Latest Version: 15 February 2025
This Privacy Policy (“Privacy Policy”) sets out the terms and conditions under which Token195. (“Company”, “Token195”, “we”, “our”, or “us”) collects information via our website www.token195.com (“Website”), our associated mobile application and other applications made available by our Company (collectively Through our Website and App (collectively, “Site”), Token195 provides information on cryptocurrency, utility tokens, digital coins/currency, initial coin offerings that do not amount to an offering of securities or securities-tokens (“ICO”) and other digital currency related information, as well as APIs (including but not limited to the Token195 API), widgets, plugins, extensions, patches, decentralized token swaps, coin purchases, listing of coins, ICO, new exchange listing, and/or events listing (“Activity Post”), features for online subscription, registration of account, registration of interest for any of our services or events, our messaging services, update functions, loyalty rewards program (currently known as “Token195 Rewards” but which may be amended from time to time in our Company’s sole discretion), and/or any other services and products provided by our Company whether by itself or in conjunction with other third parties (individually and collectively, our “Site Services”). As such, this Privacy Policy applies to any person (hereinafter referred to as “you” or “user”) who accesses, reads, participates in, or uses our Website, App and APIs (including any variations, updates, support patches or successors), forums, blogs, any of our Site Services, and/or any charts, rankings, pricing, trading volume, articles, news, press release, analysis, reports, information, write-ups, photographs, pictures, profiles, testimonials, tips, advertisements, media files and other content on our Website, our App, and our Site Services (collectively, “Site Content”), as well as to any person who receives our news updates, news summaries, press release updates, reports, analysis, newsletters, EDMs, marketing materials, promotional updates, support patches, technical updates, new version releases (whether for our APIs or App), messages (via any channels), or other emails (collectively, “Updates”). “Site Content” and “Updates” collectively shall be referred to as “Content”. For the avoidance of doubt, all Content and Site Services pertain only to cryptocurrency, and not any products or instruments that can be classified as “securities” thereunder the Securities and Futures Act (Cap. 289).
In order to serve you better and provide you with the information of interest to you, listing of your Activity Post, functionalities such as decentralized token swaps, appropriate customer service or product requested for, we require information from you, some of which may be considered as Personal Data (defined in Clause 1.2 below). We understand the importance of the privacy and security of your information, and we have therefore set out in detail below how we collect and use your information. Kindly review the terms and conditions of our Privacy Policy as follows so that you may be reassured that we take data protection seriously:-
For expediency and for compliance with any changes in the law, we reserve the right to amend this Privacy Policy in our sole discretion at any time (without prior notice to you where such amendments are immaterial and/or not required by applicable law), and you agree that your continued access to and/or use of our Website, App, our Site Services (including but not limited to our Token195 API), and/or other associated platforms, your continued desire to view our Content, receive our Updates, check for our news, cryptocurrency trading-related information and articles online or offline, keep in contact with us via email, and/or take-part in our promotions (whether notified to you or made available online or offline, via email, telephone, road shows or other events) constitutes your unconditional acceptance of our amended Privacy Policy, the date of the latest version that is in force being indicated by the “Latest Version” date shown at the start of the Privacy Policy. You agree that it is your sole responsibility to keep yourself updated of any amendments by reviewing this Privacy Policy at our Website regularly. Nonetheless, for material amendments or where advance notice is required by law, we will notify you before such amendments to this Privacy Policy take effect.
When you visit, access or use our Website, App, Content, Site Services, and/or associated platforms, request for any Activity Post, register for any account, sign-up for any of our Updates, enter into a subscription, email us, call us, or take part in our promotions (offline or online), we collect Personal Data and Anonymised Data.
“Personal Data” refers to information, whether true or otherwise, with personal identifiers that can be used separately or collectively with other available (or accessible) information to identify an individual, such as name, address, NRIC number, mobile number, email address, birthdate, gender, income range, residency status, bank account details, and credit card details.
“Anonymised Data” refers to information that is not associated with or linked to your Personal Data and cannot be used to identify individual persons.
