Privacy Policy

1. Introduction

As part of our daily business operations, we collect personal information from our clients and prospective clients in order to provide them with our products and services and ensure that we can meet their needs when providing these products and services, as well as when providing them with any respective information.

Your privacy is of utmost importance to us, and it is our policy to safeguard and respect the confidentiality of information and the privacy of individuals.

This Privacy Policy sets out how products and services provided by Samazn Pte Ltd., Samazn Canada Ltd.; and their affiliates and subsidiaries (collectively, “Samazn”, “the Company”, “We”, “Us”, and the trading services provided by Samazn (collectively the “Platform”), collects, uses and manages the personal information we receive from you, or a third party, in connection with our provision of services to you or which we collect from your use of our services and/or our website.

The Privacy Policy also informs you of your rights with respect to the processing of your personal information.

Our Privacy Policy is reviewed regularly to ensure that any new obligations and technologies, as well as any changes to our business operations and practices are taken into consideration, as well as that it remains abreast of the changing regulatory environment.

Any personal information we hold will be governed by our most recent Privacy Policy.

Please note that if you are an employee of the Company, a contractor to the Company or a third-party provider, your personal information will be used in connection with your employment contract or your contractual relationship, whichever applies.

This Privacy Policy applies to the processing activities performed by Samazn to the personal information of its clients and its potential clients and website visitors.

We may amend this Privacy Policy at any time by posting the amended version on this site including the effective date of the amended version. We will announce any material changes to this Privacy Policy on our website.

2. Definitions

2.1 As used herein, the following terms are defined as follows:

2.1.1 “Crypto Asset”

means Bitcoin, Litecoin, Ethereum, Ethereum Classic, Monero, Zcash and such other cryptocurrencies or other similar digital assets that may be available for purchase, sale or trade via the Platform from time to time.

2.1.2 “Samazn Account”

means a user account accessible via the Services where transactional data and other information related to you may be stored by Samazn on your behalf.

2.1.3 “Services”

means the website, mobile application and application programming interface provided by Samazn, and the trading and other services provided by Samazn as described in the terms and conditions governing your use of the Platform available at:

2.1.4 “Personal Information” or “Personal Data” or “your data”

refers to any information relating to you, as an identified or identifiable natural person, including your name, an identification number, location data, or an online identifier or to one or more factors specific to the physical, economic, cultural or social identity of you as a natural person.

3. Your Data Controller

Our products and services are provided through local operating entities that are subsidiaries of Samazn Pte Ltd.

You are contracting with one Samazn group company, as follows:

If you reside in Singapore, you are contracting with Samazn Pte Ltd., 6 Shenton Way, #22-08, Oue Downtown, Singapore 068809.

If you reside in Canada or anywhere else in the world, you are contracting with Samazn Canada Ltd., 18 King Street East, Suite 1400, Toronto ON M5C 1C4.

The Company you are contracting with is your Data Controller, and is responsible for the collection, use, disclosure, retention and protection of your personal information in accordance with our global privacy standards, this Privacy Policy, as well as any applicable national laws.

The Company uses encryption to protect your information and store decryption keys in separate systems. We process and retain your personal information on our servers in multiple data center locations, including European Union, Japan, the United Kingdom, the United States of America and elsewhere in the world.

4. How do we protect personal information?

The Company respects the privacy of any users who access its website, and it is therefore committed to taking all reasonable steps to safeguard any existing or prospective clients, applicants and website visitors.

The Company keeps any personal data of its clients and its potential clients in accordance with the applicable privacy and data protection laws and regulations.

We have the necessary and appropriate technical and organisational measures and procedures in place to ensure that your information remains secure at all times. We regularly train and raise awareness for all our employees to the importance of maintaining, safeguarding and respecting your personal information and privacy.

We regard breaches of individuals’ privacy very seriously and will impose appropriate disciplinary measures, including dismissal from employment.

We have also appointed a Privacy Officer, to ensure that our Company manages and processes your personal information in compliance with the applicable privacy and data protection laws and regulations, and in accordance with this Privacy Policy.

The personal information that you provide us with when applying to open an account, applying for a role within Samazn, or when using our website, is classified as registered information, which is protected in several ways.

You can access your registered information after logging in to your account by entering your username and the password that you have selected. It is your responsibility to make sure that your password is only known to you and not disclosed to anyone else.

Registered information is securely stored in a safe location, and only authorised personnel have access to it via a username and password.

All personal information is transferred to Samazn over a secure connection, and thus all reasonable measures are taken to prevent unauthorised parties from viewing any such information.

Personal information provided to the Company that does not classify as registered information is also kept in a safe environment and accessible by authorised personnel only through username and password.

5. Information we may collect about you

In order to open an account with us, you must first complete and submit a “create account” form to us by completing the required information.

By completing this form, you are requested to disclose personal information in order to enable Samazn to assess your application and comply with the relevant laws (including their regulations).

The information that we collect from you is as follows:

Information we collect about you automatically:

Browser Information – Information that is automatically collected via analytics systems providers from your browser, including your IP address and/or domain name and any external page that referred you to us, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system, and platform.

Log Information – Information that is generated by your use of the Services that is automatically collected and stored in our server logs.

This may include, but is not limited to, device-specific information, location information, system activity and any internal and external information related to pages that you visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our website or app.

This includes date and time; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.

