Privacy Policy

This Privacy Policy (the “Policy”) details how Internet Identity Foundation and any of our subcontractors operating https://www.sns.id (including any subdomains, the “Website”) website (“we”, “our” or “us”) and applications which refer to this Policy, may collect, use, disclose or otherwise process your Personal Data (as hereinafter defined).

We may revise this Policy from time to time without any prior notice. You may determine if any such revision has taken place by referring to the date on which this Policy was last updated. Your continued use of our Services constitutes your acknowledgement and acceptance of such changes. We encourage you to review this Privacy Policy regularly to stay informed about our information practices and the choices available to you.

General
1. This Policy applies to Personal Data in our possession or under our control, including Personal Data in the possession of organisations or persons that we have engaged to collect, use, disclose or process personal data for our purposes. By continuing to browse our Website and use the services and products on our Website (collectively, the “Services”), you consent to our collection, use and disclosure of your Personal Data in accordance with the terms listed in this Policy.
2. In this Policy, “Personal Data” means data, whether true or not, about you 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.
3. This 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.
4. If you have any comments on, or questions about this Policy, please email them to our data protection officer at privacy@sns.id.
Personal Data We Collect & How We Collect Such Personal Data
1. Different kinds of Personal Data which we may collect from you, depending on the nature of your interaction with us, include:
  1. Wallet and Transaction Data. E.g. details of transactions that you carry out through our Website, information about your digital wallet that you may need to provide us or our third-party payment processors in order to engage in transactions on the Website. We will never ask you for or collect your private keys.
  2. Contact Data. E.g. email addresses, telephone numbers, first and last name, user name and other information you voluntarily provide to us in order to be contacted on our forum, communication channels or when you update your user account data;
  3. Technical Data. E.g. internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our Website;
  4. Usage Data. E.g. details of your visits to our Website and the resources you use there, information that you put into forms, chatbots or fields on our website, chatrooms or communication channels at any time;
  5. Profile Data. E.g. your username and password, email address, first and last name, blockchain address and preferences (such as how your content is displayed and favourites) and any other information that you provide whether on our Website, through the chatrooms, communication channels or otherwise;
  6. Marketing and Communications Data. E.g. your preferences in receiving marketing from us and third parties, your communication preferences and subscriptions for newsletters; and
  7. Public Blockchain Data. E.g. data from activity that is publicly visible and/or accessible on blockchains. This may include blockchain addresses and information regarding transactions, purchases, sales, orders or transfers of digital assets, which may then be associated with your blockchain address or other data you have provided to us.
2. Where you do not provide us with Personal Data when requested, we may not be able to perform or conclude the contract we have or are trying to enter into with you or provide you with functions on our Website or any service that requires such Personal Data.
3. We use different methods to collect data from and about you including through:
  1. Direct interactions. You may give us your Contact, Profile and Public Blockchains Data by filling in forms, corresponding with us by email, our official chatrooms, communication channels or other interaction methods. This includes Personal Data you provide when you: (A) join our chatrooms or external communication channels (such as our Discord server); (B) subscribe to our mailing list (if any); (C) use our Website, application, chatrooms, communication channels or our Services (whether through this Website or otherwise); (D) request marketing to be sent to you; (E) connect your digital wallet with our Website; and (F) give us feedback or contact us.
  2. Automated technologies or interactions. As you interact with our Website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this Personal Data by using cookies, pixel tags, server logs and other similar technologies. Pixel tags (also referred to as clear Gifs, Web beacons, or Web bugs), allow us to analyse how users find our Services, make the Services more useful to you, and tailor your experience with us to meet your particular interests and needs.
  3. Third parties or publicly available sources. We will receive Personal Data about you from various third parties and public sources that offer their products and/or Services for use in conjunction with our Service or whose products and/or Services may be linked from our Service. For example, third-party wallet providers provide us with your blockchain address and certain other information you choose to share with those wallet providers. We may add this to the data we have already collected from or about you through our Service.
Cookies and Third Party Websites
1. Like many online services, we may use cookies to collect information. Cookies are small text files placed in visitors’ computer browsers to store their preferences and record certain information. They may have unique identifiers, and reside, among other places, on your computer or mobile device, in emails and on our web pages. Most browsers allow you to block and delete cookies. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer until you delete them) to analyse how you interact with our Website and use our Services, make improvements to our service quality, and provide users with a more personalised experience. Through the use of cookies, we provide users of the websites with more user-friendly services that would not be possible without the cookie setting.
