Privacy Policy

1. INTRODUCTION

Thank you for visiting ncollector.com. The relevant NCollector entity as a/the data controller, provides this Privacy Notice Statement to describe our practices regarding the collection, storage, use, disclosure and other processing of Personal Data (defined below). By visiting, accessing, or using ncollector.com and associated application program interfaces or mobile applications (the “NCollector Platform”), you (a) acknowledge that you have the right, capacity and authority to accept this Privacy Notice Statement (the “Privacy Notice”); (b) acknowledge that you have read and understand this Privacy Notice and (c) consent to the policies and practices outlined in this Privacy Notice. So please read them carefully to understand what we do.

This Privacy Notice explains what data we collect, why we collect it, how such data is used and stored, how such data may be shared by us, rights you may have, and how you can contact us about our privacy practices. If you do not wish your Personal Data (as defined below) to be used in the ways described in this Privacy Notice, you shall, shall not use this NCollector Platform, technologies, products and/or functionalities offered by the NCollectorPlatform (collectively, the “Services”).

2. Definitions

In addition to the terms defined elsewhere in this policy, the following terms, the first letter of which is capitalized, whether used singularly or plural in this policy, will have the following definition:

2.1 “Recipient”: means the natural or legal person, public authority, agency or any other body that receives the communication of Personal Data, whether or not it is a third party.

2.2 “Personal data” means any information relating to an identified or identifiable natural person (hereinafter referred to as “Data Subject”); an “identifiable natural person” means a natural person who can be identified, directly or indirectly, in particular by reference to an identifier, such as a name, an identification number, location data, an online identifier, or to one or more specific elements specific to his physical, physiological, genetic, mental, economic, cultural or social identity.

2.3 “Data Controller”: means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the Data Processing.

2.4 “Processor”: means the natural or legal person, public authority, agency or other body that processes Personal Data on behalf of the Controller.

2.5 “Processing”: means any operation or set of operations performed or not performed with the aid of automated processes and applied to personal data or sets of personal data, such as collection, recording, organization, structuring, storage, adaptation or modification, retrieval, consultation, use, communication by transmission, dissemination or any other form of making available, reconciliation or interconnection, limitation, erasure or destruction.

3. CONTROLLER AND CONTACT DETAILS

NCollector acts as a controller of your personal data where we determine how and why personal data can be used, and the NCollector entity is the primary controller of your personal data. This Privacy Notice does not apply where we act as a processor or service provider to another controller (including our customers).

4. WHAT PERSONAL DATA WE COLLECT AND HOLD, AND HOW WE COLLECT IT

NCollector collects, processes, and stores Personal Data via your use of the Service or where you have given your consent. This Personal Data may include contact details, copies of identification documentation provided by you or derived from publicly accessible databases, your government identification number as well as information relating to your device or internet service (such as an IP address and a MAC number).

To understand how NCollector protects the data it collects from its users, please see Section 13 (“Information Security”) below.

We collect information you provide during the NCollector Platform on-boarding process, which may be a completed, incomplete, or abandoned process. We also collect Personal Data when you communicate with us through customer support, subscribe to marketing communications, correspond with us by phone, email, or other communication channels, or when you conduct a transaction on the NCollector Platform. We may actively or automatically collect, use, store, or transfer your Personal Data, which may include, without limitation, the following:

Personal identification information such as name, email, phone number, nationality, date of birth, address, and government identification information;
Institutional details such as corporate legal name, corporate registration information, government identification number, proof of identity and legal existence, address, business description, and beneficial owner information;
Commercial information such as data related to transactions conducted on the NCollector Platform;
Financial information such as credit/debit card numbers and bank account information;
Correspondence Information such as communication with our Customer Support team and response to user survey;
Information required by regulatory agencies such as state and federal licensing authorities and consumer protection agencies; and
Other identifiers such as device fingerprint data, IP address, and geolocation information.

We may also collect Personal Data about you from third parties, such as electronic verification services, referrers, marketing agencies or liquidity providers. If so, we will take reasonable steps to ensure that they are made aware of applicable privacy laws. We may also use third parties to analyze traffic on our website, which may involve the use of cookies (additional information on Cookie Usage is set out in Section 13 below). Information collected through such analysis is not anonymous.

We will not collect Sensitive Information about you without your consent, unless an exemption or exception applies. These exemptions or exceptions include if the collection is required or authorized by law, or if it is necessary to take appropriate action in relation to suspected unlawful activity or serious misconduct.

If the Personal Data we request is not provided by you, we may not be able to provide you with the benefit of our Services or meet your needs appropriately. Accordingly, we do not give you the option of dealing with us anonymously or under a pseudonym.

