Legal & Privacy

Introduction

This website (“our website”) is owned and operated by hi Foundation Limited, a non-profit limited by guarantee incorporated in Singapore with the address 3 Fraser Street, DUO Tower, #05-25, Singapore 189352. (“the Company”, “we” or “us”). Each reference in these terms of use to “our website” includes all materials that we make available to you on our website.

By accessing and/or using our website, and/or using the services and functionalities made available through our website, you agree to comply with these terms of use.If you are accepting on behalf of your employer or another entity, you represent and warrant that: (i) you have full legal authority to bind your employer, or the applicable entity, to these terms of use; (ii) you have read and understood these terms of use; and (iii) you agree, on behalf of the party that you represent, to these terms of use.

If you do not agree to these terms of use or if you do not have the legal authority to bind your employer or the applicable entity, do not access and/or use our website or the services or functionalities available through our website.

If you are below 18 years old, you must stop using/accessing our website and/or using the services and functionalities made available through our website.

Access to and use of password-protected and/or secure areas of our website are restricted to authorised users only.You may not obtain or attempt to obtain unauthorised access to such parts of our website or to any other protected information, through any means not intentionally made available by us for your specific use.

Please check this page each time you use our website, as we may update these terms from time to time.

If you use any functions through our website (including, without limitation, any functions related to hi Dollars), those functions will be subject to additional terms and conditions which you must read and accept before using those functions.To the extent of any inconsistency with these terms, the terms and conditions of the relevant function apply to that function and any matters connected with it.

Your obligations

You agree to access and/or use our website and/or the services and functionalities made available through our website only for lawful purposes and in a lawful manner at all times, and ensure that any information or data you post or cause to appear on our website is accurate and agree to take sole responsibility for such information and data.

You must comply with any instructions we give you about how to use our website and must not do anything that interferes with or adversely affects the normal operation of the website (including the ability of other users to access or use the website).

You agree and undertake not to:

attempt to gain unauthorised access to or otherwise interfere or disrupt other computer systems or networks connected to our website;
interfere with another’s utilisation and enjoyment of our website;
use or upload, in any way, any software or material that contains, or which you have reason to suspect contains viruses, damaging components, malicious code or harmful components which may impair or corrupt our website’s data or damage or interfere with the operation of another user’s computer or mobile device and/or our website; or
access and/or use our website and/or the services and functionalities made available through our website other than in conformance with the acceptable use policies of any connected computer networks, any applicable internet standards and any other applicable laws.

You are responsible for ensuring the security of the systems and devices that you use to access our website, including through use of appropriate virus-checking and other security software.

Registration

You may need to register with us in order to access certain parts of our website. In this case, a username and password or other log-in details (“Log-in Credentials”) may either be: (i) be determined and issued to you by us; or (ii) provided by you and accepted by us in our sole and absolute discretion in connection with our website. We may at any time in our sole and absolute discretion forthwith invalidate the Log-in Credentials without giving any reason or prior notice and shall not be liable or responsible for any loss or damage suffered by or caused by you or arising out of or in connection with or by reason of such invalidation.

You are responsible for keeping your Log-in Credentials confidential so that they cannot be used without your permission.You will be responsible for any use of our website by anyone using your Log-in Credentials (whether such access and/or use is authorised or not), and you agree to indemnify us against any and all losses, liabilities, claims damages and expenses (including legal fees) attributable to any such access to and/or use of our website referable to your Log-in Credentials. You are to notify use immediately if you have knowledge that or have reason for suspecting that the confidentiality of the Log-in Credentials has been compromised or if there has been any unauthorised use of the Log-in Credentials.

Rights to suspend, terminate or block access

We may suspend, terminate or block your access to all or any part of our website at any time and without prior notice to you.

Intellectual property

All of the intellectual property rights in and to our website, including all content, information, functionalities, services or materials displayed, provided or made available on our website, are owned, licensed to or controlled by us.We may update and change the materials available on our website, including by removing materials, at any time in our discretion without notice to you.

You may download or print sections of our website if needed for your own personal use, but otherwise you may not reproduce or modify any part of our website without our express prior consent. To the extent that our website contains functionality that allows you to access or download specific materials through our website, your use of that functionality and the downloaded materials may be subject to separate terms and conditions which you will be asked to read and accept at the relevant time.

Website links

Our website may contain or link to information that has not been devised, verified or tested by us or any of our officers, employees or agents.These are provided for your information only.We do not take any responsibility for that information, nor endorse its accuracy or completeness.We are not liable for any errors, omissions, delays, defamation, liable, slander, falsehood, obscenity, pornography, profanity, inaccuracy or any other objectionable material contained in the contents, or the consequences of accessing, any linked website.

