This Privacy Policy for Coordinate Labs Pte. Ltd. (collectively with its affiliates, "Company", "we", "us" "our") describes how we collect, use and disclose information about users of the Company's website (www.axis.to, the "Site"), and any related services, tools and features, including the Axis service (collectively, the "Services"). For the purposes of this Privacy Policy, "you" and "your" means you as the user of the Services. Please read this Privacy Policy carefully. By using, accessing, or downloading any of the Services, you agree to the collection, use, and disclosure of your information as described in this Privacy Policy. If you do not agree to this Privacy Policy, please do not use, access or download any of the Services.
We may modify this Privacy Policy from time to time in which case we will update the "Last Revised" date at the top of this Privacy Policy. If we make material changes to the way in which we use information we collect, we will use reasonable efforts to notify you (such as by emailing you at the last email address you provided us, by posting notice of such changes on the Site, or by other means consistent with applicable law) and will take additional steps as required by applicable law. If you do not agree to any updates to this Privacy Policy please do not access or continue to use the Services.
When you access or use the Services, we may collect (directly or through third-party providers) certain categories of information about you from a variety of sources, which comprises:
Information provided during "Know Your Customer" ("KYC") and Anti-Money Laundering ("AML") processes for institutional clients, which includes personal identifying information. This may include:
We process the data provided and collected to provide the Services, personalize your experience with the Services, and improve the Services. Specifically, we use your data to:
In certain circumstances, the Company may share your information with third parties for legitimate purposes subject to this Privacy Policy. Such circumstances comprise of:
The legal bases for the processing of personal data of natural persons in the European Economic Area (EEA) are detailed in the General Data Protection Regulation (GDPR). The legal bases for processing your personal data are:
Do Not Track Signals: Your browser settings may allow you to transmit a "Do Not Track" signal when you visit various websites. Like many websites, our website is not designed to respond to "Do Not Track" signals received from browsers.
Cookies and Other Tracking Technologies: Most browsers accept cookies automatically, but you may be able to control the way in which your devices permit the use of cookies and other tracking technologies. If you so choose, you may block or delete our cookies from your browser; however, blocking or deleting cookies may cause some of the Services to work incorrectly.
Analytics: We use Vercel Analytics to understand website usage patterns. You can control tracking preferences through your browser settings.
The legal bases for the setting of cookies are legitimate interests under Art. 6 para. 1 letter f) GDPR and, if applicable, your consent in accordance with Art. 6 (1) (a) GDPR. In the case of the initiation of a contract or an ongoing contractual relationship, the legal basis also follows from Art. 6 para. 1 sentence 1 letter b) GDPR.
We may provide links to websites or other online platforms operated by third parties, including third-party DeFi protocols such as decentralized exchanges. If you follow links to sites not affiliated or controlled by us, you should review their privacy and security policies and other terms and conditions. We do not guarantee and are not responsible for the privacy or security of these sites. Our inclusion of such links does not imply any endorsement of the content on such platforms or of their owners or operators.
Certain transactions conducted via our Services will require you to connect a wallet to the Services. By using such wallet to conduct transactions via the Services, you agree that your interactions with such third party wallets are governed by the privacy policy for the applicable wallet. We expressly disclaim any and all liability for actions arising from your use of third party wallets, including but without limitation, to actions relating to the use and/or disclosure of personal information by such third party wallets.
We collect data from activity that is publicly visible and/or accessible on blockchains, including the Plasma network. This may include blockchain addresses and information regarding holdings, purchases, sales, or transfers of tokens, which may then be associated with other data you have provided to us.
We use appropriate technical and organizational measures to prevent accidental or intentional manipulation, partial or total loss, destruction or unauthorized access to your data by third parties. Our security measures are continuously improved in line with technological developments.
Please be aware that, despite our reasonable efforts to protect your information, no security measures are perfect or impenetrable, and we cannot guarantee "perfect security." You are responsible for the security of your digital wallet(s), and we urge you to take steps to ensure it is and remains secure.
In the event that any information under our custody and control is compromised as a result of a breach of security, we will take steps to investigate and remediate the situation and, in accordance with applicable laws and regulations, notify those individuals whose information may have been compromised.
You may have certain rights with respect to your personal data:
European Economic Area Users: If you are a user in the European Economic Area, you have certain rights under the European General Data Protection Regulation ("GDPR"). These include the right to:
If you wish to exercise your rights under the GDPR or other applicable data protection or privacy laws, please contact us at legal@axis.to, specify your request, and reference the applicable law. We may ask you to verify your identity, or ask for more information about your request. We will consider and act upon any request in accordance with applicable law.
Notwithstanding the above, we cannot edit or delete any information that is stored on a blockchain, as we do not have custody or control over any blockchains.
We may retain your data as long as you continue to use the Services, or for as long as is necessary to fulfill the purposes outlined in this Privacy Policy. We may continue to retain your data even after you cease to use the Services if such retention is reasonably necessary to comply with our legal obligations, to resolve disputes, prevent fraud and abuse, enforce our Terms or other agreements, and/or protect our legitimate interests. Where your data is no longer required for these purposes, we will delete it.
Your information may be transferred to and processed in countries outside of your jurisdiction, including Singapore and the British Virgin Islands, where data protection laws may differ. By using our Services, you consent to such transfers. We ensure that any such transfers comply with applicable data protection laws and implement appropriate safeguards.
Children under the age of 18 are not permitted to use the Services, and we do not seek or knowingly collect any personal information about children under 18 years of age. If we become aware that we have unknowingly collected information about a child under 18 years of age, we will make commercially reasonable efforts to delete such information from our database.
This section applies to you if you are able to avail yourself of certain rights under GDPR:
Right to Information, Rectification, Deletion: You have the right to request information (Art. 15 GDPR) about your personal data and related information. In addition, you can request the correction (Art. 16 GDPR) and the deletion (Art. 17 para. 1 GDPR) of your personal data. You can also request that the processing of your personal data be restricted (Art. 18 GDPR). Furthermore, you have the right to receive your personal data or to have it transmitted to another responsible body (Art. 20 GDPR).
Revocation of Consent: You can revoke your consent in accordance with Art. 6 (1) sentence 1 (a) GDPR at any time with immediate effect in accordance with Art. 7 (3) sentence 1 GDPR.
Objection to Profiling and Direct Marketing: In certain cases, you have the right to object (Art. 21 GDPR) to the data processing. In particular, you have the right to object at any time to the processing of your data based on Art. 6 (1) sentence 1 (f) GDPR (data processing on the basis of a balancing of interests) in accordance with Art. 21 (1) GDPR.
Right to Lodge a Complaint: If you believe that we have not complied with data protection regulations when processing your data, you can submit a complaint to the supervisory authority responsible for us.
Should you have any questions about our privacy practices or this Privacy Policy, please email us at legal@axis.to or contact us at:
Coordinate Labs Pte. Ltd.
138 Robinson Road, #05-02, Oxley Tower
Singapore 068906