Block Technologies Privacy Notice
Last updated: September 30, 2024
Please note that this privacy notice will regularly be updated to reflect any changes in the way we handle your personal data or any changes in applicable laws.
This Privacy Notice describes how Block Technologies (“we”,“us”, “our”, “ourselves”) collects and processes your personal information (“you”, “your”) through the Block Technologies websites and applications that reference this Privacy Notice. By using the services provided by Block Technologies (“Block Technologies Services”), you are consenting to the collection, storage, processing, and transfer of your personal information as described in this Privacy Notice.
Block Technologies Pte. Ltd. a company registered under the number 202126753E, at 20 COLLYER QUAY, #13-00, 20 COLLYER QUAY, SINGAPORE 049319 is a data processor for personal information collected and processed in connection with the provision of the Block Technologies Services.
1. What personal information does Block Technologies collect? Why does Block Technologies process my personal information? What is the legal basis for the processing activities?
“Personal Data” means data, whether true or not, about a customer 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, such as when you engage with our websites (e.g. device information, IP address).
Personal Data Provided to Us
When we refer to “Personal Data provided to us”, this means any information that you provide to us about yourself. This information is either required by law (e.g., to verify your identity and comply with “Know Your Business” obligations), necessary to provide the requested Services (e.g., you will need to provide your contact details in order to open your account), or is relevant for certain specified purposes, described in greater detail below.
Failure in providing the data required implies that Block Technologies will not be able to offer you our Services.
Personal Data collected automatically from you:
In some cases we may collect Personal Data automatically from you, to the extent permitted under the applicable law, we may collect certain types of Personal Data automatically, for example whenever you interact with us or use the Services, when we process your usage data of the platform and when we review your browsing information. This information helps us address customer support issues, improve the performance of our sites and Services, maintain and or improve your user experience, and protect your account from fraud by detecting unauthorized access.
Sensitive Data
The term “sensitive data” refers to the various categories of personal data identified by data privacy laws or regulations as requiring special treatment, including in some circumstances the need to obtain explicit consent from you. These categories include racial or ethnic origin, political opinions, religious, philosophical or other similar beliefs, membership of a trade union, physical or mental health, biometric or generic data, sexual life or orientation, or criminal convictions and offences (including information about suspected criminal activities).
Due to the type of services provided we might need to process certain types of sensitive data. In the limited cases where we do collect such data, we will do this in accordance with data privacy laws and regulations and/or ask for your consent.
| What information and personal data does Block Technologies collect and process? | Why does Block Technologies process my personal information? | Legal Basis for our use of personal information |
|---|---|---|
| Information related to company Directors, UBOs and Authorised persons, including: - Email address - Name - Gender - Date of birth - Home address - Phone number - Nationality - Device ID - A video recording | - Communicate with you: We use your personal information to communicate with you in relation to Block Technologies Services. - We collect and process identity information and Sensitive Personal Data (as detailed in section 1) to comply with our Know Your Customer (“KYC”) obligations under applicable laws and regulations, and Anti-Money Laundering laws and regulations | Performance of a contract when we provide you with products or services or communicate with you about them. This includes when we use your personal information to take and handle orders, and process payments. |
| - The Internet protocol (IP) address used to connect your computer to the Internet - Login, e-mail address, password and location of your device or computer - Block Technologies metrics (e.g., the occurrences of technical errors, your interactions with service features and content, and your settings preferences) - Version and time zone settings | - Provide, troubleshoot, and improve Block Technologies Services : We use your personal information to provide functionality, analyze performance, fix errors, and improve the usability and effectiveness of Block Technologies Services | Our legitimate interests to ensure the proper functioning of our business operations. Legal requirements that we need to comply with concerning identifying customers, preventing fraud and/or abuse and avoiding non-compliance. |
| - Transaction history - Information from other sources: we may receive information about you from other sources, such as credit history information from credit bureaus | Fraud prevention and credit risks. We process personal information to prevent and detect fraud and abuse in order to protect the security of our users, Block Technologies Services and others. We may also use scoring methods to assess and manage credit risks. | Our legitimate interests and the interests of our users when, for example, we detect and prevent fraud and abuse in order to protect the security of our users, ourselves, or others. |
We firmly believe that where the above table states that we rely on our legitimate interests for a given purpose, this is not overridden by your interests, rights or freedoms. Therefore, If you wish to obtain further information on this balancing test approach, please contact dpo@blockcustody.com.
We will not use your Personal Data for purposes that are incompatible with the purposes of which you have been informed, unless it is required or authorized by law, or it is in your own vital interest (for example, in case of a medical emergency) to do so.
2. Does Block Technologies share My Personal Information?
Information about our users is an important part of our business and we are not in the business of selling our users' personal information to others. Block Technologies shares users' Personal Data and Sensitive Personal Data for the Block Technologies services only as described below and with the subsidiaries or affiliates of Block Technologies that are either subject to this Privacy Notice or follow practices at least as protective as those described in this Privacy Notice.
Affiliates: Personal data that we process and collect may be transferred between companies, Services, and employees affiliated with us (collectively, our “Affiliates”) as a normal part of conducting business and offering our Services.
Third party service providers: We employ other companies and individuals to perform functions on our behalf. Examples include analyzing data, providing marketing assistance, processing payments, transmitting content, assessing and managing credit risk, and performing identity verification and other KYC functions. These third-party service providers have access to Personal Data and Sensitive Personal Data needed to perform their functions, but may not use it for other purposes. Further, they must process the personal information in accordance with this Privacy Notice and as only permitted by applicable data protection laws.
