Last updated: March 15, 2019
As used herein, the following terms are defined as follows:
DINNGO: DINNGO Pte Ltd., with its registered address at 100 Tras Street #16-01, Singapore 079027.
Service(s): Any services made available through DINNGO-branded websites, applications or tools operated by DINNGO.
We/Us/Our: DINNGO Pte Ltd.
Personal Information/Personal Data/your data: Any information relating to an identified or identifiable natural person, such as 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 that natural person.
3. HOW DINNGO COLLECTS INFORMATION ABOUT YOU
When you use the Services, we collect information sent to us through your computer, mobile phone, or other access devices. This information may include your IP address and device information, including, but not limited to, identifier, device name and type, operating system, location, mobile network information, and standard web log information, such as your browser type, traffic to and from our site, and the pages you accessed on our website.
DINNGO does not direct its websites, mobile app, API, or any of the Services to children. DINNGO does not intentionally collect information from children. If we become aware that we have inadvertently received personal information from a user under the age of 21 (or any lower age pursuant to applicable law), we will delete such information from our records.
If you create an account or use the Services, we, or our affiliates or vendors acting on our behalf, may collect the following types of information:
Personal Identification Information: Full name, date of birth, age, nationality, gender, signature, utility bills, photographs, phone number and/or resident address.
Account information: email address and/or password.
Formal Identification Information: ID number, passport number, driver's license details, national identity card details, photograph identification cards, your selfie along with the above mentioned ID documents, and/or visa information.
Financial Information: Bank account information, payment card primary account number (PAN), transaction history, trading data, source of fund, image of bank statement or similar information, withdraw address, and/or tax identification.
Transaction Information: Information about the transactions you make on our Services, such as the name of the recipient, your name, the amount, and/or timestamp.
Employment Information: Office location, job title, and/or description of role.
Geo-location Information: real-time location based information from your device at any time while you download or use our services. We may use this information to optimize your experience.
Online Identifiers: Login information, operating system/platform, browser fingerprint, time zone setting, OS, browser name and version, and/or personal IP addresses.
Usage Data: Survey responses, information provided to our support team, public social networking posts, authentication data, security questions, user ID, click-stream data and other data collected via cookies and/or similar technologies. By using our services, you agree to our use of these methods as set forth in our .
If you seek permission to raise the buy and sell limits associated with your DINNGO account, we may require you to provide additional information which we may use in collaboration with service providers acting on our behalf to verify your identity or address, and/or to manage risk. This information may include your date of birth, taxpayer or government identification number, a copy of your government-issued identification, or other personal information. We may also obtain information about you from third parties such as credit bureaus and identity verification services.
Finally, we may collect additional information that may be disclosed to our customer success team.
5. HOW DINNGO PROTECTS AND STORES PERSONAL INFORMATION
We store and process your personal and transactional information, including certain payment information, where DINNGO facilities or our service providers are located, and we protect it by maintaining physical, electronic, and procedural safeguards in compliance with applicable laws. We employ safeguards such as firewalls and data encryption, physical access controls to our buildings and files, and restricted access to personal information only for those employees who require it to fulfill their job responsibilities.
We store your personal information securely throughout the life of your DINNGO account. DINNGO will retain your personal information for a minimum of five years or as necessary to comply with our legal obligations or to resolve disputes.
6. HOW DINNGO USES THE PERSONAL INFORMATION WE COLLECT
Our primary purpose in collecting personal information is to provide you with a secure, smooth, efficient, and customized experience. We may use your personal information to:
provide the Services and requested customer support;
process transactions and send notices about your transactions;
resolve disputes, collect fees, and troubleshoot problems;
prevent and investigate potentially prohibited or illegal activities, and/or violations of our posted user terms;
customize, measure, and improve DINNGO Services and the content and layout of our website and applications;
deliver targeted marketing, service update notices, and promotional offers based on your communication preferences; and
verify your identity by comparing your personal information against third-party databases.
We will not use your personal information for purposes other than those purposes we have disclosed to you, without your consent. From time to time we may request your consent to allow us to share your personal information with third parties. You may opt out of having your personal information shared with third parties, or from allowing us to use your personal information for any purpose that is incompatible with the purposes for which we originally collected it or subsequently obtained your authorization. If you choose to so limit the use of your personal information, certain features of the Services may not be available to you.
We will never sell or rent your personal information to third parties.
Any communications we send to you will either be related to your account or will be related to DINNGO services or products. In the event DINNGO sends any communication to you which is not related specifically to your account, DINNGO will provide you with an "unsubscribe" mechanism through which you may opt out of receiving other similar messages in the future.
