SINPOA LIMITED

For the purposes of the Data Protection Act 1998 (the Act), EPS is a data controller of your personal data, when it provides you with electronic money and payment services or information related to those services and SINPOA is a data controller of your personal data, when it provides you with digital and fiat currency trading services and use of its technology for digital wallet and trading purposes or information related to those services and purposes. A data controller is the person who determines the purposes for which, and the manner in which, any personal data is processed. Data controllers have a responsibility to establish practices and policies in line with the Act.

We are committed to protecting our customers’ privacy. This Privacy Policy explains what personal data we collect and store about our customers and persons visiting the SINPOA website, persons with whom we share the personal data, and how customers or visitors to the SINPOA website can direct us not to share certain personal data with certain persons.Please note that we might amend this Privacy Policy from time to time. Therefore, please check this Privacy Policy for updates.

MEANING OF PERSONAL DATA

Personal data means data that we store electronically, on a computer, or in certain paper filing systems, relating to a living individual who can be identified from that data (or from that data and other non-public personal data in our possession). Personal data can be factual or an opinion.

PERSONAL DATA THAT WE COLLECT

We collect and process the following personal data about you:

• Personal data you provide on applications or other forms or upload to your SINPOA Account, such as name, address, e-mail address, telephone number and “know your client” information;
• Personal data about your transactions with us or other parties, such as account activation, trading account digital wallet balance(s),
• Personal data we receive from third parties in order to verify information that you have provided to us (such as your identity), or to protect our customers, suppliers and correspondents against fraud, such as payment processors, banks, fraud checking agencies, providers of operational services, and regulators; and
• Certain information which we automatically collect when you visit the SINPOA website: technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, and information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouseovers), and methods used to browse away from the page and any phone number used to call our customer service number We may also collect information about how users use our website and you may read about that in the Information SINPOA use of cookies and web storage technology. TELEPHONE CALLS: To make sure we follow your telephone instructions correctly, and to improve our service to you through training our staff or suppliers, we may also monitor and record telephone calls

USE OF YOUR PERSONAL DATA

We will use your personal data in order to process your registration to use the SINPOA trading technology, and open and use the SINPOA Account and to forward to third party suppliers of prepaid payment cards (if applicable), to comply with laws and regulations or good practice with regard to anti-money laundering and similar, and to provide you with our services, including:

• Analysing your registration application
• Carrying out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us;
• Taking steps aimed as fraud detection and prevention;
• Personalising aspects of our overall services for you;
• Communicating with you;
• Learning from the way you use and manage your SINPOA trading account, exchange services and digital wallet services;
• Operating our website (as described above in Information SINPOA use of cookies and web storage technology);
• Resolving disputes with you;
• Administering our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
• In our efforts to keep our site safe and secure;
• Allowing you to participate in interactive features of our service, when you choose to do so;
• Measuring or understanding the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you; We may also use your personal data to send you information about our products and services, or the products or services of third parties, where you have consented to this. You may opt out of this and if you do not wish to receive this information, please update your preferences via the SINPOA website or contact us by one of the methods referred to on the SINPOA website.

DISCLOSURE OF YOUR PERSONAL DATA

We will not disclose your personal data to any third parties except:

• Persons who perform services on our behalf, including those who administer your use of our services or your trading account or your digital wallet or respond to customer inquiries, or who provide marketing services to us;
• Persons from whom we receive or to whom we transfer your funds held in the trading account/digital wallet that we provide to you or when we enable you to buy and sell on our exchange;
• Fraud prevention agencies and other organisations who may use the data to prevent fraud and money laundering;
• To any person to whom we transfer our business or our agreements with you
• As required by law or regulation; • To such persons as you have given your consent for us to do so
• To other SINPOA customers, in the case of your name and contact details, in the event that we establish a customers’ area on our website;
• Third parties in connection with criminal or civil proceedings We may provide your contact details included in your personal data to third parties for the purpose of their informing you about their services. You may opt out of this and if you do not wish us to disclose your personal information to such third parties, please update your preferences via the SINPOA website or contact us by one of the methods referred to on the SINPOA website.

DATA PROTECTION PRINCIPLES

• Processed fairly and lawfully.
• Processed for limited purposes (consistent with those notified to you when we collected your personal data and other purposes permitted under the Act) and in an appropriate way.
• Adequate, relevant and not excessive for the purpose.
• Accurate and up-to-date.
• Not kept longer than necessary for the purpose.
• Processed in line with the rights of the person to whom they relate – please see below.
• Secure, that is that we must take appropriate security measures against unlawful or unauthorised processing of your personal data, and against the accidental loss of, or damage to, your personal data. Please see further below.
• Not transferred to people or organisations situated in countries without adequate protection – please see above.

PERSONAL DATA SECURITY

We restrict access to your personal data not known to the public to our employees who have a need to know such data (e.g., to process your transactions). We train our employees on the importance of customer privacy and confidentiality. We also maintain physical, electronic, and procedural safeguards designed to safeguard the personal data of our customers. We oblige our suppliers who process your data on our behalf to do the same. All information you provide to us is stored on our secure servers. Any payment or cryptocurrency transfers administered by us will be encrypted using SSL technology.

YOUR USER NAME AND PASSWORD

Where we have given you (or where you have chosen) a password which enables you to access certain parts of the SINPOA website, or to use your trading account, digital wallet or our other services, you are responsible for keeping this password confidential. We ask you:

• Not to share a password with anyone. Our representatives will not ask you for your password, so any communication or telephone or other request for your password should be treated with suspicion and reported to us using the methods specified on the SINPOA website;
• If you believe that someone else has obtained access to your password, please also change it as soon as you can by logging into your account and changing your customer details;
• Not to write down your password;
• Not to use a password that could easily be guessed by someone else;
• Log off any website when you have completed your transaction using our services;
• Keep your computer updated with current anti-virus software and the latest browser versions;
• Phishing: Treat emails you receive with caution. You may receive an email claiming to be from either of us or a prepaid payment card issuer introduced by us, or with a link that appears to be to the SINPOA website or the website of such persons, where you are prompted to enter your password or personal details. This email will not come from us or those persons or our partners. We never send emails requesting log-ins, passwords or other security details. If you think you have received a fraudulent email, please forward the entire email to us (including header and footer) and delete it from your computer.

PRIVACY PRACTICES OF THIRD PARTIES

The SINPOA website may feature links to third-party sites. We are not responsible for content or privacy policies or practices of any advertisers or linked sites of any third parties. We encourage you to review their privacy policy before providing them with any personal data. Third party sites may collect and use personal data in a way that is different from set out in this Privacy Policy.