2MR GLOBAL LLC

PRIVACY POLICY

Last updated: 2 7 November 2023

 

We recognise our responsibilities in relation to the collection, holding, processing, use and/or transfer of personal data. Your privacy is of utmost importance to us.

 

This policy (this Policy ) outlines how we collect, use, store and disclose your personal data. Please take a moment to read about how we collect, use and/or disclose your personal data so that you know and understand the purposes for which we may collect, use and/or disclose your personal data. By accessing the website at marketplace.giantsplanet.com and any sub-domains (the Website ), you agree and consent to 2MR Global LLC (Company No. 3282 LLC 2023), a limited liability company incorporated under the laws of St. Vincent and the Grenadines (the Company ), its related corporations, business units and affiliates, as well as their respective representatives and/or agents (collectively referred to herein as we, us or our ), collecting, using, disclosing and sharing amongst themselves the personal data, and to disclosing such personal data to relevant third party providers. This Policy supplements but does not supersede nor replace any other consent which you may have previously provided to us nor does it affect any rights that we may have at law in connection with the collection, use and/or disclosure of your personal data. We may from time to time update this Policy to ensure that this Policy is consistent with our future developments, industry trends and/or any changes in legal or regulatory requirements. Subject to your rights at law, the prevailing terms of this Policy shall apply. For the avoidance of doubt, this Policy forms part of the terms and conditions governing your relationship with us and should be read in conjunction with such terms and conditions.

 

The security of your personal data is important to us. At each stage of data collection, use and disclosure, we have in place physical, electronic, administrative and procedural safeguards to protect the personal data stored with us. However, do note that no transmission of personal data over the internet can be guaranteed to be 100% secure – accordingly and despite our efforts, we cannot guarantee or warrant the security of any information you transmit to us, or to or from our online services. We shall not have any responsibility or liability for the security of information transmitted via the internet.

 

This Policy describes how we may collect, use, disclose, process and manage your personal data, and applies to any individual’s personal data which is in our possession or under our control.

 

  1. What personal data is collected by us

 

"Personal data" means data, whether true or not, about an individual who can be identified   ( i ) from that data, or (ii) from that data and other information to which the organisation has or is likely to have access.

 

Some examples of personal data that we may collect are:

(a) personal particulars (e.g. legal name, alias(es), nationality and domicile, gender, residential address, date of birth, or identity card / birth certificate / passport / driver's licence details);

(b) e-mail address, account username, account password;

(c)   financial details (e.g. income, wealth, source of funds/wealth and bank information);

(d) information or details regarding digital assets held;

(e) particulars of digital wallet addresses (including transactions performed by said digital wallet addresses), public cryptographic key relating to digital wallet addresses on distributed ledger networks and/or similar information;

(f)    information about your use of our services and Website, and specific user interactions with the Website such as features utilised, areas visited or clicked on, and time spent;

(g) usernames and password, third party account credentials (such as your Facebook login credentials, Google login credentials), Internet Protocol (IP) address, and geographical location;

(h) browser type and version, operating system used by the accessing system, internet service provider of the accessing system, the website from which an accessing system reaches our website (i.e. "referrers"), mobile device ID, location of access, or other similar data and information;

(i)     behaviour such as pages (and sub-page) visited, time and date of your visit, time spent on each page, and other diagnostic data; and/or

(j)     personal opinions made known to us (e.g. feedback or responses to surveys).

 

Personal data will be collected when you interact with our services, access the Website, or participate in any token offering.

 

To the extent permitted by law, we may also obtain other information about you such as contact information, change of address or demographic information from commercially available sources.

 

  1. Purposes for c ollection, use and disclosure of your personal data

 

We may collect, use and/or disclose your personal data for its legitimate interests or business purposes, including operations for these purposes. These may include, without limitation, the following:

 

(a) developing, providing and improving our products and services (whether made available by us or through us) or your participation in interactive features of our services, including without limitation:

 

(i)     provision of landing page for token offerings available for participation, and providing information regarding such offerings from the project owner;

(ii)   services for purchasing, trading and/or holding of digital assets, in particular for digital assets which are issued as ERC-1155 tokens ;

(iii) acting as intermediaries between you and the project owner for token offerings, including arranging or facilitating payments to either party;

(iv)                performing KYC (Know Your Customer) data, perform AML (Anti-Money Laundering) and other compliance background checks on users;

(v)   recording and/or encryption on any blockchain, network or platform;

(vi)                promoting advertisements or marketing material, whether from us or third parties;

(vii)               various products and/or services (whether digital or not, and whether provided through an external service provider or otherwise);

(viii)             any escrow, courier, anti-counterfeiting, cyber-security or dispute resolution services;

(ix)                transactions and clearing or reporting on these transactions; and/or

(x)   research, planning, analytics, trouble-shooting, technical maintenance and bug fixes;

 

(b) communicating with you, including providing you with updates on changes to services or products (whether made available by us or through us) including any additions, expansions, suspensions and replacements of or to such services or products and their terms and conditions;

 

(c)   complying with all applicable laws, regulations, rules, directives, orders, instructions and requests from any local or foreign authorities, including regulatory, governmental, tax and law enforcement authorities or other authorities;

 

(d) financial reporting, regulatory reporting, management reporting, risk management (including monitoring credit exposures, preventing, detecting and investigating crime, including fraud and any form of financial crime), audit and record keeping purposes; and/or

 

(e) seeking professional advice, including legal or tax advice.