When you access our Website, Site Services, Content, App, and/or any of our online advertisements and banners, we collect Anonymised Data about you via the application of generally acceptable web technologies including but not limited to “web beacons”, “cookies”, “clear GIFs”, “widgets”, “online evaluations”, “surveys”, “HTML5”, “dynamic device identifiers”, and third-party web analytics such as “Google analytics” (collectively, “Acceptable Technologies”). This automatic collection of non-personal information includes (without limitation) collection of your IP Address, the web browser software that you used, the type of smart phone or tablet that you may be using, the operating software/platform of your device, your sign-up(s) for any Updates or information via our Website and/or Site Services, your general interest as indicated by the banners or advertisements that you click on, the specific pages of our Website viewed by you, the specific categories or features in our Website accessed by you, the sharing of any information by you via our Website, any third party application used in conjunction with our Website or Site Services, your downloading of our App and APIs, and third party websites that you may have visited prior to our Website. Our purpose for the aforesaid collection of information is for us to understand the preference of our visitors and users so as to enhance and facilitate the ease with which you are able to access or use our Website and our Site Services.
As part of the Anonymised Data that we collect, when you access our Website via your mobile device or tablet, we will also collect information regarding the type of mobile device or tablet that you are utilising so that our Website, App and/or Site Services can provide you with the version of our Website and/or App best suited for access on your mobile device or tablet.
If you do not consent to our collection of Anonymised Data, please adjust the settings on your computer, tablet and mobile device to block or disable our use of the Acceptable Technologies. In the event that you choose to access our Website or our Site Services without blocking or disabling or opting out of the Acceptable Technologies, such access by you will constitute your consent to our use of the Acceptable Technologies and our collection of information thereto.
To better assist you in understanding the generally Accepted Technologies used in our collection of Anonymised Data include:-
In the event that you decide in your sole discretion and risk to use any of the token swap functions made available via hyperlinks on our Site, your ETH Address will be exposed. If you do not accept the potential risk, please do not use any swap functions or perform any token swaps on our Site. For the avoidance of doubt, “ETH Address” refers to the address of your Ethereum wallet.
In order for our Company to provide you with our Site Services (including but not limited to your use of the Token195 API) as well as information via our Website, App and other channels (such as Token195 videos on YouTube) regarding our Site Services, Content, App, APIs and other products and services, including but not limited to our updating you on the latest cryptocurrency related news and trading data or other information based on your request or online subscription with us, enabling you to sign up with us online, submit your form online to list your Activity Post, your receiving our Updates based on your indicated preferred channel, and allowing you to contact us via our Website, App, email or telephone, you agree and consent to our Company collecting, using and retaining your Personal Data as follows:-
In addition, we will retain your Personal Data where necessary and for such duration as may be required in order for our Company to comply with applicable laws and regulations, assist in any legal investigations, meet the demands from any regulatory or law enforcement bodies, for utilization in legal proceedings, minimizing fraud, collection of debts, repayment of loans, resolving disputes, identifying issues, enforcing contractual breaches and/or claiming for damages.
Without prejudice to the generality of the abovegoing clauses hereunder this Section 3, specifically, when you utilize social login (i.e. using data already held with a Social Media Site (as defined in Clause 12.4 below)) to register an account with us, to access your account, our Website, App, APIs, other services or products, we will generally only collect, retain and use your email address, usually for the purposes of having a unique identifier for your account (as each user is only permitted to register one account with us), to allow you to secure your account, and for us to communicate with you regarding your account, your use of our services or products, and/or any other matters of interest to you that you may have informed us of from time to time.
We may need to disclose your Personal Data to:-
Except as provided above, we do not sell, rent, licence or otherwise disclose your Personal Data to third parties, and only our authorised personnel who have signed written obligations of confidentiality are permitted to access your securely kept Personal Data in order to provide the services that you are using or have requested for from our Company. We are careful in our selection of third party service providers, and all such third party service providers are bound by obligations of data protection (pursuant to contracts and/or applicable laws) similar to the obligations herein this Privacy Policy. In general, the third party service providers engaged by us will only collect, use and disclose your information to the extent necessary to allow them to perform the services they provide to us.
Without limiting the generality of the abovegoing, your ETH Address will be exposed when you use any of the token swap functions available via hyperlinks on our Site, and some of your Personal Data may also be shared with the third party providers of such swap functionalities and protocols pursuant (or in relation) to your token swap transaction. Your usage of identity protection technologies (as may be made available by third parties) should ideally protect your identity from being disclosed to the public. Nonetheless, please note that the third party token swapping and identification protection functionalities made available, hyperlinked to, or referenced to on our Site does not constitute Token195’s association with or endorsement of the third party providers of such functionalities or vice versa. Accordingly, we cannot provide any guarantees or warranties howsoever pertaining to any of the third party token swapping and identification protection functionalities made available, hyperlinked, or referenced to on our Site. Your usage of such third party token swapping and identification protection functionalities is also governed by the third parties’ respective terms and conditions. For example, usage of MetaMask and KyberWidget is governed by their terms and conditions at https://metamask.io/terms.html and https://files.kyber.network/tac.html respectively. In addition, such third party providers may also collect and use your Personal Data as per their respective privacy policies. To illustrate, MetaMask’s collection and use of your Personal Data is as per their privacy policy at https://metamask.io/privacy.html. Please read carefully and consider whether the third party’s terms and conditions are acceptable to you before you commence usage of any such third party token swapping and identification protection functionalities as may be made available or referenced to on our Site. Should you have any concerns regarding the potential collection, exposure, transfer and/or use of your Personal Data by any such aforesaid third party providers, please do not use their apps/widgets/plugins/extensions/protocols until you have clarified with the relevant third party provider on its privacy policy and terms of use.
