In this policy, “Color Platform”, “we”, “us”, “our” means, collectively, Color Platform. “You”, “your” or “yours” means the persons to whom this policy applies.
The security of your personal data is important to us. Color Platform has in place safeguards to protect the personal data stored with us. This policy describes how we may collect, use, disclose, process and manage your personal data.
This policy applies to any individual’s personal data which is in our possession or under our control.
1. What is Personal Information?
“Personal data” means data, whether true or not, about an individual who can be identified (a) from that data; or (b) from that data and other information to which the organization is likely to have access. Personal information is collected only when voluntarily offered and solely for purposes that are clearly identified on our Website.
2. Information We Collect
When you visit our Website, you may provide us with two types of information: personal information described below that you voluntarily disclose that is collected on an individual basis; and information collected automatically when you use our Website or the services available on our Website (See ‘Information Collected Automatically?’).
We collect your Name(Korean, English),; Username(ID); Password; E-mail address; Cryptocurrency address; Mailing address; Phone number, Fax number, Date of birth, Occupation, Nationality or Citizenship, Address, Driver’s license number or Passport number(You MUST delete last 6 digits of resident registration number. Only for Koreans), Information on documents provided for KYC and AML, and other personal information you choose to provide
We do not collect the personal information of minors under applicable law.
3. Information Collected Automatically?
When you use our Website or services available on our Website, we automatically collect information from your devices. We collect the following information:
- Server Log and IP address Information: We collect server log information when you use our Website, which may include (but is not limited to) your login details, the date and time of visits, the pages viewed, your IP and MAC address, time spent at our Website and the websites you visit just before and just after our Website.
- Device Information: We collect information on computer or mobile device you use to access our Website, including the hardware model, operating system and version, the web browser you use, and other device identifiers.
- Usage Information. If you use our Website, we will collect metadata about the files you upload for storage and we will record instances in which you have used your private key to authenticate communications.
- Information Collected by Cookies and Other Tracking Technologies: We and our service providers use various technologies to collect information when you interact with our Website, including cookies and web beacons. Cookies are small data files that are stored on your device when you visit a website, which enable us to collect information about your device identifiers, IP address, web browsers used to access the Website, pages or features viewed, time spent on pages, mobile app performance and links clicked. Web beacons are graphic images that are placed on a website or in an email that is used to monitor the behavior of the user visiting the website or sending the email. They are often used in combination with cookies.
4. Use of Information
We may use your personal data for our core business purposes, such as:
developing and providing facilities, products or services (whether made available by us or through us), including but not limited to:
- ID authentication, confirmation of intent to subscribe;
- transactions and clearing or reporting on these transactions;
- carrying out research, planning and statistical analysis; or
- analytics for the purposes of developing or improving our products, services, security, service quality, and advertising strategies;
- assessing and processing applications, instructions or requests from you or our customers;
- communicating with you, including providing you with updates on changes to products, services and facilities (whether made available by us or through us) including any additions, expansions, suspensions and replacements of or to such products, services and facilities and their terms and conditions;
- managing our infrastructure and business operations and complying with internal policies and procedures;
- responding to queries or feedback;
- addressing or investigating any complaints, claims or disputes;
- verifying your identity for the purposes of providing facilities, products or services;
- conducting credit checks, screenings or due diligence checks(including KYC, AML) as may be required under applicable law, regulation or directive;
- 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;
- enforcing obligations owed to us;
- monitoring products and services provided by or made available through us;
- complying with obligations and requirements imposed by us from time to time by any credit bureau or credit information sharing services of which we are a member or subscriber;
- creating and maintaining credit and risk related models;
- financial reporting, regulatory reporting, management reporting, risk management (including monitoring credit exposures), audit and record keeping purposes;
- enabling any actual or proposed assignee or transferee, participant or sub-participant of Color Platform’s rights or obligations to evaluate any proposed transaction;
- enforcing obligations owed to us; and/or
- seeking professional advice, including legal 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.
5. Use of Personal Data of 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. In doing so, we will comply with the Personal Data Protection Act of Singapore (PDPA) and other 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 section shall vary or supersede the terms and conditions that govern our relationship with you.
6. Retention of personal data
We shall retain documents, files and database containing personal data in accordance with applicable laws or remove the means by which the personal data can be associated with particular individuals, as soon as it is reasonable to assume that (a) the purpose for which that personal data was collected is no longer being served by retention of the personal data; and (b) retention is no longer necessary for legal or business purposes.
