BY SUBMITTING YOUR INFORMATION, SIGNING UP AND USING OUR PRODUCTS AND/OR OTHER CONFIRMATION, YOU ARE CONFIRMING THAT YOU ARE BOUND BY THIS PRIVACY POLICY. BY USING OUR PRODUCTS OR BY OTHERWISE GIVING US YOUR INFORMATION, YOU WILL BE DEEMED TO HAVE READ, UNDERSTOOD AND AGREED TO THE PRACTICES AND POLICIES OUTLINED IN THIS PRIVACY POLICY AND YOU HEREBY CONSENT TO OUR COLLECTION, USE AND DISCLOSURE OF YOUR INFORMATION AS DESCRIBED IN THIS PRIVACY POLICY. WE RESERVE THE RIGHT TO CHANGE, MODIFY, ADD OR DELETE PORTIONS OF THE TERMS OF THIS PRIVACY POLICY, AT OUR SOLE DISCRETION, AT ANY TIME.

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IF YOU DO NOT AGREE WITH THIS PRIVACY POLICY AT ANY TIME, DO NOT USE ANY OF OUR PRODUCTS OR GIVE US ANY OF YOUR INFORMATION. IF YOU DO NOT PROVIDE US WITH SOME OR ALL OF THE INFORMATION REQUESTED OR WITHDRAW YOUR CONSENT TO US COLLECTING AND USING YOUR PERSONAL DATA AND INFORMATION, YOU MAY NOT BE ABLE TO USE OUR PRODUCTS.

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IF YOU USE OUR PRODUCTS ON BEHALF OF SOMEONE ELSE (SUCH AS YOUR CHILD) OR AN ENTITY (SUCH AS YOUR EMPLOYER), YOU REPRESENT THAT YOU ARE AUTHORISED BY SUCH INDIVIDUAL OR ENTITY TO (I) ACCEPT THIS PRIVACY POLICY ON SUCH INDIVIDUAL’S OR ENTITY’S BEHALF, AND (II) CONSENT ON BEHALF OF SUCH INDIVIDUAL OR ENTITY TO OUR COLLECTION, USE AND DISCLOSURE OF SUCH INDIVIDUAL’S OR ENTITY’S INFORMATION AS DESCRIBED IN THIS PRIVACY POLICY.

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Changing Our Privacy Policy

We regularly review our privacy practices and may update them from time to time. Any change, update, or modification will be effective immediately upon posting on our Products. We will notify you of any material change to this Privacy Policy either by notifying you on the Products or through email. Be sure to return to this page periodically to ensure familiarity with our most current version with the effective date located at the bottom of this Policy. By continuing to use our Products, you accept the terms of this Policy and any updates as of the date of your visit or use.

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Introduction

Company (“Company,” “us,” “we,” or “our”) is a decentralized finance product.

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Purpose

By using our Products, you’re acknowledging you have agreed to our Terms of Service and that you have read and understood this Privacy Policy and our Cookie Policy.

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This Privacy Policy is governed by and shall be construed by the laws of the Republic of Singapore and compliance with the Personal Data Protection Act (2012) of Singapore (the “PDPA”).

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Any dispute arising out of or in connection with this Privacy Policy shall be subject to the exclusive jurisdiction of the Singapore International Arbitration Centre in Singapore, following its rules in force.

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What Information This Privacy Policy Covers

This Privacy Policy covers information we collect from you through our Products. Some of our Products’ functionality can be used without revealing any Personal Data, though for certain features, Personal Data is required. If you do not use these specific features, then the only information we collect will be “Non-Personal Information” (i.e., information that cannot be used to identify you). Non-Personal Information includes information such as the web pages that you have viewed. To access certain features and benefits of our Products, you may need to submit “Personal Data” (i.e., information that can be used to identify you). Personal Data can include information such as your name and email address, among other things. Any collection, use and disclosure of your Personal Data require your express consent. By providing any information to us through the use of our Products, you agree to expressly consent to the collection, use and disclosure of your Personal Data according to this Privacy Policy. You are responsible for ensuring the accuracy of the Personal Data you submit. Inaccurate information may affect your ability to use the Products, the information you receive when using the Products, and our ability to contact you. For example, your email address should be kept current because that is one of the primary manners in which we communicate with you.