7. HOW PERSONAL INFORMATION IS SHARED
If you use your DINNGO account to transfer digital currency in connection with the purchase or sale of goods or services, we or you may also provide the seller with your shipping address, name, and/or email to help complete your transaction with the seller. The seller is not allowed to use this information to market their services to you unless you have given prior consent. If an attempt to transfer digital currency to your seller fails or is later invalidated, we may also provide your seller with details of the unsuccessful transfer. To facilitate dispute resolutions, we may provide a buyer with the seller's address so that goods can be returned to the seller.
In connection with a digital currency transfer between you and a third party, including merchants, a third party may share information about you with us, such as your email address or mobile phone number which may be used to inform you that a transfer has been sent to or received from the third party. We may use this information in connection with such transfers to confirm that you are a DINNGO customer, that digital currency transfers are enabled, and/or to notify you that you have received digital currency. If you request that we validate your status as a DINNGO customer with a third party, we will do so. You may also choose to send digital currency to or request digital currency from an email address. In such cases, your username will be displayed in an email message notifying the user of the designated email address of your action. Please note that merchants you interact with may have their own privacy policies, and DINNGO is not responsible for their operations, including, but not limited to, their information practices.
If you authorize one or more third-party applications to access your DINNGO account, then the information you have provided to DINNGO may be shared with those third parties. Unless you provide further authorization, these third parties are not allowed to use this information for any purpose other than to facilitate your transactions made during your use of the Services.
We may also share information with others in an aggregated or otherwise anonymized form that does not reasonably identify you directly as an individual.
Due to the inherent transparency of blockchains, balance and transaction history of any public digital asset may be publicly accessible. This includes, but not limited to, your public sending address, the public address of the receiver, the amount sent or received, and any other data you have chosen to include in a given transaction. Transactions and addresses may reveal information about your identity and information. Information stored on a blockchain may be public, immutable, and difficult or even impossible to be removed or deleted. Because blockchains are decentralized or third-party networks which are not controlled or operated by us or our affiliates, we are not able to erase, modify, or alter personal information from such networks.
8. HOW DINNGO SHARES PERSONAL INFORMATION WITH OTHER PARTIES
We may share your personal information with the following parties for the following reasons.
8.1. Third-party identity verification services
This allows DINNGO to confirm your identity by comparing the information you provide us to public records and other third-party databases. These service providers may create derivative data based on your personal information that can be used solely in connection with provision of identity verification and fraud prevention services.
8.2. Various service providers
These service providers are those under contract to help with parts of our business operations, such as bill collection, marketing, and technology services. Our contracts require these service providers to only use your information in connection with the services they perform for us, and prohibit them from selling your information to anyone else.
8.3. Partner Financial Institutions
These institutions are those with a bank account and routing numbers associated with your DINNGO account.
8.4. Prospective M&A Partners
8.5. Law enforcement, government officials, or other third parties
We may be required to disclose personal information if and when compelled to do so by a subpoena, court order, or similar legal procedure.
We may also make disclosures of personal information if we believe in good faith that the disclosure of personal information is necessary to prevent physical harm or financial loss, to report suspected illegal activity, or to investigate violations of our terms and conditions of use.
Before DINNGO shares your information with any third party, DINNGO will, to the extent permitted by applicable laws, rules, or regulations, enter into a written agreement requiring that the third party to provide at least the same level of privacy protection as required hereunder.
If you establish a DINNGO account indirectly on a third-party website or via a third-party application, any information that you enter on that website or application (and not directly on a DINNGO website) will be shared with the owner of the third-party website or application and your information may be subject to their privacy policies.
In general, we will notify you of material changes to this policy by updating the last updated date at the top of this page, and we will provide you with explicit notice of material changes as required by law. We recommend that you visit this page frequently to check for changes.
9. SPECIFIC CONSENT BY USERS IN SINGAPORE
If you are located in, or a resident of, Singapore, you specifically and voluntarily consent to the transfer of your personal information to our related entity and service providers in USA and/or the UK, for the specific purposes of performing identity verification or checking, to enable us to prevent fraud and comply with our legal obligations.
You may revoke your consent to this section at any time by emailing firstname.lastname@example.org with the subject line "Revoke Singapore data consent".
10. RIGHT TO ERASURE OF PERSONAL INFORMATION
You are entitled to the right to obtain the erasure of your personal information without undue delay in certain circumstances, such as where the personal information is no longer necessary in relation to the purposes for which it was collected or processed.
Should you wish to obtain the erasure of your personal information, please email email@example.com with the subject line "Erasure of Personal Information".
11. RIGHT TO ERASURE OF PERSONAL INFORMATION
You may opt out of any future contacts from us at any time. You can do so at any time by contacting us at firstname.lastname@example.org.
12. RIGHT TO ERASURE OF PERSONAL INFORMATION
If you have questions or concerns regarding this policy, or if you have a complaint, you should first contact us on our support page, by emailing to email@example.com.