7. Erasure of Personal Information
The personal information is immediately erased after the purpose of its collection and use has been fulfilled. Personal information saved in a digital format is destroyed or erased by using technology that prevents the recovery of records.
8. Disclosure and Sharing of Personal Data
We do not share, sell or transfer your Information without your consent and in accordance with requirements of Personal Data Protection Act, except as described below:
- Our service providers and/or financial institutions. We may provide Your Information to our service providers and/or financial institutions with who we are working to help operate our Site and offer Color tokens for sale. Examples include suppliers that host our data or provide customer service. We require our service providers and/or financial institutions to use Your information only as needed to operate the Site or provide services that enable your Purchase of Color tokens.
- To protect company and its users, or for legal purposes. We may disclose Your Information:
- if we think it’s needed to detect, prevent or address illegal activity with respect to your Purchase of Color tokens, or identify, contact or bring legal action against someone who appears to be causing injury to or interfering with our rights or property or other users;
- when we believe that disclosure is required or permitted by law, including when responding to subpoenas, warrants, production orders, or similar instruments; or
- if we believe that disclosure is needed to prevent financial loss; protect your safety or the safety of others, including when there is an emergency involving potential harm, loss of security or serious injury to people or threats of such emergencies; or if we are obligated to report illegal activity.
- Audits. We may need to share Your Information in order to complete third party financial, technical and legal audits of our operations as part of that review.
9. Protection of Personal Information
We take reasonable steps to protect the security of the information communicated through our Website. However, no computer security system is entirely secure, and the Internet is not a secure method of transmitting information. As a result, we do not assume any responsibility for the data you submit to or receive from us through the Internet or for any unauthorized access or use of that information and we cannot and do not guarantee that information communicated by you to us or sent to you by us will be received or that it will not be altered before or after its transmission to us. You agree to not hold us and our respective past, present and future employees, officers, directors, contractors, consultants, equity holders, suppliers, vendors, service providers, parent companies, subsidiaries, affiliates, agents, representatives, predecessors, successors and assigns liable for any loss or damage of any sort incurred as a result of any misappropriation, interception, modification, deletion, destruction or use of information provided through our Website.
Most web browsers are set to accept cookies as a default. You may wish to opt out by turning off cookies (please refer to the help menu on your browser); however, switching off cookies may restrict your use of our Website.
You may also opt out of receiving promotional communications from us at any time by following the instructions in those communications. If you opt out, we may still send you non-promotional communications, such as technical notices, support or administrative notifications or information about your account (if you have one).
10. Third Party Websites
11. GUARANTEE OF RIGHTS OF DATA SUBJECTS
You may exercise your Rights including access to or erasure or correction or suspension of your personal data held by Color Platform, in accordance with Personal Data Protection Act. Color may charge a fee and postage (only in case of a request to mail the copies) for processing your request for access, etc. Such a fee and postage depend on the nature and complexity of your access request. Information on the processing fee will be made available to you.
Upon receipt of a request by you, we shall investigate the personal information in question without delay; shall take necessary measures to correct or erase or suspend as requested unless otherwise specifically provided by other statutes in relation to correction or erasure; and shall notify you of the result and
12. Measures for the Protection of Personal Information
- We take technical measures to prevent the loss, leakage, external attacks on and hacking of information.
- The personal information is secured using passwords and all files and personal data transmitted are encrypted.
- We use anti-virus solutions to prevent damages from PC viruses, and regularly updates the anti-virus programs.
- We select a security solution for the safe transmission of personal information, using the safe encryption algorithm.
- We use a security solution that blocks external attacks to prevent the leakage of personal information and monitor for invasions around the clock by installing the invasion detection system.
- The number of managers processing personal information is limited to the minimum level, and the managers are subject to continuous security training and monitoring of compliance with the personal information policy.
13. Processing of Suggestions and Complaints
We enable you to freely express opinions and raise complaints in relation to the protection of personal information. Suggestions or complaints submitted to the following contacts are immediately processed, and Users will be notified of the results.
- Data Protection Officer (DPO): Yong Uk Lee
- Websites: Colors.org
- eMail: [email protected]naver.com
We may amend this policy from time to time to ensure that this policy is consistent with any developments to the way Color Platform uses your personal data or any changes to the laws and regulations applicable to Color Platform. We will make available the updated policy on our website. All communications, transactions and dealings with us shall be subject to the latest version of this policy in force at the time.
Have a Colorful Day
Last updated: 23th May 2018