 

We may also use personal data for purposes set out in the terms and conditions that govern our relationship with you or our customer.

 

  1. eKYC

 

For certain product offerings, we may engage and authorise certain third party service providers of electronic know-your-client ( eKYC ) services for identity verification, processing of identity documentation, collection of due diligence documentation, and/or transaction monitoring.

Under these arrangements, personal data may be provided to such eKYC service providers through the submission of information, forms, documents or media files (in whatever format) through an upload to online platforms operated by such eKYC service providers. The eKYC process may be automated, semi-automated or performed by a human.

The result of the eKYC process as well as all personal data provided to eKYC service providers will be made available solely to us and will not be shared with any other external parties. All eKYC service providers shall be required to ensure that the eKYC solution is secure and robust to protect personal data from unauthorised access, use and disclosure at all times.

 

  1. Use of personal data for marketing purposes

 

We may use your personal data to offer you products or services, including special offers, promotions, contests or entitlements that may be of interest to you or for which you may be eligible. Such marketing messages may be sent to you in various modes including but not limited to electronic mail, direct mailers, short message service, telephone calls, facsimile and other mobile messaging services, and may be sent directly by us or by various third parties which we work with. In doing so, the sender will comply with all applicable data protection and privacy laws.

 

In respect of sending telemarketing messages to your telephone number via short message service, telephone calls, facsimile and other mobile messaging services, please be assured that we shall only do so if we have your clear and unambiguous consent in writing or other recorded form to do so or if you have not otherwise made the appropriate registration of that number with the Do Not Call Registry. If we have an ongoing relationship with you and you have not indicated to us that you do not wish to receive telemarketing messages sent to your telephone number, we may send you telemarketing messages to that number related to the subject of our ongoing relationship via short message service, facsimile and other mobile messaging services (other than a voice or video call).

 

You may at any time request that we stop contacting you for marketing purposes via selected or all modes.

 

To find out more on how you can change the way we use your personal data for marketing purposes, please contact us.

 

Nothing in this Policy shall vary or supersede the terms and conditions that govern our relationship with you.

 

 

  1. Disclosure and sharing of personal data

 

We may from time to time and in compliance with all applicable laws on data privacy, disclose your personal data to any of our personnel, staff, employees, officers, group entities, or to third parties (including without limitation banks, financial institutions, credit card companies, credit bureaus and their respective service providers, companies providing services relating to insurance and/or reinsurance to us, and associations of insurance companies, agents, contractors or third party service providers who provide services to us such as telecommunications, information technology, payment, data processing, storage and archival, and our professional advisers such as our auditors and lawyers, and regulators and authorities), located in any jurisdiction, in order to carry out the purposes set out above (including without limitation the provision of our services, or as required by any law). Please be assured that when we disclose your personal data to such parties, we will disclose only the personal information that is necessary to deliver the service required, and will also require them to ensure that any personal data disclosed to them are kept confidential and secure.

 

For more information about the third parties with whom we share your personal data, you may, where appropriate, wish to refer to the agreement(s) and/or terms and conditions that govern our relationship with you or our customer. You may also contact us for more information (please see section 11 below).

We wish to emphasise that we do not sell personal data to any third parties without your explicit consent, and we shall remain fully compliant of any duty or obligation of confidentiality imposed on us under the applicable agreement(s) and/or terms and conditions that govern our relationship with you or our customer or any applicable law.

 

You are responsible for ensuring that the personal data you provide to us is accurate, complete, and not misleading and that such personal data is kept up to date. You acknowledge that failure on your part to do so may result in our inability to provide you with the products and services you have requested. To update your personal data, please contact us (please see section 11 below for contact details). Where you provide us with personal data concerning individuals other than yourself, you are responsible for obtaining all legally required consents from the concerned individuals and you shall retain proof of such consent(s), such proof to be provided to us upon our request.

 

We may transfer, store, process and/or deal with your personal data in any jurisdiction, and accordingly such personal data may be transferred to computers, servers or hardware located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those in your jurisdiction. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Policy and no transfer of your personal data will take place to an organisation or a country unless there are adequate controls in place including the security of your data and other personal information (including without limitation the Standard Contractual Clauses approved by the European Commission). Your consent to this Policy followed by your submission of such information represents your agreement to the transfer of personal data as described herein.