13. EEA USERS & DATA
If you are a resident of the EEA, DINNGO is the data controller with respect to your personal data. As data controller, we determine the means and purposes of processing data in relation to cryptocurrency transactions.
13.1. OUR LAWFUL BASIS FOR PROCESSING PERSONAL DATA
Under EEA Data Protection Law, we are required to described our lawful basis for processing your personal data. We will only use your personal data where we have a legal ground to do so. We determine the legal grounds based on the purposes for which we have collected and used your personal data. In every case, the legal ground will be one of the following:
It is necessary to process your personal data in order to fulfill the contract we have with you, such as to provide you with access to DINNGO websites and to enable you to use the Services.
We process certain of your personal data on the basis of our legitimate interests where it is necessary in pursuit of our business interests. For example, we will rely on our legitimate interest to carry out marketing analysis to determine what services may be relevant to the interests of our users.
LEGAL AND REGULATORY OBLIGATIONS
In some cases, we obtain, collect and process your personal data to comply with a legal obligation, such as to respond to a court order or a regulator.
We process your personal data on the basis where you have provided your consent for specific purpose, such as receiving marketing emails from us.
13.2. DIRECT MARKETING
We deliver marketing communications only by electronic means (email or SMS). Where required by law, we will ask you to explicitly opt in to receive marketing from us. If we send you a marketing communication it will include instructions on how to opt out of receiving these communications in the future. Honoring your marketing preferences is important to us. You have the right to opt out of receiving direct marketing and targeted online advertising. Where we send marketing emails, we provide unsubscribe options for your use within our emails. To update your email marketing preferences, please visit the applicable email preference center, a link to which will normally be included in emails you receive from us.
13.3. INDIVIDUAL RIGHTS
Under applicable data protection laws, EEA residents have the rights set out below, which can be exercised by contacting us at firstname.lastname@example.org. Please note that these rights are not absolute and are subject to certain exemptions under applicable data protection law.
13.3.1. Right to withdraw consent.
You have the right to withdraw any consent you have previously given us to the processing of your personal data. If you withdraw your consent, this will not affect the lawfulness of DINNGO's processing of your personal data prior to the withdrawal of your consent
13.3.2. Right to access
You have the right to request for details of your personal data and a copy of that personal data. The provision of this information is subject to some fee associated with gathering of the information (as permitted by law), unless such provision adversely affects the rights and freedoms of others.
13.3.3. Right to rectification
You have the right to have any inaccurate personal data about you corrected or removed.
13.3.4. Right to erasure ('right to be forgotten')
In below circumstances, you have the right to have your personal data erased:
Your personal data is no longer necessary in relation to the purposes for which it was collected or otherwise processed.
Your personal data was collected in relation to processing that you previously consented, but later withdraw such consent.
Your personal data was collected in relation to processing activities to which you object, and there are no overriding legitimate grounds for our processing.
If we have made your personal data public and are obliged to erase the personal data, we will, taking account of available technology and the cost of implementation, take reasonable steps, including technical measures, to inform other parties that are processing your personal data that you have requested the erasure of any links to, or copy or replication of your personal data. The above is subject to limitations by relevant data protection laws.
13.3.5. Right to data portability
In case the processing is based on a contract with you or based on your consent, or the processing is carried out by automated means, you may request to receive your personal data in a structured, commonly used and machine-readable format and you may request us to transmit your personal data directly to another controller where this is technically feasible.
13.3.6. Right to restriction of processing
You have the right to restrict how your personal data is used in certain circumstances including if you contest the accuracy of your personal data that we processed or that our use of your personal data is unlawful. Where applicable, you also have the right to object to us processing your personal data for certain purposes.
13.3.7. Right to object to processing
Where we reply on consent, contract or legitimate interests to process your data, you may object, at any time, to the processing of your personal data. We will refrain from processing your personal data unless we can demonstrate an overriding legitimate grounds to continue the processing.
13.3.8. Right related to automated individual decision-making and profiling
You have the right not to be subject to a decision based solely on automated processing of your personal data, including profiling, which produces legal effects concerning you or similarly significantly affects you. You can object to your personal data being used in this way.
13.3.9. Right to lodge a complaint
In the event that you are not content with how we manage your personal data, we encourage you to contact us first at email@example.com so that we can try to resolve the issue or dispute informally. You also have the right to lodge a complaint with the data protection supervisory authority located in the EU jurisdiction where you reside. In the UK, the supervisory authority is the UK Information Commissioner's Office (ICO).
13.4. PERIOD FOR WHICH THE PERSONAL DATA WILL BE STORED
We will process and store your personal data only for the period necessary to achieve the purpose of storage, or as far as this is granted by European legislator or any applicable laws to which the controller is subject to.
13.5. CONTACT US
If you have any questions about how we use your personal data or if you have any concern about how your personal data is used, please email our Data Protection Officer at firstname.lastname@example.org.