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PDPA Disclosures
Last updated: October 18, 2024
COLLECTION OF PERSONAL DATA
By voluntarily providing your name, email address, residential address and any other personal information to Gemini Trust Company (Singapore Branch) (UEN: T20FC0045F) or its affiliates (the “Company”) for the purpose of entering into any events, contests, giveaways or lucky draws hosted by the Company, you are deemed to have consented to the collection, use and disclosure of such personal information by the Company. This document explains the type of information that is being collected and stored by the Company and how such information will be used by the Company.
If you have any queries about the policy, please get in touch with the Company via support@gemini.com and the Company will do its best to answer your questions.
1. USE OF YOUR PERSONAL INFORMATION:
1.1 The Company collects, uses, stores and/or processes your personal information for different purposes, including but not limited to:
1.1.1 communicating with you about the results of any event, contest, giveaway or lucky draw, which you have entered or any other information with regard to such events, contests, giveaways or lucky draws;
1.1.2 mailing to your provided address, any items such as prizes or merchandise from the event, contest, giveaway or lucky draw;
1.1.3 providing customer support to you including replying to any query requests and complaints; and
1.1.4 purposes which are reasonably related to the aforementioned.
2. SHARING THIS INFORMATION
2.1 The Company may share your personal information with third parties and its associated organisations for the purpose of providing services to you on the Company’s behalf, including, but not limited to:
2.1.1 service providers under contracts who provide professional services to the Company, such as marketing or technology services;
2.1.2 law enforcement, government officials and agencies, regulators, or other third parties when the Company is compelled to do so by a subpoena, court order, or similar legal procedure, to comply with applicable laws and regulations, to report suspected illegal activity, or to investigate violations of the Company’s terms of use or any other applicable policies; and
2.1.3 organisations assisting the Company with customer service facilities or data storage services.
3. INFORMATION ABOUT OTHER PRODUCTS AND SERVICES
3.1 From time to time the Company may send you information about its updates and product launches that the Company thinks may be of interest to you.
3.3 The Company may also pass your information onto its business partners to enable them to send you information which may be of interest to you but only if you have not opted-out at any time by sending an email to support@gemini.com.
4. CHANGES TO YOUR DETAILS
4.1 The Company aims to keep information about you as accurate as possible. If you would like to review or change the details you have supplied the Company with, you may do so at any time by contacting the Company at support@gemini.com, with the email header “Request to Update Personal Information”.
5. RETENTION OF PERSONAL INFORMATION
5.1 The Company may retain your personal information for as long as it is necessary to fulfill the purpose for which it was collected, or as required or permitted by applicable laws, including for the purpose of satisfying any legal and compliance, accounting, reporting obligations, or dispute resolution.
5.2 The Company will cease to retain your personal information 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 information was collected and is no longer necessary for legal and compliance, or business purposes.
6. TRANSFERRING YOUR INFORMATION OUTSIDE OF SINGAPORE
6.1 The information you provide to the Company may be transferred to countries outside of Singapore. By way of example, this may happen if any of the Company’s servers are located in a country outside of Singapore or one of the Company’s service providers is located in a country outside of Singapore. If the Company transfers your information outside of Singapore in this way, it will take steps to ensure that a similar or higher degree of protection is afforded to the information under the Personal Data Protection Act 2012 of Singapore.
7. YOUR PRIVACY RIGHTS
7.1 You have the following rights in relation to your privacy and protection of personal data:
7.1.1 Right to access your personal information and receive a copy of it;
7.1.2 Right to request the rectification of your personal information which is incorrect, and also make additions to it;
7.1.3 Right to have your personal information deleted;
7.1.4 Right to object to the processing of your personal information for reasons relating to your particular situation;
7.1.5 Right to temporarily restrict the processing of your personal information in certain cases, provided there are valid grounds for doing so; and
7.1.6 Right to withdraw your consent at any time.
These rights may be limited in some situations, such as where the Company can demonstrate that there is a legal requirement to process your personal data, it is necessary for the defense of legal claims, or other exceptions permitted by applicable law. If you have any questions or concerns about the way we collect and process your personal information, please contact support@gemini.com.
8. CONSEQUENCE OF SUSPENSION OR TERMINATION OF YOUR CONSENT TO THE COMPANY’S PRIVACY POLICY:
8.1 If you suspend or terminate your consent to the Company’s usage or processing of your personal information, this will not affect the lawfulness of any processing carried out before you withdrew your consent.