Furthermore, we conduct business and collect Personal Data from individuals and entities located in various jurisdictions in accordance with data protection laws. Where applicable, we are required to protect Personal Data processed in such jurisdictions in accordance with the applicable data protection laws. To understand more about how we protect the data collected from individuals and entities located within such jurisdictions, please see Sections 18 to 20 below.

5. UNSOLICITED PERSONAL DATA

We may receive unsolicited Personal Data about you. We destroy or de-identify all unsolicited Personal Data we receive, unless it is relevant to the purposes stated in this Privacy Notice for collecting Personal Data. We may retain additional information we receive about you if it is combined with other information we are required or entitled to collect. If we do this, we will retain the information in the same way we hold your other Personal Data.

6. WHO WE COLLECT PERSONAL DATA ABOUT

The Personal Data we may collect, and hold includes (but is not limited to) Personal Data about users, potential users, service providers or suppliers of the NCollector Platform or our Services, prospective employees, employees and contractors and other third parties with whom we come into contact.

7. HOW WE USE YOUR PERSONAL DATA

NCollector uses Personal Data to administer, deliver, improve, and personalize the Services for you and to comply with our legal and regulatory obligations. We also may use such data to communicate with you in relation to other products or services offered by NCollector and/or its partners to consider any concerns or complaints you may have.

We may use and disclose your Personal Data for any of these purposes. We may also use and disclose Personal Data for secondary purposes which are related to the primary purposes set out in this section, or in other circumstances authorized by the law.

Sensitive Information will be used and disclosed for the purpose for which it was provided (or a directly related secondary purpose), unless you explicitly consent otherwise, or an exemption under law applies. Below are specific ways in which we may process your Personal Data:

Provide you with our services. We use your Personal Data to provide you with our Services pursuant to our terms of service. For example, we need to know certain financial information to conduct fiat transfers into and out of your account.
Detecting and preventing fraud. Your Personal Data is used to detect and prevent fraud.
Protect the security of our Services. We process your Personal Data, such as information about your device and activity, to maintain the security of your account and the NCollector Platform.
User/customer support. We process your Personal Data when you contact our Customer Support team to help us address your question.
Enhance our Services. We process your Personal Data to understand how our Services are being used to improve our Services, train our systems to improve our Services provided and develop new Services.
Product marketing. We process your Personal Data to identify our Services that we believe may be of interest to you. We may contact you about them. For more information, refer to Section 12 (Communications) below.
Consent. We may use your Personal Data for additional purposes with your consent.
Other business purposes. We may use your Personal Data for other reasonably expected business purposes as permitted by law or when required to comply with our legal obligations.

Processing Personal Data Without Consent

If you do not provide us with consent to process your Personal Data, we may still process your Personal Data under one of the following bases:

Public interest. We will process your Personal Data without your consent where it is necessary to protect the public interest.
Legal Proceedings. We will process your Personal Data without your consent where it is necessary to initiate or defend legal proceedings or in relation to judicial or security procedures.
Protection of your interests. We will process your Personal Data without your consent where it is necessary to protect your interests.
Performance of a contract. We will process your Personal Data without your consent 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; we use this basis for provision of our Services.
Compliance with a legal obligation. We will process your Personal Data without your consent where we need to comply with a legal obligation we are subject to.

To Whom We Might Disclose Personal Data

NCollector may disclose Personal Data to:

Members of our corporate group, which includes our subsidiaries, holding companies and companies under common control including their respective contractors, affiliates, employees or representatives.
Our service providers and other third parties which assist us in providing Services to you and/or as required or permitted by law or professional standards including, for example, payment processing, customer support, data analytics, information technology, data processing, network infrastructure, storage and tax reporting.
Entities in connection with corporate transactions involving NCollector, including any financing, acquisition or dissolution proceedings which involve disclosing a certain portion or all of our business or assets.
Government entities or other parties to the legal process, including law enforcement agencies and authorities, officers, regulators or other third parties to comply with any law, court order, subpoena or government request.
Professional advisors, including legal, accounting or other consulting services for purposes of audits or to comply with our legal obligations.

Other than as disclosed in this Privacy Notice, NCollector does not share your Personal Data with any other third parties unless required to do so by law or legal reporting obligations. The NCollector Platform may contain links to other third-party websites where their own privacy policies / notices may apply and NCollector is not responsible for the privacy policies / notices of such third-party websites.