2. We may engage third party service providers to assist in recording your usage patterns, trends and customise your experience, or use cookies on our websites to collect the same type of Personal Data for the same purposes we do for ourselves. We do not have access to or control over the cookies these third parties use but they may not disclose personal data obtained in the course of their engagement to any other parties. Additionally, we may share non-personally identifiable personal data with third parties.
3. For the avoidance of doubt, we shall not be responsible for the collection, use, disclosure and care of Personal Data by any third party websites (including third party operated communication channels such as Discord) linked to our websites.
4. We may use the following cookies:
  1. Strictly necessary cookies. These are cookies that are required for the operation of our websites. They include, for example, cookies that enable you to log into secure areas of our websites.
  2. Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our websites when they are using it. This may help us to improve the way our websites work, for example, by ensuring that users are finding what they are looking for easily.
  3. Functionality cookies. These cookies are used to recognise you when you return to our websites. They may enable us to personalise our content for you, greet you by name, or remember your preferences (for example, your choice of language or region).
  4. Targeting cookies. These cookies record your visit to our websites, the pages you have visited and the links you have followed.
5. You may, at any time, prevent the setting of cookies through our websites by means of a corresponding setting of the Internet browser used, and may thus permanently deny the setting of cookies. Furthermore, previously set cookies may be deleted at any time via an Internet browser or other software programs. This is possible in all popular Internet browsers. If the data subject deactivates the setting of cookies in the Internet browser used, it may not be possible to use all the functions of our websites.
6. By continuing to browse or use our websites, you are agreeing to our use of cookies as well as our cookie policy set out in this Section 3.
The Purposes of Collection, Use, and Disclosure of Your Personal Data
1. We use your Personal Data for a variety of business purposes, including to provide our Services, for administrative purposes, and to market our Services. We will only collect, use, and disclose your Personal Data to:
  1. present Website content effectively, including to provide our Services to you;
  2. identify and display the .sol domain name representing your Solana blockchain address which may act as your username and profile;
  3. provide customer support and respond to your requests and inquiries;
  4. send you administrative notifications, such as security, support, and maintenance advisories;
  5. perform obligations in the course of or in connection with our terms of service with you or to take steps at your request prior to entering into a contract with us;
  6. comply with a legal obligation to which we are subject;
  7. allow you access to the Services;
  8. send you our publications and marketing materials in accordance with the subscription details and preferences that you have submitted to us;
  9. perform analytics and research concerning the Services and to improve such Services or develop new services;
  10. protect and improve the security of the Services, and detect and prevent misuse of such Services;
  11. prevent, detect and deal with fraud; and
  12. convey to third party service providers, subcontractors, agents and other organisations we have engaged (e.g. search engine facilities) to perform any of the functions with reference to the above mentioned purposes.
2. Under certain circumstances we may also use Personal Data to:
  1. establish, exercise or defend legal claims;
  2. investigate, prevent, or take action regarding illegal activities, suspected fraud, violations of our Terms of Use, or situations involving threats to our property, the property or physical safety of any person or third party;
  3. facilitate the financing, securitisation, insuring, sale, assignment, bankruptcy, or other disposal of all or part of our business or assets;
  4. respond to valid and enforceable subpoenas, court orders, and other legal process, or as otherwise required by law; and
  5. comply with legal and/or regulatory requirements.
3. We may use your Personal Data without your knowledge or consent where this is required or permitted by law.
4. The purposes listed in the above Sections may continue to apply even in situations where your relationship with us (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 us to enforce our rights under a contract with you).
Reliance on the Legitimate Interests Exception
1. We may collect, use or disclose your Personal Data without your consent for our legitimate interests or the legitimate interests of another person. We will assess the likely adverse effects on the individual and determine whether the legitimate interests outweigh any adverse effect.
2. In line with the legitimate interests’ exception, we will collect, use or disclose your Personal Data for the following purposes:
  1. sanctions monitoring, money laundering, terrorism financing, fraud and credit risk detection and prevention; and
  2. detection and prevention of misuse of Services.
3. The purposes listed in the above Sections may continue to apply even in situations where your relationship with us (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 us to enforce our rights under a contract with you).