Information we receive about you from other sources:

We obtain information about you in a number of ways through your use of our Services, including through any of our websites, the account opening process, webinar sign-up forms, event subscribing, news and updates subscribing, and from information provided in the course of on-going support service communications.

We also receive information about you from third parties such as your payment providers and through publicly available sources.

For example:

6. Lawful basis for processing your personal information

We will process your personal information on the following bases and for the following purposes:

Performance of a contract

We process personal data in order to provide our services and products, as well as information regarding our products and services based on the contractual relationship with our clients (i.e., so as to perform our contractual obligations).

In addition, the processing of personal data takes place to enable the completion of our client on-boarding process.

In view of the above, we must verify your identity in order to accept you as our client and we will use your personal data in order to effectively manage your trading account with us.

This may include third parties carrying out credit or identity checks on our behalf.

The use of your personal information is necessary for us to know who you are, as we have a legal obligation to comply with “Know Your Customer” and customer due diligence regulatory obligations.

7. Disclosure of your personal information

The Company will not disclose any of its clients’ confidential information to a third party, except:

Samazn will endeavour to make such disclosures on a “need-to-know” basis, unless otherwise instructed by a regulatory authority.

Under such circumstances, Samazn will notify the third party regarding the confidential nature of any such information.

As part of using your personal information for the purposes set out above, Samazn may disclose your personal information to the following:

If the Company discloses your personal information to service providers and business partners, in order to perform the services requested by clients, such providers and partners may store your personal information within their own systems in order to comply with their legal and other obligations.

We require that service providers and business partners who process personal information acknowledge the confidentiality of this information, undertake to respect any client’s right to privacy and comply with all relevant privacy and data protection laws and this Privacy Policy.

8. Where we store your personal data

Our operations are supported by a network of computers, servers, and other infrastructure and information technology, including, but not limited to, third-party service providers.

We and our third-party service providers and business partners store and process your personal data in the European Union, Japan, the United Kingdom, the United States of America and elsewhere in the world.

9. Transfers of personal information outside of the European Economic Area (EEA) and the United Kingdom (UK)

We may transfer your personal information outside the EEA and UK to other Samazn affiliates and subsidiaries, service providers and business partners (i.e., Data Processors) who are engaged on our behalf.

To the extent that we transfer your personal information outside of the EEA and UK, we will ensure that the transfer is lawful and that Data Processors in third countries are obliged to comply with the European Union (EU) General Data Protection Act 2016 and the UK Data Protection Act 2018.

If transfers of personal information are processed in the US, we may in some cases rely on standard contractual clauses.

10. Transfers of Personal Information outside of your country

By using our products and services, you consent to your Personal Data being transferred to other countries, including countries that have differing levels of privacy and data protection laws than your country.

In all such transfers, we will protect your personal information as described in this Privacy Policy and ensure that appropriate information sharing contractual agreements are in place.

11. Privacy when using digital assets and blockchains

Your funding of Crypto Assets may be recorded on a public blockchain.

Public blockchains are distributed ledgers, intended to immutably record transactions across wide networks of computer systems.

Many blockchains are open to forensic analysis which can lead to deanonymization and the unintentional revelation of private financial information, especially when blockchain data is combined with other data.

Because blockchains are decentralized or third-party networks which are not controlled or operated by Samazn or its affiliates, we are not able to erase, modify or alter personal data from such networks.

12. Data Retention

Safeguarding the privacy of your personal information is of utmost importance to us, whether you interact with us personally, by phone, by email, over the internet or any other electronic medium.

We will hold personal information, for as long as we have a business relationship with you, in secure computer storage facilities, and we take the necessary measures to protect the personal information we hold from misuse, loss, unauthorised access, modification or disclosure.

When we consider that personal information is no longer necessary for the purpose for which it was collected, we will remove any details that will identify you or we will securely destroy the records.

However, we may need to maintain records for a significant period of time (after you cease being our client).

For example, we are subject to certain anti-money laundering and securities laws which require us to retain Personal Data for set periods of time.

Also, the personal information we hold in the form of recorded information, by telephone, electronically or otherwise, will be held in line with local regulatory requirements.

If you have opted out of receiving marketing communications, we will hold your details on our suppression list so that we know you do not want to receive these communications.

17. Contact Information

Any questions, complaints, comments, and requests regarding this Privacy Policy are welcome and should be addressed to:

support@Samazn.com

18. Data Protection Authorities

If you are not satisfied with our response to your complaint, you have the right to submit a complaint with our regulator.

You can contact the appropriate regulator directly from the details below:

For residents of Singapore:

Personal Data Protection Commission

10 Pasir Panjang Road
#03-01 Mapletree Business City
Singapore 117438

For residents of Canada:

Office of the Privacy Commissioner of Canada

30, Victoria Street
Gatineau, QC K1A 1H3, Canada

For residents of Australia:

Office of the Australian Privacy Commissioner

GPO Box 5218,
Sydney, NSW 2001, Australia

For residents of the United Kingdom:

The Information Commissioner’s Office

Wycliffe House, Water Ln
Wilmslow SK9 5AF, UK

For residents of Europe:

Irish Data Protection Commission

21 Fitzwilliam Square South
Dublin 2D02 RD28
Ireland

For residents of Japan:

Personal Information Protection Commission

Kasumigaseki Common Gate West Tower 32nd Floor,
3-2-1, Kasumigaseki, Chiyoda-ku,
Tokyo, 100-0013, Japan