 

  1. Cookies and related technologies

 

The Website uses cookies. A cookie is a small text file placed on your computer or mobile device when you visit a Website or use an app, which may include an anonymous unique identifier. Cookies collect information about users and their visit to the Website or use of the app, such as their Internet protocol (IP) address, how they arrived at the Website (for example, through a search engine or a link from another Website), how they navigate within the Website or app, browser information, computer or device type, operating system, internet service provider, website usage, referring/exit pages, platform type, date/time stamp, number of clicks, ads viewed, and how they use our services. We use cookies and other technologies to facilitate your internet sessions and use of our apps, offer you customised products and/or services according to your preferred settings, display features and services which might be of interest to you (including ads on our services), track usage of our websites and apps, to compile statistics about activities carried out on our websites, and to hold certain information. Examples of cookies which we use include, without limitation, Sign-in and Authentication Cookies for user authentication, Session Cookies to operate our service, Preference Cookies to remember your preferences and various settings, Third-Party Cookies from third party services to receive and incorporate external data, as well as Security Cookies for security purposes.

 

You may set up your web browser to block cookies from monitoring your website visit. You may also remove cookies stored from your computer or mobile device. However, if you do block cookies you may not be able to use certain features and functions of our Website.

 

Our systems do not fully recognise “do not track” signals or other mechanisms that might enable users to opt out of tracking on the Website.

 

  1. Other web sites

 

Our websites may contain links to other websites which are not maintained by us. This Policy only applies to websites maintained by us. When visiting these third party websites, you should read their privacy policies which will apply to your use of such websites.

 

  1. Retention of personal data

 

Your personal data is retained as long as the purpose for which it was collected remains and until it is no longer necessary for any legal or business purposes. This enables us to comply with legal and regulatory requirements or use it where we need to for our legitimate purposes, such as transfers of digital assets, and dealing with any disputes or concerns that may arise.

 

We may need to retain information for a longer period where we need the information to comply with regulatory or legal requirements or where we may need it for our legitimate purposes (e.g. to help us respond to queries or complaints, fighting fraud and financial crime, responding to requests from regulators etc).

 

When we no longer need to use personal data, we will remove it from our systems and records and/or take steps to anonymise it so that you can no longer be identified from it.

 

  1. Queries , Access/Correction Requests and Withdrawal of Consent

 

If you:

 

(a) have queries about our data protection processes and practices;

 

(b) wish to request access to and/or make corrections to your personal data in our possession or under our control; or

 

(c)   wish to withdraw your consent to our collection, use or disclosure of your personal data,

 

please submit a written request (with supporting documents, (if any) to our Data Protection Officer at: admin@2mrglobal.com.   Our Data Protection Officer shall respond to you within 30 days of your submission. Please note that if you withdraw your consent to any or all use or disclosure of your personal data, depending on the nature of your request, we may not be in a position to continue to provide our services or products to you or administer any contractual relationship in place. Such withdrawal may also result in the termination of any agreement you may have with us. Our legal rights and remedies are expressly reserved in such event.

 

We may charge you a fee for processing your request for access. Such a fee depends on the nature and complexity of your access request. Information on the processing fee will be made available to you.

 

  1. Contact information

 

To contact us on any aspect of this Policy or your personal data or to provide any feedback that you may have, please contact our Data Protection Officer at admin@2mrglobal.com .

 

  1. Governing Law

 

This Policy and your use of the Website shall be governed and construed in accordance with the laws of Singapore, without regard to its conflict of laws principles.

 

  1. Amendments and updates to 2MR Global LLC Privacy Policy

 

We reserve the right to amend this Policy from time to time to ensure that this Policy is consistent with any developments to the way we use your personal data or any changes to the laws and regulations applicable to us. We will make available the updated Policy on the Website. When this Policy is updated, we will post a notice on the Website and also change the "Last Updated" date indicated at the top. You are encouraged to visit the Website from time to time to ensure that you are well informed of our latest policies in relation to personal data protection. All communications, transactions and dealings with us shall be subject to the latest version of this Policy in force at the time.

 

  1. Your acceptance of these terms

 

This Policy applies in conjunction with any other notices, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your personal data by us. We may revise this Policy from time to time without any prior notice. You may determine if any such revision has taken place by referring to the date on which this Policy was last updated.

 

By using the Website and/or any services provided by us, you signify your acceptance of this Policy and terms of service. If you do not agree to this Policy or terms of service, please do not use the Website or any services provided by us. Your continued use of the Website following the posting of changes to this Policy will be deemed your acceptance of those changes.