Whom We Share Personal Data With
1. Sharing for business purposes. We may share, disclose, or transfer your personal information to the following categories of recipients:
  1. Service providers that help us deliver, manage, develop, and improve the Services including but not limited to third-party hosting, cloud services and other information technology services providers, email communication and SMS software providers, identity verification services, background check providers, public and private records database providers, consumer reporting services, and fraud and identity management providers;
  2. Contract partners or business partners who are participating in the performance of the delivery of the Services; and
  3. Companies that are part of our corporate group.
2. These parties will access, process or store Personal Data while performing their duties to us. Moreover, as set out in “The Purposes of Collection, Use, and Disclosure of Your Personal Data”, we may also disclose Personal Data when required to do so by regulators or by law, and may share your personal information with the following categories of recipients: legal advisors; auditors for the performance of audits; courts and public authorities; and any acquirer or successor in the event of a corporate sale, merger, reorganisation, dissolution, or similar event if any of your personal information is part of the assets we transfer or share in preparation for such a transaction.
3. Aggregated information. From time to time, we may also share anonymised and/or aggregated information, such as by publishing a report on trends in the usage of our Services.
Withdrawal of Consent
1. The consent that you provide for the collection, use and disclosure of your Personal Data will remain valid until such time it is being withdrawn by you in writing. You may withdraw consent and request us to stop collecting, using and/or disclosing your Personal Data for any or all of the purposes listed above by submitting your request via email to our Data Protection Officer at the contact details provided above.
2. Upon receipt of your written request to withdraw your consent, we may require reasonable time 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.
3. Whilst we respect your decision to withdraw your consent, please note that depending on the nature and scope of your request, we may not be in a position to fulfil our contractual obligations to you or provide you with functions on our Website or any service that requires such Personal Data. We shall, in such circumstances, notify you before completing the processing of your request. Should you decide to cancel your withdrawal of consent, please inform us via email to our Data Protection Officer at the contact details provided above.
4. 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.
Your Right to Access and Correct Your Personal Data
1. If you wish to make (a) 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 (b) 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 the contact details provided above.
2. 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.
Security of Your Personal Data
1. To safeguard your Personal Data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, and against the accidental loss of, or damage to, Personal Data, we have put in place appropriate administrative, physical, security and technical measures from the point of collection to the point of destruction, including:
  1. We ensure that all our directors, employees, contractors, agents, and subcontractors comply with this Policy, and that they have access to your Personal Data on a need-to- know basis.
  2. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
  3. Personal Data will only be transferred to a third-party data intermediary if there is agreement by them to comply with our practice and procedures.
2. You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. We cannot ensure or warrant the security of any information you provide to us. To the fullest extent permitted by applicable law, we do not accept liability for unauthorised disclosure. By using the Services or providing personal information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of our Website. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on our ServicesWebsite, by mail or by sending an email to you.
How We Keep Your Personal Data Accurate
1. We generally rely on Personal Data provided by you (or your authorised representative). In order to ensure that your Personal Data is current, complete and accurate, please update us if there are changes to your Personal Data by informing our Data Protection Officer in writing or via email at the contact details provided below.
2. If we receive Personal Data relating to you from another source, we will check your Personal Data regularly and keep it accurate and up-to-date to the best of our knowledge. If we identify inaccurate or out-of-date Personal Data, we will take reasonable steps to amend or to erase that data.
How Your Personal Data is Retained
1. We may retain your Personal Data for as long as it is necessary to fulfil the purpose set out in this Policy, or as required or permitted by applicable laws.
2. 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.
3. It may sometimes be necessary to retain Personal Data if, for example, we are contractually bound to do so or if we have become involved in litigation or business disaster recovery in respect of which your Personal Data is relevant.
Governing Law and Dispute Resolution
1. This Policy shall be governed by and construed in accordance with the laws of Singapore.
2. In the event of a dispute arising out of or in connection with this Policy, the parties to the dispute shall use all reasonable efforts to resolve the dispute amicably.
3. If the dispute has not been amicably resolved within thirty (30) days of one party giving written notice of a dispute to the other, any dispute, controversy or claim arising under, out of, in connection with or in relation to this Policy, including any dispute as to its existence, validity, interpretation, performance, breach or termination and any dispute relating to any non-contractual obligations arising out of or in connection with it shall be referred to and finally resolved by arbitration in accordance with the Arbitration Rules of the Singapore International Arbitration Centre for the time being in force, which rules are deemed to be incorporated by reference in this Clause, and the conduct of the arbitration thereof shall be under the administration of the Singapore International Arbitration Centre. The arbitral tribunal shall consist of one (1) arbitrator. The seat of the arbitration shall be Singapore. The language of the arbitration shall be English. This arbitration agreement shall be governed by the laws of Singapore. This Clause shall not affect the right of any party to this Policy to seek such urgent interlocutory relief and the parties to this Policy agree irrevocably and unconditionally to submit to the exclusive jurisdiction of the courts of Singapore in respect thereof.