Pursuant to the purposes and activities as set out in sections 3 and 4 above, it may be necessary for us to transfer your Personal Data out of Singapore. You hereby agree and consent to the aforesaid transfer, on the understanding that the recipients of such Personal Data are also subject to applicable laws or contractual obligations similar to the obligations as set out in the Personal Data Protection Act 2012.
In order for us to provide you with access to your account, our Website, our App, our APIs, our Site Services, our Content, our Updates, and all their respective associated functions, our services and our products, and to perform the activities as set out in sections 3, 4 and 5 above, you warrant that the Personal Data that you provide to us is accurate, and that all Personal Data as may be relevant for that particular purpose/circumstance has been provided. In the event of any changes or updates to your Personal Data, you undertake to promptly inform us in writing of such changes, failing which we shall not be responsible for any consequences thereto (including but not limited to your non-receipt of communications sent by us, non-completion of any transactions performed via our Website, inaccuracy of your listed Activity Post, inability to redeem your loyalty points, and/or your inability to access our Website).
We respect your selections in relation to the channels via which you wish to receive our Updates. Therefore, if you have registered your telephone and/or fax number with the Do-Not-Call Registries in relation to telephone calls, text or fax messages, we will not send you any Updates via the channels that you have opted out of by registering with the Do-Not-Call Registries. However, if you have previously consented to our sending you Updates via your telephone number (calls or text messages) and/or facsimile number, we will continue doing so until you withdraw your consent by contacting our Data Protection Officer at hello@Token195.com.
Should you wish to delete your account, please click on the “Delete my account” button on the Login & Security page after logging into your account. To learn more about deleting your account, please visit this guide on our support page. Please note that all your saved data will be permanently deleted when you delete your account. As such, deletion of your account will constitute your withdrawl of consent to our use, retention, disclosure and transfer of your Personal Data. Please see Clause 8.2 below to understand what may ensue pursuant to your withdrawal of consent.
You may at any time withdraw your consent to our use, retention, disclosure or transfer of your Personal Data pursuant to this Privacy Policy by emailing our Data Protection Officer at social@token195.com. However, please note that any such withdrawal of consent may result in us being unable to continue providing our services or fulfilling our contractual obligations with you, including but not limited to termination of your access to your account with us, our Website, App, APIs and/or Site Services, inability to access or redeem any loyalty points, inability to transact or complete an ongoing transaction started via our Website, our App, APIs, cancellation of any engaged services (including but not limited to listing of your Activity Post), scheduled Updates’ delivery, purchased products or services, enrolled events, and thereby all deliverables that would have been provided thereunder, termination of loyalty programme benefits that would otherwise have been available to you, inability to access your status and logs that would be otherwise reflected in your registered account with us, cessation of your access to our Website, our App, our APIs, our Site Services and all Content as well as other features thereto, inability to provide you with the opportunity to participate in promotions, inability to fulfil any request for information or regular Updates that you may have submitted to our Company, inability to allow your participating in any requested event or listing, fulfill any purchase orders, and potentially inability of third parties to provide you with their services or products as you might have contracted with them through our Website or Site Services, regardless of whether you have made payment for such engagements, enrolments, services or products. Accordingly, your withdrawal of consent may also lead to the termination of any contract(s) that you may have with our Company, as well as termination of any contracts with any third parties you may have engaged with through our Website, our Company or Site Services, for which our Company expressly reserves its rights and remedies thereto. Our Data Protection Officer will further advise you on the legal consequences that may ensue should you contact him to withdraw your consent.
Should you wish to unsubscribe to our email updates, please click the “unsubscribe” option made available in our emails to you. Please note however that this may result in our being unable to make available to you updates on our products and services, events, our Company, your benefits under our membership programme, and any ongoing promotions.
Should you wish to access, update or make corrections to your Personal Data held with us, or if you wish to receive further clarifications on your Personal Data held with us, please email our Data Protection Officer at social@token195.com.