If we disclose your Personal Data to service providers that perform business activities for us, they may only use your Personal Data for the specific purpose for which we supply it. We will take reasonable steps to ensure that all contractual arrangements with third parties adequately address compliance with applicable privacy laws. Additionally, we have implemented standards to prevent money laundering, terrorist financing and circumventing trade and economic sanctions. These standards require us to undertake due diligence on our users in order to be compliant with applicable laws and regulations. This may include the use of third-party data and service providers which will cross-reference your Personal Data for identity verification, fraud detection and prevention, transaction monitoring, credit verification and security threat detection.

8. HOW WE STORE YOUR PERSONAL DATA

We recognize the importance of securing the Personal Data of our users. We take steps to ensure your Personal Data is protected from misuse, interference or loss, and unauthorized access, modification or disclosure. Your Personal Data is generally stored in our or our affiliates ‘computer databases and/or with third party storage providers. In relation to information that is held on our computer database, we apply data security guidelines to ensure that your Personal Data is managed securely.

For more information, please refer to Section 14 (Information Security) below.

The data that we collect from you may be transferred to, and stored at, a destination outside of the country of your residence. It may also be processed by staff operating outside of your residence who work for us or for one of our service providers. By submitting your Personal Data, you expressly consent to this transfer, storing or processing, except users located in certain jurisdictions, as detailed in Sections 18 to 20 below.

We retain your Personal Data for as long as is reasonably necessary to provide services to you, for our legitimate business purposes, and to comply with our legal and regulatory obligations. If you close your account on the NCollector Platform, we will continue to retain your Personal Data as necessary to comply with our legal and regulatory obligations. For example, we are subject to certain anti-money laundering laws which require us to retain records we used to comply with our client identification and due diligence obligations for an additional period after our business relationship with you has ended.

9. SENDING INFORMATION TO OTHER COUNTRIES

The NCollector group operates a global business and Personal Data may be stored and processed in any country where we have operations or where we engage service providers. We may disclose information to third party storage providers or affiliates that are located outside your country of residence or disclose to third-party storage providers or affiliates that are located outside your country or residence.

We may transfer Personal Data that we maintain about you to recipients in countries other than the country in which the Personal Data was originally collected. Those other countries may have data protection or privacy rules that are different from those of your country. However, we will take measures to ensure that any such transfers comply with applicable data protection laws and that your Personal Data remains protected to the standards described in this Privacy Notice. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your Personal Data. By communicating electronically with NCollector, you acknowledge and agree to your Personal Data being processed in this way.

10. ACCESS, CORRECTION, AND DELETION OF YOUR PERSONAL DATA

Subject to exceptions set out in the law, you have the right to obtain a copy of your Personal Data upon request and ascertain whether the information we hold about you is accurate and up-to-date. We will provide access within 30 days of your request. If we refuse to provide the information, we will provide reasons for the refusal. We will require identity verification and specification of what information is required before providing you with access. If any of your Personal Data is inaccurate, you may request to update your information. Where we are satisfied that the request to update the information is accurate, we will take reasonable steps to correct the information within 30 days, unless you agree otherwise. If you are entitled by law, you may request to delete your Personal Data, with the exception that we may refuse your deletion request in certain circumstances, such as compliance with law or legal purposes. For data access, correction, or deletion requests, or to request withdrawal of your previously provided consent, please send an email with your request to the relevant email address set out in Section 2 above with the subject “DATA INQUIRY REQUEST”.

11. CHILDRENS’ PERSONAL DATA

NCollector does not knowingly offer services to or collect the Personal Data of anyone under the age of 18. If we learn that we have collected Personal Data of anyone under the age of 18, we will promptly delete it from our systems. If you are aware of anyone under the age of 18 using our Services, please notify us so we can take prompt action to prevent access to our Services.

12. COMMUNICATIONS

We may only use Personal Data we collect from you for the purposes of direct marketing without your consent if the Personal Data does not include Sensitive Information, you would reasonably expect us to use or disclose the information for the purpose of direct marketing, we provide a simple way of opting out of direct marketing and you have not requested to opt out of receiving direct marketing from us.

If we collect Personal Data about you from a third party, we will only use that information for the purposes of direct marketing if you have consented (or it is impracticable to obtain your consent) and we will provide a simple means by which you can easily request not to receive direct marketing communications from us. We will draw your attention to the fact you may make such a request in our direct marketing communications.

We may communicate company news, promotions, and information relating to our products and services provided by NCollector. We may share Personal Data with third parties to help us with our marketing and promotional projects or sending marketing communications.

Users can opt out from these marketing communications at any time by following the unsubscribe link within any marketing communications sent to you or by contacting our Customer Service at the Support Center.

For Services related communications, such as surveys, policy/terms updates and operational notifications, you will not be able to opt out of receiving such information.