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What You Consent To By Using Our Products

Please understand that by submitting any Personal Data to us, you consent and agree that we may collect, use and disclose such Personal Data following this Privacy Policy and our Terms of Service, and as permitted or required by law. If you do not agree with these terms, then please do not provide any Personal Data to us. If you refuse or withdraw your consent, or if you choose not to provide us with any required Personal Data, you may not be able to to access certain Products.

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What Information We And Our Partners Collect

This information collected from you may constitute Personal Data under the PDPA. “Personal Data” is defined under the PDPA to mean any data, whether true or not, about an individual who can be identified from that data or from that data and other information to which an organization has or is likely to have access. This would include, without limitation, information such as name, address, telephone number, e-mail address, credit card details and any other personal information.

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The company and its partners will be free to use, collect and disclose freely available information in the public domain without your consent. Information that is business contact information such as your name, position name or title, business telephone number, business address, business electronic mail address or business fax number and any other similar information about you, which are not provided by you for personal purposes, will not be regarded as Personal Data under the PDPA. Your consent to us collecting, using and disclosing any business contact information will not be required. Information you voluntarily provide to us through our Products shall be deemed to be collected with your permission. Such information may include any Personal Data or other information necessary for the use of Products.

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For you to fully utilize the Products, you will need to create a user profile. Our Products provide users with many different functionalities and need to collect and process certain information from you to do the same. We may collect the following:

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Information you provide by completing forms, including but not limited to, your name, email and postal addresses, telephone number, country of residence, login, and password details. This information may be requested for the use of our Products;

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Information you provide for identity verification purposes, including but not limited to, your legal name, country of residence, business name and Tax ID for business entities, and date of birth;

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Details of any transactions from the use of the Products. We may partner with third parties for certain aspects of our platform, including payments, and the information provided to such third parties is collected and used following their privacy policies;

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Information about your interaction and use of our Products, including use of our mobile apps (such as your IP address, the type of device or browser you use, and your actions on the Products);

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Information about how our community members visit and interact with our Products through traffic analytics. You can always opt out of being included. For more information about our use of data analytics, see our Cookie Policy;

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Communications you send to us (for example, when you ask questions or provide comments, or report a problem);

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Information that you submit on or to our forums in the form of comments, discussions, or messages to other users; and

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The email address associated with your Facebook or Google accounts, if you choose to sign up using your related credentials. The company will also request permission to access your name, profile picture, and friends list (these permissions are governed by the related company’s privacy policies and can be managed through your privacy settings). We never post anything to third-party accounts without your permission.

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You are free to provide as much or as little information to us as you would like. However, the level of information you provide may affect your ability to utilize our Products

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We gather two types of information about users through our Products:

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Non-Personal Information

When you use our Products, we may track, collect and aggregate Non-Personal Information indicating, among other things, which pages were visited, the order in which they were visited, when they were visited, and which hyperlinks were “clicked.” We also collect information from the URLs from which you linked to our Products. Collecting such information may involve logging the IP address, operating system and browser software used by each user of the Products. Although such information is not Personal Data, we may be able to determine from an IP address a user’s internet service provider and the geographic location of his or her point of connectivity.

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We also use or may use cookies and/or web beacons to help us determine and identify repeat visitors, the type of content and sites to which a user of our Products links, the length of time each user spends at any particular area of our Products, and the specific functionalities that users choose to use. Essentially, cookies are a user’s identification card for our servers. Web beacons are small graphic files linked to the servers that allow us to track your use of our Products and related functionalities. Cookies and web beacons allow us to serve you better and more efficiently, and to personalize your experience. Cookies and web beacons are not used to retain Personal Data. From time to time we may also use additional typical methods of collecting data. Please see our Cookie Policy for additional details.

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You should be able to control how and whether cookies will be accepted by your web browser. If you reject our cookies, many functions and conveniences of our Products may not work properly.

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Personal Data

We collect Personal Data that you provide to us when you register for an account, update or change information to your account, utilize the Products, sign-up for email updates, participate in our public forums, and send us email messages. We may use the Personal Data that you provide to respond to your questions, provide you with the specific Products you select, send you updates or other events, and send you email messages about Product maintenance or updates. The Company will be the controller of your Personal Data.

