This Privacy Policy (“Privacy Policy”) describes how Enjin App Pte. Ltd. may collect, use, disclose, process, and protect your information when you access Enjin’s mobile wallet application (“Mobile Wallet”) or browser-based wallet (“Web Wallet, and together with the Mobile Wallet, the “Wallets”) including the use of the current and future features and functionalities of the Wallets (collectively, “Services”). All references in this Privacy Policy to "Enjin", "our", "us" or "we" refer to Enjin App Pte. Ltd., or our group companies, as appropriate.
This Privacy Policy governs the collection, storage and use of personal information by us when you install, access, or use the Services. It provides you with details about the personal information we collect from you, how we use your personal information, and your rights regarding the personal information we hold about you. Please read this Privacy Policy carefully.
We are always looking to improve the information we provide to our customers and contacts so if you have any feedback on this Privacy Policy, please let us know by contacting our data protection officer ("DPO") whose details are set out at section 13 (Further questions and how to make a complaint) below.
This Privacy Policy describes the following important topics relating to your information:
In this Privacy Policy, "personal information" means any personal information about you which could identify you (by itself or in combination with other data) such as your name, address, email address, wallet address or an online identifier, such as a unique ID, or your Internet Protocol (or 'IP') address.
In relation to the use of the Wallets, we generally do not collect and store personal information, except for the limited information under sections 2.1 and 2.2. The collection of limited personal information can be through a number of different ways. In this section, we explain the different ways we collect personal information and the ways in which that information will be used. For more detail on how we use your data, please see section 3 (What does Enjin do with this data and what is our legal basis for processing this data?) below.
We will usually collect and store the following data about you when you access and use our Services:
We will sometimes use third party companies to help us collect this personal information. Further information is provided below in section 4 (What personal information is shared with or accessed by third parties?) below.
The personal information you provide is collected, stored and used to enable us to deliver, operate, improve, customize, and support the Services in the best way possible. This includes, but is not limited to:
The above uses of your personal information are necessary in order for us to provide the Wallets and the Services, and for you and other users to be able to use them, in accordance with our Terms of Service.
Sometimes, our use of your personal information is for purposes which are ancillary to the provision of the Wallets, or which are desirable in order to make it operate more effectively. In those circumstances, we believe we have a legitimate interest in handling your data, and do not believe that this storage and use of your data will be of particular concern to you.
We use your personal information for our legitimate interests in the following ways:
We will also collect anonymised details about the use of the Wallets for the purposes of creating aggregate statistics or reporting purposes. However, no single individual will be identifiable from the anonymised details we collect for these purposes. We may share this aggregated information about our user base with our partners and advertisers.
We may share your personal information with various third parties (including our affiliate companies in other countries) as follows:
Any third parties with whom we share your personal information are limited (by law and by contract) in their ability to use your personal information for any purpose other than to provide services for us. We will always take reasonable steps to ensure that any third parties with whom we share your personal information are subject to privacy and security obligations consistent with this Privacy Policy and applicable laws.
To the extent available to us, we will also disclose your personal information to third parties:
We may also disclose and use anonymised, aggregated reporting and statistics about users of our Services or our goods and services for the purpose of internal reporting or reporting to our group or other third parties, and for our marketing and promotion purposes. None of these anonymised, aggregated reports or statistics will enable our users to be personally identified.
Save as expressly detailed above, we will never share, sell or rent any of your personal information to any third party without notifying you and, where necessary, obtaining your consent. If you have given your consent for us to use your personal information in a particular way, but later change your mind, you should contact us and we will stop doing so.
We engage the services of a cloud storage provider in providing the Wallets and the Services. This means that the personal information we collect from you might be used, stored and/or accessed by our staff, members of our group, or suppliers outside of Singapore, such as in the European Economic Area ("EEA"), the USA, Canada, Asia Pacific, and other locations where our provider has servers. Further details on to whom your personal information may be disclosed are set out in section 4 (What personal information is shared with or accessed by third parties?).
Where we transfer any personal information about you to any location outside the EEA, we will take appropriate measures to ensure that the recipient protects your personal information adequately in accordance with this Privacy Policy. These measures may include the following permitted in Articles 45 and 46 of the EU's General Data Protection Regulation:
In relation to personal information collected in Singapore, we will only transfer personal information outside Singapore in accordance with the Personal Data Protection Act 2012 ("PDPA") of Singapore. Further, you agree, acknowledge and consent that your personal information (and such other personal information which you provide to us) may be stored or processed in any country where we have operations or where we engage service providers. We may transfer personal information outside Singapore to countries which may have data protection rules that are different from those of Singapore. However, we shall take measures to ensure that any such transfers comply with the PDPA, and such personal information remains protected to the standards described in this Privacy Policy. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access the personal information.
Further details on the steps we take to protect your personal information are available from us on request by contacting our DPO, whose details are set out at section 13 (Further questions and how to make a complaint), at any time.