We do not guarantee that the information, or the provision of the hyperlinks to you, does not infringe third party rights.If our website contains a link to an external website, we do not endorse, recommend, approve, guarantee or introduce any third parties or the services and/or products that those third parties may offer.We accept no responsibility for them or any of the content available, or for any loss or damage that may arise from your use of them.

You may provide a link to the home page of our website at, on any website you operate, as long as you do not suggest any form of association, approval or endorsement on our part without our express prior permission and you promptly delete the link at our request.

Except as set out in this clause, you may not link to our website.

No financial services activities or advice

The information and any materials contained in this website should not be considered as an offer or solicitation to buy or sell financial instruments, provide financial advice, create a trading platform, or provide any other financial services of any kind in any jurisdiction.

The information contained on this website is not intended to provide and should not be construed as advice of any kind.You should obtain appropriate professional advice when necessary. It does not take into account your objectives, financial situation or needs.

Liability

Our website, including the services and/or functionalities made available through our website, are provided on an “as is” and “as available” basis. While we will use reasonable care and skill in operating our website, we cannot promise that our website will always be available, meet your requirements or completely free of faults, errors or compromise from cybersecurity events.

To the maximum extent permitted by law, except as expressly set out in these terms of use, we exclude:

all conditions, representations, warranties and statutory guarantees, whether express or implied, in relation to our website, including the warranties of non-infringement of third party rights; and
any liability, whether in contract, tort (including negligence), or otherwise, for any indirect or consequential loss, damage or expense incurred by you or any other user in connection with our website.

To the extent we are unable by law to exclude any implied condition, representation, warranty or statutory guarantee in relation to the provision of goods or services through our website, we limit our liability for a breach to the re-supply of those goods or services, or payment for such re-supply.This is without limitation to any other exclusions or restrictions of our or others’ liability in connection with this website.

Privacy

We will manage any personal information that we collect through our website in accordance with our Privacy Policy, which you can access here

Rights of Third Parties

A person who is not a party to these terms of use has no right under any applicable laws to enforce any of these terms, regardless of whether such person or entity has been identified by name, as a member of a class or as answering a particular description.

Governing Law

These terms of use are governed by the laws in force in the Republic of Singapore and are subject to the exclusive jurisdiction of the courts in that place.

Questions?

Please contact us at [email protected] if you have any questions about our website.

Introduction

We are hi Foundation Limited, a non-profit limited by guarantee incorporated in Singapore with the address 3 Fraser Street, DUO Tower, #05-25, Singapore 189352. (“we” or “us”).

Your privacy is important to us. We are committed to protecting the privacy, confidentiality, and security of the personal data we hold by complying with the requirements under applicable laws and regulations. We are equally committed to ensuring that all our employees, service providers and agents uphold these obligations. When you engage us to provide services for you, we will be the “data controller” for your personal data.

This policy explains how we collect, use, process, manage and disclose personal data within our organisation.

Explaining the legal basis we rely upon to process your personal information

Data protection laws set out various grounds on which an organisation may lawfully collect and process your personal data. These include:

Consent

We can collect and process your data with your consent. For example, when we are processing sensitive or special personal data, such as information relating to your health or religious beliefs. In many circumstances, if we rely on your consent as our legal basis for processing your personal data, you have the right to withdraw that consent at any time.

Contractual obligations

In many circumstances, we require your personal data to comply with contractual obligations. For example, we collect your identity and contact information when we verify you as a new customer. If you are unable to provide such information to us, we may not be able to perform the contract we have with you or your organisation or enter into a contract with you or your organisation.

Legal compliance

If the law requires us to, we may need to collect and process your personal data. For example, we may require your personal data to comply with anti-money laundering legislation or laws relating to the provision of legal services. If you are unable to provide such information to us, we may not be able to perform the contract we have with you or your organisation or enter into a contract with you or your organisation.

Legitimate interests

In many situations, we require your personal data to pursue our legitimate interests in a way which might reasonably be expected as part of running our business and which does not materially impact on your rights, freedoms or interests. For example, it may be in our legitimate interests to use your personal information for marketing purposes to assist us with the growth of our business.

Data protection laws do vary across the different jurisdictions in which we operate. Please contact us if you require details of the specific legal ground we are relying on to process your personal data.

How we collect personal data

We collect personal data about you in the following ways:

where you register for an account or to receive emails from us
when you order products or services from us (eg hi Dollars)
when you submit a query or request to us
when you respond to a survey that we run or fill in forms on one of our websites
by tracking your use of our websites and mobile applications
from public sources
from examination of public and private blockchains
from third parties who are entitled to disclose that information to us
when you apply for a job with us

In some cases, we may be required by law to collect certain types of personal data about you.