Business transfers: As we continue to develop our business, we might sell or buy other businesses or services. In such transactions, user information generally is one of the transferred business assets but remains subject to the promises made in any pre-existing Privacy Notice . Also, in the unlikely event that Block Technologies or substantially all of its assets are acquired, user information will be one of the transferred assets.
Legal Authorities: We may be required by law or by Court to disclose certain information which might cover Personal Data or any engagement we may have to relevant regulatory, law enforcement and/or other competent authorities. We will disclose Personal Data to legal authorities to the extent we are obliged to do so according to the law. We may also need to disclose Personal Data in order to enforce or apply our legal rights or to prevent fraud.
Protection of Block Technologies and others: We release accounts and other Personal Data when we believe such release is appropriate to comply with the law or with our regulatory obligations; enforce or apply our Terms of Use and other agreements; or protect the rights, property or safety of Block Technologies, our users or others. This includes exchanging information with other companies and organizations for fraud protection and credit risk reduction, and with regulatory agencies and law enforcement to comply with lawful requests.
3. International Transfers of Personal Data
To facilitate our global operations, we may transfer to, store and process Personal Data within our Affiliates, third-party partners, and service providers based throughout the world.
Your Personal Data may be transferred from the country, state and city ( “Home Country”) in which you are present while using our Services to another country, state and city (“Alternate Country”).
When we transfer your Personal Data from your Home Country to the Alternate Country, we will comply with our legal and regulatory obligations in relation to your Personal Data, including having a lawful basis for transferring Personal Data and putting appropriate safeguards in place to ensure an adequate level of protection for the Personal Data. We will also ensure that the recipient in Alternate Country is obliged to protect your Personal Data at a standard of protection comparable to the protection under Singapore laws.
Our lawful basis will be either consent (i.e. we may ask for your consent to transfer your Personal Data from your Home Country to the Alternate Country at the time you provide your Personal Data) or one of that which is prescribed by relevant laws.
4. How Secure is My Information?
We design our systems with your security and privacy in mind. We work to protect the security of your personal information during transmission by using encryption protocols and software.
We maintain physical, electronic and procedural safeguards in connection with the collection, storage and disclosure of your personal information. Our security procedures mean that we may ask you to verify your identity before we disclose personal information to you. We hold ISO 27001 and ISO 27701 certifications, which demonstrate our commitment to managing information security in accordance with best practices.
It is important for you to protect against unauthorized access to your account password. We recommend using a unique password for your Block Technologies account that is not utilized for other online accounts. Be sure to sign off when you finish using a shared computer.
5. How Long Does Block Technologies Keep My Personal Information?
We keep your Personal Data to enable your continued use of Block Technologies Services, for as long as it is required in order to fulfill the relevant purposes described in this Privacy Notice as may be required by law such as for tax and accounting purposes, compliance with Anti-Money Laundering laws, or to resolve disputes and/or legal claims or as otherwise communicated to you.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.
6. What Rights Do I Have?
Subject to applicable law, as outlined below, you have a number of rights in relation to your privacy and the protection of your Personal Data. If you want to exercise any of your rights please contact at dpo@blockcustody.com. These rights may be limited in some situations - for example, where we can demonstrate we have a legal requirement to process your personal information.
- Right to access: you have the right to obtain a copy of the Personal Data that we hold about you as well as certain information related to its processing;
- Right to correct: you can request the rectification of your Personal Data which are inaccurate, and also add to it. You can also change your Personal Data in your account at any time.
- Right to withdraw your consent: You have the right to withdraw your consent and request us to stop collecting, using or and/or disclosing your personal data for any or all of the purposes listed above at any time. Exercising this right does not affect the lawfulness of the processing based on the consent given before the withdrawal of the latter. Please note that we will respond to such withdrawal request within ten (10) business days;
We will respond to a request (1) 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; and (2) to correct or update any of your personal data which we hold about you, as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days after receiving your request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to your request. If we are unable to provide you with any personal data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the applicable laws).
If you have any questions or objections as to how we collect and process your Personal Data, please contact dpo@blockcustody.com. To comply with your request, we may ask you to verify your identity.
When you consent to our processing your personal information for a specified purpose, you may withdraw your consent at any time and we will stop any further processing of your data for that purpose.
If you have any questions or objections as to how we collect and process your personal information, please contact dpo@blockcustody.com. Where we act as a processor, you should contact the data controller, your service provider, to exercise any of your rights.
7. Contact Information
Our data protection officer can be contacted at dpo@blockcustody.com, and will work to address any questions or issues that you have with respect to the collection and processing of your personal information.
8. Conditions of Use, Notices and Revisions
If you choose to use Block Technologies Services, your use and any dispute over privacy is subject to this Privacy Notice and our Terms of Use. If you have any concerns about privacy at Block Technologies, please contact us with a thorough description, and we will try to resolve it. You also have the right to contact your local Data Protection Authority.
Our business changes constantly, and our Privacy Notice will change also. You should check our websites frequently to see recent changes. If you do not agree with the revised content, you shall stop accessing Block Technologies Services immediately. When an updated version of the Privacy Notice is released, your continued access to Block Technologies Services means that you agree to the updated content and agree to abide by the updated Privacy Notice. Unless stated otherwise, our current Privacy Notice applies to all information that we have about you and your account.