2022.05.20

CTOMORROW PTE.LTD. , d/b/a OPick (“OPick,” “we” or “us” or “our”) is committed to protecting your privacy. We have prepared this Privacy Policy to describe to you our practices regarding the Personal Information (as defined below) we collect, why we collect it, and how we use and disclose it.

Your privacy matters to us, so please do take the time to get to know and familiarize yourself with our policies and practices. Please understand that we reserve the right to change any of our policies and practices at any time, but you can always find the latest version of this Privacy Policy here on this page.

1. I. Personal Information We Collect

   As used herein, “Personal Information” means information that identifies or is reasonably capable of identifying an individual, directly or indirectly, and information that is capable of being associated with an identified or reasonably identifiable individual.

   1. Personal Information we collect from you

      We may collect the following categories of Personal Information directly from you

      1. Identification Information such as name, email, phone number, postal address;
      2. Commercial Activity such as trading activity, order activity, deposits, withdrawals, account balances;
      3. Correspondence such as information you provide to us in correspondence, including account opening and customer support; and
      4. Sensory Information such as images that you upload to your User Profile;

   2. Personal Information we collect automatically

      We may collect the following categories of Personal Information automatically through your use of our services:

      1. Online Identifiers such as IP address, domain name;
      2. Device Information such as hardware, operating system, browser;
      3. Usage Data such as system activity, internal and external information related to Nifty Gateway pages that you visit, clickstream information; and
      4. Geolocation Data.

      Our automatic collection of Personal Information may involve the use of Cookies, described in greater detail below.

   3. Personal Information we collect from third parties

      We may collect and/or verify the following categories of Personal Information about you from third parties, including service providers and our affiliates:

      1. Identification Information such as name, email, phone number, postal address
      2. Transaction Information such as public blockchain data (bitcoin, ether, and other Digital Assets are not truly anonymous. We, and any others who can match your public Digital Asset address to other Personal Information about you, may be able to identify you from a blockchain transaction because, in some circumstances, Personal Information published on a blockchain (such as your Digital Asset address and IP address) can be correlated with Personal Information that we and others may have. Furthermore, by using data analysis techniques on a given blockchain, it may be possible to identify other Personal Information about you);
      3. Financial Information such as bank account information, routing number, credit card number, debit card number; and
      4. Additional Information at our discretion to comply with legal obligations.

   4. Accuracy and retention of Personal Information

      We take reasonable and practicable steps to ensure that your Personal Information held by us is (i) accurate with regard to the purposes for which it is to be used, and (ii) not kept longer than is necessary for the fulfillment of the purpose for which it is to be used.

2. II. How We Use Your Personal Information

   We collect Personal Information about you in an attempt to provide you with the best experience possible, protect you from risks related to improper use and fraud, and help us maintain and improve our Services. We may use your Personal Information to:

   1. Provide you with our Services. We use your Personal Information to provide you with our Services pursuant to the terms of our Terms of Use. For example, in order to facilitate fiat transfers out of your account, we need to know your financial information.
   2. Comply with legal and regulatory requirements. We process your Personal Information as required by applicable laws and regulations.
   3. Detect and prevent fraud. We process your Personal Information to detect and prevent fraud on your account, which is especially important given the irreversible nature of cryptocurrency transactions.
   4. Protect the security and integrity of our Services. We use your Personal Information, including information about your device and your activity on OPick to maintain the security of your account and the OPick platform.
   5. Provide you with customer support. We process your Personal Information when you contact our support team with questions about or issues with your account.
   6. Market our products. We may contact you with information about our Services. We will only do so with your permission, which can be revoked at any time.
   7. Other business purposes. We may use your Personal Information for additional purposes if that purpose is disclosed to you before we collect the information or if we obtain your consent.

3. III. How We Share Your Personal Information

   We will not share your Personal Information with third parties, except as described below:

   1. Service Providers. We may share your Personal Information with third-party service providers for business or commercial purposes, including fraud detection and prevention, security threat detection, payment processing, customer support, data analytics, Information Technology, advertising and marketing, network infrastructure, storage, transaction monitoring. We share your Personal Information with these service providers only so that they can provide us with the services, and we prohibit our service providers from using or disclosing your Personal Information for any other purpose.
      1. You authorize us to collect and share with our payments provider CTOMORROW PTE. LTD , your Personal Information including full name, email address and financial information, and you are responsible for the accuracy and completeness of that data.
      2. OPick Artists. In some circumstances, OPick may share your contact information with OPick Artists to facilitate the delivery of Additional Items under the Terms of Use.
   2. Affiliates. We may share Personal Information about you with our affiliates in the ordinary course of business and offering our Services to you.
   3. Law Enforcement. We may be compelled to share your Personal Information with law enforcement, government officials, and regulators.
   4. Corporate Transactions. We may disclose Personal Information in the event of a proposed or consummated merger, acquisition, reorganization, asset sale, or similar corporate transaction, or in the event of a bankruptcy or dissolution.
   5. Professional Advisors. We may share your Personal Information with our professional advisors, including legal, accounting, or other consulting services for purposes of audits or to comply with our legal obligations.
   6. Consent. We may share your Personal Information with your consent.

   If we decide to modify the purpose for which your Personal Information is collected and used, we will amend this Privacy Policy.

4. IV. Cookies

   When you access OPick, we may make use of the standard practice of placing tiny data files called cookies, flash cookies, pixel tags, or other tracking tools (herein, “Cookies”) on your computer or other devices used to visit OPick. We use Cookies to help us recognize you as a customer, collect information about your use of OPick to better customize our services and content for you, and collect information about your computer or other access devices to: (i) ensure that your account security has not been compromised by detecting irregular, suspicious, or potentially fraudulent account activities; (ii) assess and improve our services and advertising campaigns

   You also can learn more about cookies by visiting http://www.allaboutcookies.org, which includes additional useful information on cookies and how to block cookies on different types of browsers and mobile devices. Please note that if you reject cookies, you will not be able to use some or all of OPick. If you do not consent to the placing of Cookies on your device, please do not visit, access, or use OPick.

5. V. Direct Marketing

   Subject to applicable laws and regulations, we may from time to time send direct marketing materials promoting services, products, facilities, or activities to you using information collected from or about you. You may also opt-out of such communications by following the directions provided in any marketing communication. It is our policy to not provide your Personal Information for those third parties’ direct marketing purposes without your consent.

6. VI. Information Security

   No security is foolproof, and the Internet is an insecure medium. We cannot guarantee absolute security, but we work hard to protect OPick and you from unauthorized access to or unauthorized alteration, disclosure, or destruction of Personal Information we collect and store. Measures we take include encryption of the OPick website communications with SSL; optional two-factor authentication; periodic review of our Personal Information collection, storage, and processing practices; and restricted access to your Personal Information on a need-to-know basis for our employees, contractors and agents who are subject to strict contractual confidentiality obligations and may be disciplined or terminated if they fail to meet these obligations.