We keep your personal information for no longer than necessary for the purposes for which the personal information is processed. The length of time for which we retain personal information depends on the purposes for which we collect and use it and/or as required to comply with applicable laws and to establish, exercise or defend our legal rights.
If you wish to remove your personal information from the Wallets (except for your IP address and logs tracked), you can delete the Mobile Wallet at any time. However, please note that even if you delete or uninstall the Mobile Wallet, we may still retain some personal information to comply with our obligations under laws or regulations. For the Web Wallet, you can clear your browser history, cookies, and cache.
In relation to the use of the Wallets, we generally do not collect and store personal information, except for the limited information under sections 2.1 and 2.2. You have certain rights in relation to your personal information. If you are located in the European Union, please refer to section 7.2 for information relating to your rights. If you are located outside the European Union, please refer to section 7.3 for information relating to your rights.
If you would like further information in relation to these or would like to exercise any of them, please contact our DPO, whose details are set out at section 13 (Further questions and how to make a complaint), at any time.
We will consider all such requests and provide our response within a reasonable period (and in any event within one (1) month of your request unless we tell you we are entitled to a longer period under applicable law). Please note, however, that (i) we require proof of identity before responding to any requests to exercise your rights and (ii) certain personal information may be exempt from such requests in certain circumstances, for example if we need to keep using the information to comply with our own legal obligations or to establish, exercise or defend legal claims.
If an exception applies, we will tell you this when responding to your request. We may request that you provide us with information necessary to confirm your identity before responding to any request you make.
If you are located in the European Union, you have the following rights:
If you are not located in the European Union, you have the following rights:
We may send you certain marketing and update communications through the Mobile Wallet’s push notifications or other means. If you sign up for the beta version of the Wallets, you also consent to the use of your email address for marketing purposes.
Enjin recognizes the importance of children’s safety and privacy on the Internet. For this reason, and in compliance with certain laws, we do not intentionally collect personal information from children, nor do we offer any content targeted to children. We do not collect information relating to the age of individuals using our Services and, therefore, we recommend parents and guardians of children using our Services regularly clear their browser cache and/or browsing history to clear cookies.
The main risk of our processing of your personal information is if it is lost, stolen or misused. This could lead to your personal information being in the hands of someone else who may use it fraudulently or make public, information that you would prefer to keep private.
For this reason, Enjin is committed to protecting the personal information that has been provided to us from loss, theft and misuse. We take all reasonable precautions to safeguard the confidentiality of your personal information, including through use of appropriate organizational and technical measures. We secure your personal information via TLS, and use a secure service to prevent unauthorized access to data. Data is protected by encryption and secured through access control lists, security keys / tokens, IP whitelisting and by the use of username / password access. Enjin also carries out access audits of its staff in order to detect any unauthorized access.
In the course of provision of your personal information to us, your personal information may be transferred over the internet. Although we make every effort to protect the personal information which you provide to us, the transmission of information over the internet is not completely secure. As such, you acknowledge and accept that we cannot guarantee the security of your personal information transmitted from our Wallets and that any such transmission is at your own risk. Once we have received your personal information, we will use strict procedures and security features to prevent unauthorized access to it.
Where you have chosen a password and where private keys have been provided to you which enable you to access the Wallets, you are responsible for keeping this information confidential. We require that you do not share your passwords or private keys with anyone else.
The Wallets may contain hyperlinks to websites that are not operated by us but by third parties such as but not limited to Facebook, Twitter, Telegram, and decentralized apps (“dApps”). These hyperlinks are provided for your reference and convenience only and do not imply any endorsement of the activities of such third-party websites or any association with their operators. When you click on these hyperlinks, you become subject to the third party’s privacy practices. This Privacy Policy only applies to the personal information that we collect or which we receive from third party sources, and we cannot be responsible for personal information about you that is collected and stored by third parties.
Third party websites have their own terms and conditions and privacy policies, and you should read these carefully before you submit any personal information to these websites. We do not endorse or otherwise accept any responsibility or liability for the content of such third party websites or third party terms and conditions or policies.
Because of the evolving nature of technologies and the way we conduct business, we may update our Privacy Policy from time to time. Any changes we make to our Privacy Policy in the future will be posted on this page. You can determine when the policy was last updated by looking at the “Updated” date at the top and bottom of this policy. If there are material and substantial changes to the policy, we will note as such through a prominent notice on our Wallets. Please check back frequently to see any updates or changes to our Privacy Policy.
If you have any queries or complaints about our collection, use or storage of your personal information, or if you wish to exercise any of your rights in relation to your personal information, please contact our DPO, Oscar Franklin Tan, at privacy@enjin.io. We will investigate and attempt to resolve any such complaint or dispute regarding the use or disclosure of your personal information.
If you are an EU citizen, you may also make a complaint to the relevant data protection regulator under the EU's General Data Protection Regulation.
The practices described in this Privacy Policy are current as of 3 July 2023.