Where we collect personal data from you, we will generally do so ourselves. However, in some cases we may collect personal data from a third party, such as through your representatives, contractors who provide services to us, or third parties who refer you to us because they think you may be interested in our products or services.

Kinds of personal data we collect, use, hold and disclose

The kinds of personal data that we collect, use, hold and disclose about you may include:

identifying information, such as your name and date of birth
contact information, such as your postal address, email address and telephone number
personal information
social media handles and other social media profile information that you make available to us or to the public
financial information, such as credit card, bank account or other payment details
blockchain identifiers, such as blockchain addresses and public keys
usernames and passwords that you create when registering for an account with us
details of any products or services that we provide to you
information about how you use the products and services we provide
records of our communications with you, including any messages you send us

Without this information, we may not be able to provide you with our products or services (or with all of the features and functionality offered by our products or services) or to respond to queries or requests that you submit to us.

Purposes for which we collect, use and/or disclose personal data

We collect, use and/or disclose personal data about you for the following purposes:

to verify your identity when you are dealing with us
to determine your eligibility for any of our products or services (eg hi Dollars)
to determine your compliance with the terms and conditions that apply to any of our products or services and applicable law
to enable us to provide our products and services (eg creation, sale and/or distribution of the hi Dollar)
to improve our website based on your information and feedback
to answer your queries and requests
to conduct “know-your-client” processes
to comply with any applicable rules, laws or regulations, regulatory policies, industry codes of practice or guidelines, judgments, orders, notices, directions or requests issued by any court, or any administrative, governmental or regulatory body, whether in Hong Kong or otherwise, including but not limited to rules and regulations relating to anti-money laundering and countering the financing of terrorism and the carrying out of audit checks, surveillance and investigations
to carry out market analysis and research
to monitor use of our products and services
to assess, maintain, upgrade and improve our products and services
to carry out education and training programs for our staff
to manage and resolve any legal or commercial complaints or issues
to carry out planning and forecasting activities and other internal business processes
to keep you informed about our activities, including by sending out newsletters
to connect you with our users of our products and services

We may also collect, use and/or disclose your information for other purposes in accordance with your requests or instructions.

Direct marketing

We may from time to time use your personal data in order to send you marketing materials about products or services that we think you may be interested in (including in some cases products and services that are provided by a third party). We may not use your personal data unless we have received your consent.

There are several ways you can stop receiving direct marketing communications from us. Click the ‘unsubscribe’ or ‘opt-out’ link in any email communication that we send you, or email us at [email protected]. We will then stop any further marketing related emails from us. Please note that you may continue to receive communications for a short period after changing your preferences while our systems are fully updated. In relation to any third-party marketing, we will get your express opt-in consent before we share your personal data with any company outside our company for any marketing purposes.

We may use your following personal data for the purpose of direct marketing:

identifying information, such as your name and date of birth
contact information, such as your postal address, email address and telephone number
products and services portfolio information and demographic data held by us from time to time

We may use your personal data to market the following products and/or services to you:

New service offerings, services that you are not yet using.

If we use your personal data in any direct marketing communications, you have the right to request that we provide you with the source of that personal data. There is no fee for requesting this information. We will provide you with the source of the personal data, unless it is impracticable or unreasonable to do so.

Please indicate your consent to receiving information relating to the above by contacting us at [email protected].

We may also use and disclose your information for other purposes in accordance with your requests or instructions.

People to whom we may disclose personal data

We may share personal data about you with:

your representatives, advisers and others you have authorised to interact with us on your behalf
our staff who need the information to discharge their duties
related entities within our corporate group
our business partners, agents and service providers
payment system operators and financial institutions
prospective purchasers of all or part of our business or a related entity
professional advisers who we engage to provide advice on our business
government authorities who ask us to disclose that information, or to other people as required by law

We may also collect, use and/or disclose your information to other organisations in accordance with your requests or instructions.

In some cases, the people to whom we disclose your personal information may be located overseas. Further, we may have servers located overseas.

Cookies

We use cookies to monitor and observe your use of our websites, compile aggregate data about that use, and provide you with a more effective service (which may include customising parts of our websites based on your preferences and past activities on those websites). "Cookies" are small text files created and stored on your hard drive by your internet browser software, in order to hold relevant information about the web page you are currently viewing. Most internet browsers have a facility that will allow you to disable cookies altogether – please refer to your browser’s help menu to find out how to do this. While you will still be able to browse our websites with cookies disabled on your internet browser, some website functionality may not be available or may not function correctly.

Storage and security of personal data

We generally store the personal data that we collect in electronic databases, some of which may be held on our behalf by third party data storage providers. Sometimes we also keep hard copy records of this personal data in physical storage facilities. We use a range of physical and technical security processes and procedures to protect the confidentiality and security of the information that we hold, and we update these from time to time to address new and emerging security threats that you become aware of.