13. COOKIE USAGE

While you access our website, i.e., ncollector.com, we may use the industry practice of placing a small amount of data that will be saved by your browser (“Cookies”). This information can be placed on your computer or other devices used to visit our Site. We use Cookies to enhance your experience of using our Site. The information is used to identify users, remember user preferences and allow users to complete tasks without having to re-enter information when browsing from one webpage to another or when re-visiting our website at a later date. We also use Cookies to collect and analyze website usage data, related to user use and patterns. This data is used to improve our website and enhance users ‘experience. We may also use the information collected to ensure compliance with our regulatory and Anti-Money Laundering (“AML”) requirements, and to ensure your account security has not been compromised by detecting irregular, suspicious, or potentially fraudulent account activities.

Set up, you can set your browser to block or alert you about these Cookies, but this may affect the functionality of the Services or your user experience. Session Cookies are added when a user starts to browse our website or interacts with a specific feature and are deleted when the browser is closed. Persistent Cookies are added when a user starts to browse our website or interacts with a specific feature but may remain stored on your device until a certain termination date is reached.

14. INFORMATION SECURITY

We have put in place appropriate information security measures to prevent your Personal Data from being accidentally lost, accessed, altered, disclosed, used or destroyed in an unauthorized way (or other similar risks). We take various measures to ensure information security, including encryption of the NCollector Platform communications; required two-factor authentication for all sessions; periodic review of our Personal Data collection, storage, and processing practices; and restricted access to your Personal Data on a need-to-know basis for our employees and vendors who are subject to strict contractual confidentiality obligations.

If you have any questions about information security or report any security issues, please contact us by sending an email to the relevant email address set out in Section 2 above with the subject “INFORMATION SECURITY REQUEST”.

15. CONTACTING NCollector ABOUT PRIVACY QUESTIONS OR CONCERNS

If you have any questions about this Privacy Notice or the use of your Personal Data, please contact us by sending an email to the relevant email address set out in Section 2 above with the subject “PRIVACY REQUEST”.

When handling requests to exercise your privacy rights, we check the identity of the requesting party to ensure that he or she is the person legally entitled to make such a request. While we endeavor to respond to these requests free of charge, should your request be repetitive or unduly onerous, we reserve the right to charge you a reasonable fee (if applicable) for compliance with your request. To exercise your privacy rights, please send an email with your request to the relevant email address set out in Section 2 above with the subject “DATA INQUIRY REQUEST”.

16. CHANGES TO OUR Privacy Notice

We may update this Privacy Notice at any time by posting the amended version on the NCollector Platform including the effective date of the amended version, so please check frequently to see if there are any updates and changes. Your continued access to or use of the NCollector Platform and/or the Services constitutes your acknowledgment and acceptance of such changes to this Privacy Notice.

17. LANGUAGES

This Privacy Notice may be posted in different languages. If there are any discrepancies, the English version shall prevail.

18. ADDITIONAL INFORMATION FOR PERSONS SUBJECT TO EU DATA PROTECTION LAWS

For users who are located in the EEA or other locations subject to EU data protection laws (collectively, “European Residents”), we adhere to relevant and applicable EU data protection laws and provide European Residents with the following additional information. For the purposes of this section, “Personal Data” has the meaning provided in the General Data Protection Regulation (EU) 2016/679 (GDPR).

A. Legal Basis For Processing Personal Data. We process Personal Data subject to the GDPR on one or more of the following legal bases:

To comply with legal obligations and regulations. To comply with applicable laws, including “know your customer” obligations based on applicable anti-money laundering and anti-terrorism requirements, financial crime and fraud prevention, suspicious activity reporting, responding to requests from public authorities, complying with economic and trade sanctions requirements, performing customer due diligence, performing audit and risk assessments, preparing tax reports, fulfilling our retention obligations and handling legal claims.
To comply with contractual obligations. To comply with our contractual obligations to you under our terms of service, including to provide you with our services and customer support services, and to optimize and enhance the NCollector Platform.
Consent. To provide and market our services to you based on your consent. You may withdraw your consent at any time without affecting the lawfulness of processing based on consent before consent is withdrawn.
Legitimate interest. To monitor the usage of the NCollector Platform, fraud prevention, network and information security, conduct automated and manual security checks of our Services, to engage in direct marketing activities and to protect your rights. When we process your personal data for our legitimate interests, we consider and balance any potential impact on you and your rights under data protection laws.

B. European Privacy Rights. European Residents have the following rights under the GDPR with respect to their Personal Data, subject to certain exceptions provided under the law. We will advise you in our response to your request where we are relying on such exemptions. You should include adequate information to identify yourself and other relevant information that will reasonably assist us in fulfilling your request.

