PRIVACY POLICY
DATA PROTECTION NOTICE FOR CUSTOMERS
This Data Protection Notice (“Notice”) sets out the basis which Me3 Labs Inc (“we”, “us”, or “our”) may collect, use, disclose or otherwise process personal data of our customers in accordance with the Personal Data Protection Act of [insert country] (“PDPA”). This Notice applies to personal data in our possession or under our control, including personal data in the possession of organisations which we have engaged to collect, use, disclose and/or process personal data for our purposes.
PERSONAL DATA
As used in this Notice:
“customer” means an individual who: (a) has contacted us through any means to find out more about any goods or services we provide, or; (b) may enter, or has entered, into a contract with us for the supply of any goods or services by us; and
“personal data” means data, whether true or not, about a customer who can be identified: (a) from that data; or (b) from that data and/or other information to which we have or are likely to have access.
Depending on the nature of your interaction with us, some examples of personal data which we may collect from you include:
name;
email address;
telephone number;
date of birth;
financial information (crypto holdings across different chains, NFT);
facial biometric including liveness data;
IP address;
GPS location;
MAC ID;
IMEI;
SIM card information such as IMSI;
advertiser ID;
crypto public keys across multiple onboarded crypto chains;
crypto transactions on the public blockchain;
crypto private keys (crypto private keys are encrypted (AES 256) on your device before being sent to our servers, and we have no access to the encryption key which is stored on your device/cloud outside of our control nor are we able to derive the encryption keys on our end); and/or
in app customisation, usage and transactions.
Other terms used in this Notice shall have the meanings given to them in the PDPA (where the context so permits).
COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA
We generally do not collect your personal data unless: (a) it is provided to us voluntarily by you directly or via a third party who has been duly authorised by you to disclose your personal data to us (your “authorised representative”) after: (i) you or your authorised representative have or has been notified of the purposes for which the data is collected, and; (ii) you or your authorised representative have or has provided written consent to the collection and usage of your personal data for those purposes; or (b) collection and use of personal data without consent is permitted or required by the PDPA or other laws. We shall seek your consent before collecting any additional personal data and before using your personal data for a purpose which we have not notified you of (except where permitted or authorised by law).
We may collect and use your personal data for any or all of the following purposes:
performing obligations in the course of, or in connection with, our provision of the goods and/or services requested by you;
verifying your identity;
responding to, handling, and/or processing queries, requests, applications, complaints, and/or feedback from you;
managing your relationship with us;
complying with any applicable laws, regulations, codes of practice, guidelines, and/or rules, or to assist in law enforcement and/or investigations conducted by any governmental and/or regulatory authority;
any other purposes for which you have provided the information to us;
transmitting to any unaffiliated third parties, including our third party service providers and agents, and relevant governmental and/or regulatory authorities, whether in Panama or abroad, for the aforementioned purposes; and/or
any other incidental business purposes related to, or in connection with, the above.
We may disclose your personal data:
where such disclosure is required for performing obligations in the course of, or in connection with, our provision of the goods and services requested by you; or
to third party service providers, agents and/or other organisations we have engaged to perform any of the functions herein with reference to the above mentioned purposes. Or
Where the disclosure is mandated by Government or the relevant enforcement/regulatory agencies.
DEEMED CONSENT BY NOTIFICATION
We may collect, use and/or disclose your personal data for secondary purposes that differ from the primary purpose which it had originally been collected, such as for:
application diagnostics;
application usage;
website usage; and/or
business intelligence.
If we intend to rely on your deemed consent by notification for such secondary purposes, we will notify you of the proposed collection, use or disclosure of your personal data.
Before relying on your deemed consent by notification, we will assess and determine that the collection, use and/or disclosure of your personal data will not likely have an adverse effect on you.
You will be given a reasonable period to inform us if you wish to opt-out of the collection, use and/or disclosure of your personal data for such purposes.
After the lapse of the opt-out period, you may notify us that you no longer wish to consent to the purposes for which your consent was deemed by notification, by withdrawing your consent for the collection, use and/or disclosure of your personal data in relation to those purposes.