Google Analytics

Our website uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses cookies to help the website analyse how users use our website.

The information generated by the cookie about your use of our website (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google.

You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of our website. By using our website, you consent to the processing of data about you by Google in the manner and for the purposes set out above.

Retention of personal data

Your personal data will only be kept as long as required for the purposes for which such personal data was collected, used and/or disclosed, or for any legal or business purposes.

We may retain your personal data for a period of at least 12 years. At our discretion, we may retain personal data for longer than the said period if we consider it necessary or desirable to do so to meet our legal or regulatory obligations.

Where your data may be processed

To facilitate our global operations, we may transfer, store and process your information within our group of associated entities around the world.

For those individuals residing in the European Economic Area (EEA), this may sometimes involve the transferring of your personal information out of the EEA. Laws in these countries may differ from the laws applicable to your country of residence. Where we transfer, store and process your data outside of the EEA we have ensured that appropriate safeguards are in place to ensure an adequate level of data protection. This may be an adequacy decision of the European Commission confirming an adequate level of data protection in the respective non-EEA country or an agreement on the basis of the EU Model Clauses (a set of clauses issued by the European Commission). Further information on these EU Model Clauses and the rights they provide to data subjects can be found on the European Commission website.

Please contact us if you require further information on the specific mechanism used by us when transferring your personal data outside of the EEA.

Your consent

By using our website, providing personal data and/or using any of our products or services, you agree that:

you consent to this privacy policy, as updated from time to time; and
if you have provided personal data to us relating to any other person, you:

have a right to provide that information;
have provided a copy of this privacy policy, as updated from time to time, to that person; and
each such person has agreed to those terms.

What are your rights over your personal data?

You have a number of rights in relation to the personal data that we hold about you. These rights are subject to certain exemptions and do differ across the jurisdictions in which we operate.

Request access to the personal data we hold about you

If you want to access any of the personal data that we hold about you or to correct some aspect of it (for example, because you think it is incomplete or incorrect), please contact our privacy compliance team using the contact details set out below. To protect the integrity and security of the information we hold, we may ask that you follow a defined access procedure, which may include steps to verify your identity. In certain cases we may charge you an administration fee for providing you with access to the information you have asked for, but we will inform you of this before proceeding. There may be cases where we are unable to provide the information you request, such as where it would interfere with the privacy of others or result in a breach of confidentiality. In these cases we will let you know why we cannot comply with your request.

Even if you do not request access to and/or correct your personal data held by us, if we are satisfied that, having regard to the reasons for which we hold your personal data, that personal data is inaccurate, incomplete, out-of-date, irrelevant or misleading, we may take reasonable steps to correct that information.

For EU residents, we will do this for no fee, in accordance with applicable legislation.

Right to rectification

If the information we hold about you is inaccurate, you have the right to have this information rectified.

Right to erasure / ‘Right to be forgotten’

You can ask us to delete or remove your information in certain circumstances. For EU residents, whenever you have given us your consent to use your personal data, you have the right to change your mind at any time and withdraw that consent. In cases where we are processing your personal data on the basis of our legitimate interests, you can ask us to stop processing your data for reasons connected to your individual situation. We must then do so unless we believe we have a legitimate overriding reason to continue processing your personal data.

Right to data portability

In certain circumstances, you may have the right to obtain your personal data in a structured, commonly used and machine readable format and to reuse it elsewhere or ask us to transfer it to a third party of your choice.

Right to object

In certain circumstances, you have a right to object to processing being carried out by us. Where personal data is being processed for direct marketing purposes, you have a right to object at any time

Rights in relation to automated decision-making and profiling

In certain circumstances, you have a right not to be subject to a decision which is based on automated processing where the decision will produce a legal effect or a similarly significant effect on you.

To protect the confidentiality of your information, we will require you to verify your identity before proceeding with any request. If you have authorised a third party to submit a request on your behalf, we will ask them to prove they have your permission to act.

Complaints

We try to meet the highest standards in order to protect your privacy. However, if you are concerned about the way in which we are managing your personal data and think we may have breached any applicable privacy laws, or any other relevant obligation, please contact our privacy compliance team using the contact details set out below. We will make a record of your complaint and refer it to our internal complaint resolution department for further investigation. We will deal with the matter as soon as we can, and keep you informed of the progress of our investigation.

Changes to this policy

We may make changes to this policy from time to time, to take into account changes to our standard practices and procedures or where necessary to comply with new laws and regulations. The latest version of this policy will always be available on our website.

Contact details

If you want any further information from us on privacy matters, please contact our privacy compliance team at [email protected].

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