Right to Access and Rectification. You may submit a request that NCollector disclose the Personal Data we process about you and correct any inaccurate Personal Data.
Right to withdraw consent. Where we have relied upon your consent to process your Personal Data, you have the right to withdraw that consent. This does not affect the lawfulness of processing based on your consent until withdrawal.
Right to Erasure. You may submit a request that NCollector delete the Personal Data that we have about you.
Right to Restriction of Processing and Right to Object. You have the right to restrict or object to our processing of your Personal Data under certain circumstances.
Right to Data Portability. You have the right to receive the Personal Data you have provided to us in an electronic format and to transmit the Personal Data to another data controller.
Right to complain. You may lodge a complaint with a data protection supervisory authority.

C. Auto decision-making. We may engage in automated decision-making for purposes of risk and fraud detection. When we do, we implement suitable measures to safeguard your rights and freedoms and legitimate interests, including the right to obtain human intervention, to express your point of view and to contest the decision.

D. Transfers of Personal Data out of the EEA. NCollector enters into appropriate data processing agreements and standard contractual clauses approved by the European Commission for the transfer of data. We may transfer Personal Data from the EEA to countries outside of the EEA where the transfers are necessary to satisfy our obligations to you under our terms of service (including providing you with our Services and to optimize and enhance the NCollector Platform) and where you have consented to the transfer of your Personal Data to a third country.

19. INFORMATION SECURITY

For users who are located in Singapore, we adhere to the PDPA and provide Singapore residents with the following additional information. For the purposes of this section, “Personal Data” has the meaning provided in section 2 of the PDPA.

A. Transfers of Personal Data out of Singapore. If your personal data has been processed in Singapore, prior to transferring such personal data from Singapore to a jurisdiction or territory outside Singapore, NCollector will generally take appropriate steps to ensure that the recipient of the personal data is bound by legally enforceable obligations to provide to the transferred personal data a standard of protection that is at least comparable to the protection under the PDPA (“Comparable Standard”). To this end, NCollector will ensure that at least one of the following measures is implemented:

you consented to such transfer after you have been given a reasonable summary in writing of the extent to which your personal data to be transferred will be protected to a Comparable Standard (including but not limited to this Privacy Notice);
the overseas recipient of such personal data is bound by law, contract, binding corporate rules or any other legally binding instrument to protect the transferred personal data to a Comparable Standard; and/or
the overseas recipient of such personal data holds a valid certification under the Asia Pacific Economic Cooperation Cross Border Privacy Rules (“APEC CBPR”) System or the Asia Pacific Economic Cooperation Privacy Recognition for Processors (“APEC PRP”) System.

Where the above measures are not feasible, NCollector may still proceed with the transfer of your personal data from Singapore to a recipient outside of Singapore if:

the transfer is necessary for a use or disclosure that is in your vital interests or in the national interest and NCollector has taken reasonable steps to ensure that the personal data will not be used or disclosed by the recipient for any other purpose; and/or
the transfer is reasonably necessary for the conclusion or performance of a contractual obligation between you and NCollector.

B. Security of your Personal Data. If we have credible grounds to believe that a data breach has occurred, we will take steps to assess whether the data breach is notifiable under the PDPA. Once we assess that a data breach is a notifiable data breach, we will notify the Personal Data Protection Commission of Singapore and you as soon as it is practicable. If we share your personal data with our third party service providers, we will require them to process it strictly in accordance with our instructions or as otherwise required by the PDPA.

20. INFORMATION SECURITY

For users who are located in Hong Kong, we adhere to the PDPO and provide Hong Kong residents with the following additional information. For the purposes of this section, “Personal Data” has the meaning provided in section 2 of the PDPO.

A. Transfers of Personal Data out of Hong Kong. NCollector may transfer your Personal Data from Hong Kong to a jurisdiction or territory outside Hong Kong on any of the following grounds:

NCollector has reasonable grounds for believing that there is in force in that jurisdiction or territory any law which is substantially similar to, or serves the same purposes as the PDPO;
you have consented in writing to such transfer (which you hereby grant if you have not previously done so);
NCollector has reasonable grounds for believing that, in all the circumstances of the case:

(a) such transfer is for the avoidance or mitigation of adverse action against you;

(b) it is not practicable to obtain your written consent to such transfer; and

your Personal Data is exempt from data protection principle 3 (as defined in Schedule 1 to the PDPO) by virtue of an exemption under Part 8 of the PDPO.

NCollector has taken all reasonable precautions and exercised all due diligence to ensure that your Personal Data will not, in that place, be collected, held, processed or used in any manner which, if that place were Hong Kong, would be a contravention of a requirement under the PDPO.