There will be no administrative fees or other charges levied for any request to correct or update your Personal Data. However, for all other requests such as accessing your Personal Data held with us, obtaining a record of when you accessed our Site or Site Services, the date of your requests for information, etc., a reasonable administrative fee may be levied depending on your request as time and resources will be spent in accommodating your requests.
Should you have any queries or complaints pertaining to this Privacy Policy, our Website Terms of Use, any other specific terms of service of the Agreement, your Personal Data as registered with us, or in relation to our Company’s use, retention, disclosure or transfer of your Personal Data, or should you desire to learn more about our data protection policies and security measures, please email our Data Protection Officer at social@token195.com.
In the event that you are a citizen or resident of the European Union, please refer to section 14 “Citizens of and Residents in Members of the European Union” below for more information.
Our Website, our Site Services (including our Token195 API and other APIs), our App, our Content, our Updates, our events, our promotions, our services and products are not meant for persons who may be defined as minors under applicable law. As such, if you are below 21, please terminate all access to our Website, our App and Site Services immediately, and do not register any account with us. We reserve the right (but not the obligation) to demand at any time evidence for our review to verify that you are above 21 years of age. In the event that you are under 21 years of age, or we reasonably suspect that you are under 21 years of age and you are unable to prove otherwise, all your listed Activity Posts, use of our APIs, account registrations, enrolments, subscriptions and purchases with us (if any) shall be immediately terminated and no refunds of any kind shall be provided to you.
To clarify, we do not knowingly collect Personal Data from minors, however, through the internet, we are not able to ascertain on our end whether such individuals are minors. It is thus the responsibility of parents or guardians to ensure that their minors do not access our Website, use our Site Services (including our Token195 API), download our App, enrol for any of our events, download or access our related applications, email us, or provide us with Personal Data without their parental/guardian’s consent. If a parent or guardian becomes aware that his or her minor has accessed our Website, our App or our Site Services or provided us with Personal Data without his/her consent, he or she should contact our Data Protection Officer at social@token195.com promptly.
We ensure that our Website is protected by reasonable security measures afforded by current technology, and that all our data hosts and servers are similarly protected by such security measures, including but not limited to firewalls.
Your Personal Data is kept securely and protected against unauthorized access and disclosure. We utilise security means such as (without limitation) password protection, encryption, locked and restricted access. We have strict policies in place restricting access to Personal Data to only our authorized personnel on a need-to-know basis.
We will take practical steps to ensure that your Personal Data will not be kept longer than as set out herein this Privacy Policy, or for as long as is necessary for fulfilling the purposes for which you have entrusted us with your Personal Data, or as may be required for legitimate business or legal purposes, whichever is the latest.
Our Website, our App, our APIs, our Site Services (including but not limited to widgets and plugins), our Updates, our Content, our loyalty program’s redemption items and system, emails and other promotional messages may contain hyperlinks to websites operated by third parties. Some of the aforesaid third party links may also be “affiliate links”. However, such third party websites are not governed by our Privacy Policy or Website Terms of Use. We are not responsible for the privacy policies or data security of such third party websites, even if they are affiliate links, co-branded with our Company name or logo, or our Website or Site Services, or promotional messages on our Site display products or services that originate from such third parties, or our Site displays products or services originating from such third parties as redemption rewards available thereunder our loyalty points redemption scheme, or when we allow your utilization of social login to register an account with us, to access your account, our Website, App, APIs, other services or products. As such, we urge you to learn about the privacy policies of these third party websites before accessing or using them, and to be careful about providing any Personal Data to such third party websites. We seek your understanding that we are not liable for any acts or omissions or any loss or damage that you may suffer due to your use or access of such third party websites.
For clarification, “affiliate links” refer to third party links on our Site pursuant to which our Company may receive compensation from the referenced third party, which may be in the form of tokens, digital currency, fiat currency, services or products from such affiliated third parties (which includes without limitation “Binance”, and certain operators of Social Media Sites). Such compensation to our Company may be provided to our Company even if you do not click on the affiliate links, and/or additional compensation may be provided to our Company if you do click on such affiliate links and/or take any further action in relation to such affiliate links (for example, signing up on the affiliate’s website or using the affiliate’s application). In the event that you take any action such as clicking on an “affiliate link”, and particularly if you take any further steps thereafter such as (without limitation) subscribing for the affiliated third party’s services, please be aware that your information (including without limitation your Personal Data), may be collected by such affiliated third party. Please therefore read the privacy policy of such affiliated third parties carefully before you agree to disclose any of your Personal Data to any such affiliated third parties, and you do so at your own risk and discretion. Each affiliate link is identified by an affiliate icon next to it.
