This article "digital assets" refers to digital assets (i.e., "virtual financial assets", "convertible virtual currency", "digital currency" or "digital products" as referred to in the relevant laws and regulations of Singapore), such as Bitcoin, Ethereum or other computer network based encryption protocols, which may be (i) centralized or decentralized, (ii) closed or open source, and (iii) used as an intermediary for exchange and/or value storage.
As used herein, "personal information" means any information relating to an identified or identifiable natural person, such as a name, identification number, location information, online identifier or a physical, economic, cultural or specific one or multiple factors, or your social identity as a natural person.
III. Information collection
99EX collects, processes and stores personal information through your use of the service or with your consent. These personal data may include contact information, a copy of the identification document you provided or a copy of the identification document available from the public information base, your government identification number and information related to your device or Internet service (like IP address and MAC number).
We collect the information you provide in the 99EX onboarding process, which may be complete, incomplete or abandoned. We collect, use, store and transfer your personal information, which may include the following:
We operate in Singapore and collect, store and process your personal information in accordance with the relevant laws. To learn more about how we protect the information collected by individuals and entities in Singapore, please see the details below.
Full legal name (including previous name and local language name)
Country of citizenship
Passport number, or any government-issued ID number
date of birth
Proof of identity (such as a passport, driver's license or government-issued identification)
Proof of residence
Other personal information or documents required by our compliance team at discretion
Clients of company:
Company legal name (including local legal name)
Full legal name of all beneficial owners, directors and legal representatives
Address (primary place of business and / or other places)
Proof of legal existence
Percentage of ownership of individual/company owners
Contact information of the owner, responsible person and executive management (if applicable)
Identification of the important personal beneficial owner of the institutional client entity (such as passport, driver's license or government-issued identification)
Personal information of the important beneficiary owners of each entity's institutional client entity (for more information on the personal information we collect for individuals, please see the “Personal Clients” section above)
Source of wealth
The estimated amount of bitcoin or other digital assets injected
- Information collection outside Singapore
As mentioned above, we may collect personal information from customers located in Singapore. In order to facilitate our services provided to them, we require permission to transfer information from Singapore to outside the region. If you are an individual in Singapore and you refuse to consent to such a transfer, you will no longer be able to use 99EX and our services. You will be able to withdraw your digital assets; however, all other features will be disabled.
- How we use your personal information
99EX uses personal information to communicate with you and to manage, deliver, improve and personalize your services. 99EX may also generate generic information from personal information we collect and use it for our own purposes. We may also use this information to communicate with you about other products or services offered by 99EX and/or its partners. We will not share your personal information with third parties (other than partners working with 99EX) unless we obtain your permission. Further detailed are provided below.
We may share your personal information with third parties:
(a) If we believe that it is necessary to implement the terms of service to share it;
(b) For compliance with regulation policies of government agencies, including regulatory agencies, law enforcement and/or judicial departments;
(c) third parties that provide services (such as management or technical services) to 99EX;
(d) sales or transfers involving our business or any part thereof.
In addition, we have implemented international standards to prevent money laundering, terrorist financing and trade and economic sanctions, and will implement the final virtual financial asset rules and regulations effectively, which may require us to conduct due diligence on our clients. This process may include cross referencing your personal information with third party information.
- Storage of your personal information
The information we collect from you may be transferred to and stored at destinations outside of Singapore. This information may also be processed by employees outside of Singapore who work for us or our suppliers. In addition to the customers in Singapore, when you submit your personal information, you agree to the above transfer, storage or processing terms. All information you provide to us is stored on our and/or third-party’s cloud security servers.
VII. Review, modify and delete your personal information
You have the right to request a copy of your personal information to determine that the information we have about you is accurate and up-to-date. If there is any inaccuracy in your personal information, you can request to update your information. You may also request that your personal information be removed, but we may deny your request for specific reasons such as compliance or legal purposes. To view, modify and delete your personal information, please email "service inquiry" to email@example.com.
In response to a data access, correction or deletion request, we will verify the identity of the requesting party to ensure that he is legally entitled to make such a request. While our goal is to respond to these requests for free, we reserve the right to charge you a reasonable fee for your repeated or time-consuming requests.
VIII. Marketing Promotion
Customers can choose not to receive such marketing notifications at any time. If you do not wish to receive such notifications, please email us at firstname.lastname@example.org.
You cannot choose not to receive product-related notifications, such as policy/terms updates and operational announcements.
When you visit 99EX, we may place a small amount of data in your browser(cookies). This information can be placed on your computer or other device used to access the 99EX. This information helps us identify you as a customer and collect information about your use of 99EX to better customize our services and improve your experience. We may also use the information we collect to ensure that we comply with our compliance program and that your account security is not negatively influenced by detection of irregular or suspicious account activity.
Most browsers are set to automatically accept cookies. Some cookies will expire when you complete your browsing, while other cookies will remain on your computer or device until they are deleted or expired. You may choose to refuse to use our cookies, but this may affect the functionality of the 99EX service or your user experience.
- Information security
We are committed to protecting 99EX and you from unauthorized access, alteration, disclosure or destruction of personal information collected and stored. We take various measures to ensure information security. We use SSL to encrypt all 99EX communications; all our programs require double authentication; we regularly review our personal information collection, storage and processing methods; we restrict our employees and suppliers to access to the information. They will only be permitted to look up information when it’s necessary and they will act in accordance with the confidentiality obligation required by the contract.
- Contact 99EX on privacy issues or concerns
*If there is any ambiguity in the Chinese and English versions, the English version shall prevail.