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Personal Data that may be collected from you may include, but is not limited to, the following:

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Account Registration: If you register for an account on our Products, you may be required to provide us with Personal Data such as your name, email address, telephone number, passport or identification number or any other information required to register an account or utilize our Products.

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Use of Products: We may receive your Data, including computer/device and connection information, IP address, cookies, usage history, bandwidth, and statistics on page views when you use our Products.

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Communications with Us: We may receive Personal Data when voluntarily provided when you send us an email message or otherwise contact us.

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Third-Party Services: We may receive Personal Data when you access or login into a third-party site, e.g., Facebook, from our Products. This may include the text and/or images of your Data available from the third-party site.

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Third-Party Payment Processing: We may provide you with the ability to pay for Products with a credit card or other form of payment through a third-party payment processing service provider. Please note that these service providers – not us – collect and process your information.

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How We Use The Information

Non-Personal Information

We use Non-Personal Information to build higher quality, more useful Products by performing statistical analyses of the collective characteristics and behaviour of our users, and by measuring demographics and interests regarding our Products. We may also use it for other legitimate business purposes.

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Personal Data

Except as outlined in this Privacy Policy or as specifically agreed to by you, we will not disclose any Personal Data we gather from you. In addition to the other uses outlined in this Privacy Policy, we may disclose and otherwise use Personal Data as described below. We may also use it for research and other legitimate business purposes, including improving and customizing the Products. In any event, the use of your data will be governed by what a reasonable person would consider appropriate under the circumstances.

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Identity Verification: For services that require identity verification, we use the Personal Data that we collect for verifying your identity, and for authenticating that submissions made on the Products were made by you. This includes due diligence checks following applicable laws including Know Your Client, Anti-money Laundering and Countering the Financing of Terrorism policies.

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Communications with Us: When you send us an email message or otherwise contact us, we may use the information provided by you to respond to your communication and/or as described in this Privacy Policy. We may also archive this information and/or use it for future communications with you.

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Communications with Third Parties: We may share your Data with third parties and business partners so that they may share information about their products and services that may be of interest to you upon obtaining your express consent for such disclosure.

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We may share your information with certain trusted third-party services to help us provide, improve, promote, or protect our Products (like when we partner with payment processors). When we share data with third-party services that support the delivery of our Products, we require that they use your information only for the purposes we’ve authorized and that they protect your Data at least to the same standards we do. We may also share information that’s aggregated and anonymized in a way that doesn’t directly identify you.

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Disclosure to Operations and Maintenance Contractors: We use various service providers, vendors and contractors (collectively, “Contractors”) to assist us in providing our products and Services to you. Our Contractors may have limited access to your Data in the course of providing their products or services to us so that we in turn can provide our products and Services to you. These Contractors may include vendors and suppliers that provide us with technology, services, and/or content related to the operation and maintenance of the Site. Access to your Data by these Contractors is limited to the information reasonably necessary for the contractor to perform its limited function for us.

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Government Authorities, Legal Rights and Actions: We may share your Personal Data with various government authorities in response to subpoenas, court orders, or other legal processes; to establish or exercise our legal rights or to protect our property; to defend against legal claims; or as otherwise required by law. In such cases, we reserve the right to raise or waive any legal objection or right available to us. We also may share your Data when we believe it is appropriate to investigate, prevent, or take action regarding illegal or suspected illegal activities; to protect and defend the rights, property, or safety of the Company, the Products, our Users, customers, or others; and in connection with our Terms of Service and other agreements.

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Disclosure to Acquirers: We may disclose and/or transfer your Personal Data to an acquirer, assignee or other successor entity in connection with a sale, merger, or reorganization of all or substantially all of the equity, business or assets of the Company to which your Personal Data relates.

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We shall not collect, use or disclose your Data unless:

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We shall not, as a condition to using our Products, require consent to such collection, use or disclosure beyond what is reasonable to achieve such purpose. We shall not obtain or attempt to obtain your consent for collecting, using or disclosing Personal Data by providing false or misleading information concerning the collection, use or disclosure of your Personal Data, or using deceptive or misleading practices.