Without limiting the generality of Clauses 12.1 and 12.2 above, as our Website incorporates videos and podcasts regarding cryptocurrency, utility tokens, digital coins/currency, ICOs that do not amount to an offering of securities or securities-tokens, and other related digital currency information, and such videos and podcasts (or links to such videos and podcasts) are made available via YouTube, or the use of YouTube API Services (as defined in the “YouTube Terms of Service” found at https://www.youtube.com/t/terms), you hereby agree that in order for you to access the aforesaid videos and podcasts, you must agree to abide by all provisions therein the YouTube Terms of Service as well as the Google Privacy Policy at http://www.google.com/policies/privacy, failing which, you are not permitted to access the aforesaid videos and podcasts.
Our Company may utilise reputable social media/network sites such as, but not limited to Facebook, Twitter, Instagram, Pinterest and LinkedIn as well as app stores such as Google and Apple platforms (collectively the “Social Media Sites”) so as to connect to your social networks, or to allow for your utilization of social login to register an account with us, to access your account, our Website, App, APIs, other services or products. In order to allow for your utilization of social login to register an account with us, to access your account, our Website, App, APIs, other services or products, and/or to generate interest in our Website, our App, our APIs and our Site Services, our products and services amongst the contacts in your social networks and to allow you to share your interest in our Website, our App, our APIs, our Site Services, our Updates, our Content, our events, and/or our other products and services, we may provide access to our Website to the third party Social Media Sites, and there may thus be links on our Website to such Social Media Sites. The aforesaid association with the Social Media Sites does not constitute any endorsement or recommendation of any of the Social Media Sites by our Company nor vice versa. As per clauses 12.1 and 12.2 above, kindly review the terms of use and privacy policies of the Social Media Sites before you use or access such Social Media Sites in conjunction with our Website, our App or Site Services or any of our promotions and our products or services made available via any Social Media Sites.
The association of our Website, our App, APIs, and/or Site Services with the Social Media Sites makes available certain features which when used by you, may result in information being made available from your accounts with the Social Media Sites to our Company, which in the case of your utilization of social login to register an account with us, to access your account, our Website, App, APIs, other services or products tends to be limited to the collection, retention and use of your email address. Should you prefer that we do not collect your information from the Social Media Sites, please (i) do not use the features or links that associates our Website, our App and/or Site Services with the Social Media Sites; and (ii) adjust the settings in your accounts with the Social Media Sites to prevent the sharing of your information with our Website and App. Please note that our Company cannot control nor is our Company howsoever responsible for the sharing of your information by the Social Media Sites with third parties.
One of the features which you may see available on our Website, App and Site Services in association with the Social Media Sites, is the “like” feature by Facebook, and other similar functions provided by other Social Media Sites. When you “like” our Website, App or any of our Site Services or our other products or services, information about our Website or Site Services, our products and services will be made known to your network within your Social Media Sites’ accounts via a variety of methods employed by the relevant Social Media Site. Your information may also be made known alongside with our services, products or services that you have liked pursuant to the methods/channels made available by Social Media Sites in relation to such features. If you are not agreeable to the aforegoing, please instruct the relevant Social Media Site or adjust your account settings with the Social Media Site. Please note however that we are not obliged to display on our Website or any related webpages (whether on Social Media Sites or otherwise) any of your information, including but not limited to your photo or name, even if you “like” our Website, our Site Services, our other services or products. In the event that any of your information, product or service endorsements (including your liking of our Website, our Site Services, any of our Company’s other services or products, or third party services or products featured on our Website or Site Services) appear on our Website or any related webpages (whether on Social Media Sites or otherwise), we shall have the right in our sole discretion to remove such information or product/service endorsements from our Site or any related webpages.
The terms and conditions of this Privacy Policy are governed by the laws of Singapore. In the event of any disputes arising from this Privacy Policy and your use of our Website and/or our Services (including but not limited to our courses and other educational activities), you must first contact our Data Protection Officer at social@token195.com regarding your concern and use your best endeavours to amicably settle any dispute in good faith. We on our part will also use our best endeavours to amicably settle your concerns in good faith. However, if no amicable resolution is reached within 30 days, you agree to submit to the exclusive jurisdiction of the Courts of Singapore. If you have any questions regarding this Privacy Policy or your Personal Data, please contact our Data Protection Officer at social@token195.com.
In order to resolve a complaint regarding the Site or to receive further information regarding use of the Service, please contact us at: social@token195.com.
