We are dedicated to minimize any data collection and storage thereof to the widest extent possible. Since we are not able to operate with minimal data from you such as identification details, IP address and behavior on our Site, we would like to emphasize that your privacy is important to us and we are committed to protecting your Personal Data where we come across such data of yours. We fully adhere to the PDPA as amended from time to time when you are accessing our website.

1.1. In this Policy the following terms shall have the meaning as described:

“Customer”, “you” or “your” means an individual who (a) has contacted us through any means to find out more about any products or services we provide, or (b) may, or has, entered into an agreement with us for the supply of services or products by us, or (c) connects its wallet with our Site, or (d) has received an invitation code to access our Site; and“PDPA” means Personal Data Protection Act

“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.“Site” means our website under http://www.desat.org

1.2. Depending on the nature of your interaction with us, some examples of Personal Data which we may collect from you include your name and identification information such as your NRIC number, contact information such as your address, email address or telephone number, nationality, gender, date of birth, marital status, photographs and other audio-visual information, employment information and financial information such as credit card numbers, debit card numbers or bank account information.

1.3. Other terms used in this Policy shall have the meanings given to them in the PDPA (where the context so permits).

2.1. We generally do not collect your Personal Data unless (a) it is provided to us voluntarily by you directly or via a third party who has been duly authorised by you to disclose your Personal Data to us (your “authorised representative”) after (i) you (or your authorised representative) have been notified of the purposes for which the data is collected, and (ii) you (or your authorised representative) have provided written consent to the collection and usage of your Personal Data for those purposes, or (b) collection and use of Personal Data without consent is permitted or required by the PDPA or other laws. We shall seek your consent before collecting any additional Personal Data and before using your Personal Data for a purpose which has not been notified to you (except where permitted or authorised by law).

2.2. Please note that as you interact with us via the Site, we automatically collect technical data about your equipment, browsing actions, patterns and wallet addresses (private keys). Such information is collected by using cookies, server logs and other similar technologies. By using the Site, you confirm that we are entitled to collect such data from you.

2.3. We may collect and use your Personal Data for any or all of the following purposes:

2.3.1. performing obligations in the course of or in connection with our provision of the products and/or services requested by you;

2.3.2. verifying your identity;

2.3.3. responding to, handling, and processing queries, requests, applications, complaints, and feedback from you;

2.3.4. managing your relationship with us;

2.3.5. processing payment transactions;

2.3.6. complying with any applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority;

2.3.7. any other purposes for which you have provided the information;

2.3.8. transmitting to any unaffiliated third parties including our third-party service providers and agents, and relevant governmental and/or regulatory authorities, whether in Switzerland or abroad, for the aforementioned purposes; and

2.3.9. any other incidental business purposes related to or in connection with the above.

2.4. We may disclose your Personal Data:

2.4.1 where such disclosure is required for performing obligations in the course of or in connection with our provision of the products or services requested by you; or

2.4.2 to third party service providers, agents and other organisations we have engaged to perform any of the functions listed in clause 1.5 above for us.

2.4.3 The purposes listed in the above clauses may continue to apply even in situations where your relationship with us (for example, pursuant to an agreement) has been terminated or altered in any way, for a reasonable period thereafter (including, where applicable, a period to enable us to enforce our rights under any agreement with you).

3.1. The consent that you provide for the collection, use and disclosure of your Personal Data will remain valid until such time it is being withdrawn by you in writing. You may withdraw consent and request us to stop using and/or disclosing your Personal Data for any or all of the purposes listed above by submitting your request in writing or via email to our Data Protection Officer at the contact details provided below.

3.2. Upon receipt of your written request to withdraw your consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us. In general, we shall seek to process your request within twenty (20) business days of receiving it.

3.3. Whilst we respect your decision to withdraw your consent, please note that depending on the nature and scope of your request, we may not be in a position to continue providing our products or services to you and we shall, in such circumstances, notify you before completing the processing of your request. Should you decide to cancel your withdrawal of consent, please inform us in writing in the manner described in clause 3.1 above.

3.4. Please note that withdrawing consent does not affect our right to continue to collect, use and disclose Personal Data where such collection, use and disclose without consent is permitted or required under applicable laws.

4.1. If you wish to make (a) an access request 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, or (b) a correction request to correct or update any of your Personal Data which we hold about you, you may submit your request in writing or via email to our Data Protection Officer at the contact details provided below.

4.2. Please note that a reasonable fee may be charged for an access request. If so, we will inform you of the fee before processing your request.

4.3. We will respond to your request 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 PDPA).

5.1. To safeguard your Personal Data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, we have introduced appropriate administrative, physical and technical measures such as up-to-date antivirus protection, encryption and the use of privacy filters to secure all storage and transmission of Personal Data by us, and disclosing Personal Data both internally and to our authorised third party service providers and agents only on a need-to-know basis.

5.2. You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.

5.3. Please note that we have no power over third-party applications and plug-ins that collect your Personal Data.

6.1. We generally rely on Personal Data provided by you (or your authorised representative). In order to ensure that your Personal Data is current, complete and accurate, please update us if there are changes to your Personal Data by informing our Data Protection Officer in writing or via email at the contact details provided below.

7.2. 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.

8.1. We generally do not transfer your Personal Data to countries outside of Switzerland. However, if we do so, we will obtain your consent for the transfer to be made and we will take steps to ensure that your Personal Data continues to receive a standard of protection that is at least comparable to that provided under the PDPA.

8.3 This Site uses functions of the web analysis service Google Analytics. The provider of this service is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.

Google Analytics enables us to analyse the behaviour patterns of you while on the Site. To that end, we receive a variety of user data, such as pages accessed, time spent on the page, the utilized operating system and the user’s origin. This data is assigned to the respective end device of the user. An assignment to a user-ID does not take place.

9.1. Our Site includes links to third-party websites. By clicking on such links and visiting the linked websites, you may allow third parties to collect or share data about you. We are not in control of any data you share willingly or unwillingly with such third-party websites and recommend you to read the third party’s privacy policies to better understand their use of your data.

10.1. You may contact our Data Protection Officer if you have any enquiries or feedback on our Personal Data protection policies and procedures, or if you wish to make any request, under the following email address: dpo@desat.org

11.1. This Policy applies in conjunction with any other notices, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your Personal Data by us.

11.2. We may revise this Policy from time to time without any prior notice. You may determine if any such revision has taken place by referring to the date on which this Notice was last updated. Your continued use of our services constitutes your acknowledgement and acceptance of such changes.