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External Links

For your convenience, we may provide links to sites operated by other organizations (“Third Party Services”) that we believe may be of interest to you. We do not disclose your Data to these Third Party Services without obtaining your consent. We do not endorse and are not responsible for the privacy practices of these Third Party Services. If you choose to click on a link to one of these Third Party Services, you should review the privacy policy posted on the other site to understand how that Third Party Services collects and uses your Personal Data.

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Confidentiality & Security Of Personal Data

We consider the confidentiality and security of your information to be of the utmost importance. We will use industry standard physical, technical and administrative security measures to keep your Data confidential and secure and will not share it with third parties, except as otherwise provided in this Privacy Policy, or unless we have good faith belief that such disclosure is necessary in special cases, such as a physical threat to you or others. Because the Internet is not a 100% secure environment we cannot guarantee the security of Personal Data, and there is some risk that an unauthorized third party may find a way to circumvent our security systems or that transmission of your information over the Internet will be intercepted. It is your responsibility to protect the security of your login information. Please note that e-mails and other communications you send to us through our Products are not encrypted.

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Data Transfers

Because of the global nature of our Products and to provide better service we may transfer, store, and process information about Users, including Personal Data, on servers and equipment, and with service providers based all over the world, like Singapore, the United States or Canada, for the purposes described and following this Policy.

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These data transfers are necessary to provide the services outlined in our Terms of Service and to globally operate and provide our Products to you.

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The data we hold may also be processed by employees operating around the world who work for us or our partners and service providers. This staff may be engaged in, among other things:

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the processing of transactions and your payment details and;

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the provision of support services.

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When we transfer your Personal Data internationally we will take reasonable steps to ensure that your Personal Data is treated securely, lawfully and in the manner we describe here. Please note that laws vary from jurisdiction to jurisdiction, and so the privacy laws applicable to the places where your information is transferred to or stored, used or processed, may be different from the privacy laws applicable to the place where you are resident. We will always ensure that appropriate safeguards are in place to ensure an adequate level of data protection.

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For residents of countries and jurisdictions outside of Singapore who are using or accessing our Products operated and managed on servers located and operated within Singapore, you agree and consent to the transfer to and processing of personal information on servers located in Singapore, and that the protection of such information may be different than required under the laws of your residence or location.

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Where your Personal Data is to be transferred out of Singapore, we will comply with the PDPA in doing so. This includes obtaining consent from you to transfer your Personal Data overseas, and before you give consent, providing you with a reasonable written summary on the extent of the protection offered to the Personal Data to be transferred overseas, and/or taking appropriate steps to ascertain that the foreign recipient organization of the Personal Data is bound by legally enforceable obligations to provide to the transferred Personal Data a standard of protection that is at least comparable to the protection under the PDPA.

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Retention

We will retain your information as long as your account is active, as necessary to use our Products or as otherwise outlined in this Policy. We will also retain and use this information as necessary for the purposes set out in this Policy and to the extent necessary to comply with our legal obligations, resolve disputes, enforce our agreements and protect our legal rights.

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We also collect and maintain aggregated, anonymized or pseudonymized information which we may retain indefinitely to protect the safety and security of our Products, improve our Products or comply with legal obligations.

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Updating Or Deleting Your Data

You can access your Personal Data and confirm that it remains correct and up-to-date or choose whether or not you wish to receive material from us or some of our partners by logging into the Products and visiting your user account page. You may also contact us via admin@singularity.network. We try to answer every email promptly, but may not always be able to do so. Keep in mind, however, that there will be residual information that will remain within our databases, access logs and other records, which may or may not contain your Data.

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If you have any privacy-related questions, unresolved problems, or complaints you may contact us via admin@singularity.network.

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Notifications And Communication

We want to communicate with you only if you want to hear from us. We try to keep emails to a minimum and give you the ability to opt-in to any marketing communications we send.

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We will send you emails relating to your transactions on the Products. You may also elect to receive certain marketing email communications, following your preferences, from which you may opt out at any time.

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We’ll also send you service-related announcements when it’s necessary to do so.

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European Union And GDPR

Data protection law in Europe requires a “lawful basis” for collecting and retaining Personal Data from citizens or residents of the European Economic Area. Our lawful bases include:

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Performing the contract we have with you: In certain circumstances, we need your Personal Data to comply with our contractual obligation to deliver the Products.

