


If applicable, you undertake to keep your username and password secure and confidential and shall not disclose or permit it to be disclosed to any unauthorised person, and to inform us as soon as reasonably practicable if you know or suspect that someone else knows your username and password or believe the confidentiality of your username and password has been lost, stolen or compromised in any way or that actual or possible unauthorised transactions have taken place. We are not liable for any loss or damage resulting from your act or omission to safe-keep your username and password from unauthorised use.


Please also refer to the Terms of Use in this regard.


CHANGES TO THIS POLICY 

We reserve the right to update, modify, delete or otherwise make changes to this Privacy Policy at any time. Any changes to this Privacy Policy will be posted to the Site. A notification may also be sent to your email address.


Any changes to this Privacy Policy will take effect and be binding on you from the time of posting the changes to the Site. If you continue to use any Services following any changes to this Privacy Policy, you will be deemed to have accepted the changes and the updated version of this Privacy Policy.


If you do not agree with the changes, you are not allowed to use any part of the Services. Please ensure that you refer to this Privacy Policy on a regular basis to check for any changes. It is your responsibility to regularly review this Privacy Policy (and the applicable conditions).


If any provision of this Privacy Policy shall be held to be invalid, illegal or unenforceable for any reason whatsoever, the validity, illegality and enforceability of the remaining provision of this Privacy Policy shall not in any way be affected or impaired thereby.


DATA PROTECTION OFFICER

You may contact our Data Protection Officer if you have any enquiries or feedback on our personal data protection policies and procedures, or if you wish to make any request, in the following manner:


DPO: Mr. Sameer Deval


Email Address: dpo@rario.com


CONTACT INFORMATION

Rario welcomes your comments regarding this Privacy Policy. If you believe that the Site has not adhered to this Privacy Policy, please contact us at dpo@rario.com


GOVERNING LAW

This Privacy Policy and your use of this website shall be governed in all respects by the laws of Singapore.



OUR ADDRESS
DIGITAL COLLECTIBLES PTE. LTD.
68 CIRCULAR ROAD, #02-01
SINGAPORE 049422

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