RELIANCE ON THE LEGITIMATE INTERESTS EXCEPTION
In compliance with the PDPA, we may collect, use and/or disclose your personal data without your consent for the legitimate interests of ourselves or another person. In relying on the legitimate interests exception of the PDPA, Me3 Labs Inc Ltd must assess the likely adverse effects towards you and determine that the legitimate interests outweigh any such adverse effects.
In line with the legitimate interests exception, we will collect, use and/or disclose your personal data for the following purposes:
Fraud detection and prevention;
Detection and prevention of misuse of services; and/or
Network analysis to prevent fraud and financial crime, and to perform credit analysis.
The purposes listed above may continue to apply even in situations where your relationship with us (for example, pursuant to a contract) has been terminated or altered in any way, for a reasonable period thereafter.
WITHDRAWING YOUR CONSENT
The consent that you provide for the collection, use and/or disclosure of your personal data will remain valid until such time it is withdrawn by you in writing. You may withdraw consent and request us to stop collecting, using and/or disclosing your personal data for any or all of the purposes listed above by submitting your request in writing or via email to our Data Protection Officer at the contact details provided below.
Upon receipt of your written request to withdraw your consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us. In general, we shall seek to process your request within ten (10) business days of receiving it.
Whilst we respect any decision you may make to withdraw your consent, please note that depending on the nature and scope of your request, we may not be in a position to continue providing our goods or services to you and we shall, in such circumstances, notify you before completing the processing of your request. Should you decide to cancel your withdrawal of consent, please inform us in writing.
Please note that withdrawing consent does not affect our right to continue to collect, use and/or disclose personal data where such collection, use and/or disclosure without consent is permitted and/or required under applicable laws.
ACCESS TO AND CORRECTION OF PERSONAL DATA
If you wish to make: (a) a request for access to a copy of the personal data which we hold about you or information about the ways in which we use and/or disclose your personal data; or (b) a correction request to correct or update any of your personal data which we hold about you, you may submit your request in writing or via email to our Data Protection Officer at the contact details provided below.
Please note that a reasonable fee may be charged for an access request. If so, we will inform you of the fee before processing your request.
We will respond to your request as soon as reasonably possible. In general, our response will be within ten (10) business days. Should we not be able to respond to your request within thirty (30) days after receiving your request, we will inform you in writing of the time by which we will be able to respond to your request. If we are unable to provide you with any personal data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the PDPA).
PROTECTION OF PERSONAL DATA
To safeguard your personal data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, we have introduced appropriate administrative, physical and technical measures such as authentication and access controls (such as good password practices, need-to-basis for data disclosure, etc.), encryption of data, regular patching of operating system and other software, security reviews and regular testing.
You should be aware, however, that no method of transmission over the internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.
ACCURACY OF PERSONAL DATA
We generally rely on personal data provided by you or your authorised representative. In order to ensure that your personal data is current, complete and accurate, please update us if there are changes to your personal data by informing our Data Protection Officer in writing or via email at the contact details provided below.
RETENTION OF PERSONAL DATA
We may retain your personal data for as long as it is necessary to fulfil the purpose for which it was collected, and/or as required or permitted by applicable laws.
We will cease to retain your personal data or remove the means by which the data can be associated with you as soon as it is reasonable to assume that such retention no longer serves the purpose for which the personal data was collected and is no longer necessary for legal or business purposes.
TRANSFERS OF PERSONAL DATA OUTSIDE OF PANAMA
We generally do not transfer your personal data to countries outside of Panama. However, if we do so, we will obtain your consent for the transfer to be made and we will take steps to ensure that your personal data continues to receive a standard of protection that is at least comparable to that provided under the PDPA.
DATA PROTECTION OFFICER
You may contact our Data Protection Officer if you have any enquiries or feedback on our personal data protection policies and procedures, or if you wish to make any request, in the following manner:
Name : Artur Niki
Email Address : [email protected]
EFFECT OF NOTICE AND CHANGES TO NOTICE
This Notice applies in conjunction with any other notices, terms and conditions, contractual clauses and consent clauses that apply in relation to the collection, use and/or disclosure of your personal data by us.
We may revise this Notice 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 Notice was last updated. Your continued use of our services constitutes your acknowledgement and acceptance of such changes.
Effective date : 2022-07-15
Last updated : 2024-04-25