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Legal compliance: Sometimes the law says we need to collect and use your Data. For example, tax laws require us to retain records of transactions made through our Products.

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Legitimate interests: This is a technical term in data protection law which essentially means we have a good and fair reason to use your data and we do so in ways that do not hurt your interests and rights. We sometimes require your data to pursue our legitimate interests in a way that might reasonably be expected as part of running our business and that does not materially impact your rights, freedom or interests.

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Children

We strongly believe in protecting the privacy of children and no one under 18 (or the legal age in your jurisdiction) is allowed to use our Products without parental consent. In line with this belief, we do not knowingly collect or maintain Personal Data on our Products from persons under 18 years of age (or the legal age in your jurisdiction), and no part of our Products is directed to persons under 18 years of age (or the legal age in your jurisdiction). If you are under 18 years of age (or the legal age in your jurisdiction), please do not use or access our Products at any time or in any manner. We will take appropriate steps to delete any Personal Data of persons less than 18 years of age (or the legal age in your jurisdiction) that has been collected on our Products without verified parental consent upon learning of the existence of such Personal Data.

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Your Rights

Right to Access. You have the right to obtain confirmation from us as to whether or not we have processed your Personal Data and, access to the Personal Data and information including the details of the purposes of the processing, the categories of Personal Data concerned and the recipients of the Personal Data. We will, at your request, endeavour to provide you with a copy of your Data in our possession or control within a reasonable period.

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We may charge you a reasonable fee for administrative costs. However, please note that your right to obtain a copy of your Personal Data is subject to the rights and freedoms of others, and we may have to deny your request should your request adversely affect the rights and freedoms of others.

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Right to Rectification: You have the right to have any inaccurate Personal Data about you rectified. In addition, when there are any changes to your Personal Data, we highly encourage you to inform us of any such changes so that we may have an accurate record of your Personal Data.

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Right to Erasure: You have the right to request that we delete or remove your Data where your Personal Data is no longer relevant to the original purposes for processing, where we may have processed your information unlawfully, where you have withdrawn your consent to processing your Personal Data or where we are required to delete or remove your Data under relevant legislation and regulations. However, please note that we may have denied your request where we are legally required to retain your Data for, inter alia, reasons of public interest or for the establishment, exercise or defence of legal claims.

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Right to Restriction of Processing: You have the right to request that we suspend the processing of your Data where you want to establish the accuracy of your Personal Data, where the processing of your Personal Data is unlawful but you do not want us to erase your Personal Data, where we no longer require your Data for the processing but you require us to retain your Data for the establishment, exercise or defence of legal claims or where you have objected to our processing of your Personal Data but we need to verify whether we have an overriding legitimate grounds to use your Data.

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Right to Object: You have the right at any time to object to our processing of your Personal Data because there is something about your particular situation that makes you want to object. In addition, you also have the right to object to the processing of your Personal Data for direct marketing purposes. However, in some instances, we may demonstrate that we have compelling legitimate grounds for processing your Personal Data which may override your objection.

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Right to Data Portability: You have the right to request us to transfer your Data to you or a third party of your choosing, in a structured, commonly used, machine-readable format. This right shall only be applicable where the processing of your Personal Data is carried out by automated means and provided that the request does not affect the rights and freedom of others.

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Right to Lodge a Complaint: You have the right to complain at any time to the relevant supervisory authority. However, the Company endeavours to provide you with the best user experience and therefore would appreciate the opportunity to deal with any concerns you may have before you seek the assistance of such supervisory authority.

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processing your Personal Data. However, the withdrawal of your consent shall not affect the lawfulness of our processing of your Personal Data that was based on your consent before your withdrawal. You may also withdraw your consent for specific forms of communication and on specific communications via the unsubscribe options as stated in our email or other marketing messages.

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Please note that in withdrawing your consent, you acknowledge that we may not be able to provide or continue providing certain Products to you and that we may cease such provisions accordingly without any liability.

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To exercise any of your rights as explained above, kindly send your requests to admin@singularity.network.

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We hope that we can fulfil your requests within 30 days. In cases where we may take longer than 30 days, we will notify you and keep you updated. Notwithstanding the foregoing, you agree and acknowledge that there may be circumstances where we may be unable to accede to your request due to legal or contractual obligations.

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