Privacy Policy

Last Updated: October 17, 2021

1. Our Privacy Policy

1.1. Trophee Pte. Ltd. (UEN 202117459E) (“Trophee”, “us”, “we”, or “our”), a company incorporated in Singapore, is committed to protecting and respecting your privacy.

1.2. In this Privacy Policy, unless the context otherwise requires, “Personal Data” means (a) data, whether true or not, about an individual who can be identified (i) from that data; or (ii) from that data and other information to which we have or are likely to have access, and (b) any other similar definition under any applicable personal data protection laws.

1.3. This Privacy Policy, together with our terms of use at our Terms of Use Page (the “Terms of Use”), sets out how we will collect, use, disclose and process any Personal Data and information that we collect from users such as yourself (“you”) or that you provide to us in the course of your use of the Trophee Platform (the “Platform”) accessible at (the “Website”), and the Services provided on the Platform.

1.4. Please read this Privacy Policy carefully to understand our views and practices regarding your Personal Data and how we handle it. By using the Platform, visiting or accessing our Website, signing up for an account on the Platform and/or by accessing any of the Services or available on our Platform, you accept and consent to the practices described in this Privacy Policy. You may not use the Platform if you do not accept the terms of this Privacy Policy or our Terms of Use.

1.5. All capitalised terms used and not otherwise defined in this Privacy Policy shall have the meanings set forth in the Terms and Conditions for Users or Terms and Conditions for Artists as the case may be.

2. Information we collect from you

2.1. We will collect and process the following Personal Data about you:

2.1.1. Information about you that you give us while registering for an account to use the Platform or Website, whether by filling in forms on our Platform, given to us through e-mail, or otherwise, and/or when you use our Platform or Services. Such information may include, where relevant, your full name, cryptographic public address(es), email address, contact number, and transaction data made through our Platform or Website.

2.1.2. Where appropriate and legally required, we will also collect and process Personal Data such as your identification/passport numbers to manage the AML/CFT risks associated with your use of our Platform or Services.

2.1.3. Information relating to of each of your visits to our Website including but not limited to the Internet protocol (IP) address used to connect your computer to the Internet, the IP address where payment is carried out, device types which is used to access our site and upon which payment is carried out, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform), the full Uniform Resource Locators (URL), page response times, download errors, length of visits to certain pages and methods used to browse away from the page.

2.2. We may also collect and process your Personal Data:

2.2.1 If you subscribe to our newsletters or mailing lists (if any).

2.2.2. If you provide us with comments or suggestions, request for information about our Website, our Platform or our Services, or contact us via phone, email or other forms of communication.

2.3. By using our Website, our Platform and/or our Services, you expressly consent to us collecting and processing the above types of Personal Data and information.

3. How we use your information

3.1. We may use your Personal Data in the following ways:

3.1.1. to provide the Website, the Platform and/or the Services to you which shall include the facilitation, execution, or administration of any transaction(s) requested and/or authorised by you;

3.1.2. to manage and administer the Website and the Platform and to ensure that content on our Website and our Platform is presented in the most effective manner for you and for your computer or device, which shall include the maintenance, servicing and termination of the accounts registered with the Platform;

3.1.3. for legal and compliance reasons under applicable local and any applicable foreign laws that include the conduct of due diligence procedures for opening of accounts, and ongoing monitoring and compliance purposes in accordance with our internal risk management procedures, audit/financial accounting and management reporting purposes;

3.1.4. to prevent and/or detect fraudulent behaviour or transactions or potential illegal or criminal activity as part of our efforts to keep our Website and Platform safe and secure;

3.1.5. for the enforcement of any legal or contractual rights;

3.1.6. for legal and compliance reasons, including where information is to be disclosed to law enforcement agencies and other relevant authorities for crime prevention and detection purposes;

3.1.7. to verify your identity so as to ensure the safety and integrity of the transactions made through our Platform;

3.1.8. to improve or enhance the Platform, Website, or the provision of our Services, or develop any methods or processes in relation to the above; and/or

3.1.9. to administer our Website and Platform and for internal operations, including troubleshooting, data analysis to learn about and understand the behaviour and preferences of users, testing, research, statistical and survey purposes to identify products or services which we might offer to existing and future users.

3.2. By using our Website, our Platform or our Services, you expressly consent to us collecting, using, and/or disclosing the Personal Data in the ways listed above.

3.3. If we need to collect, use and/or disclose your Personal Data for additional purposes, unless excepted by law, we will seek prior consent from you where you will be informed of the new purposes, and we will obtain your consent before such Personal Data will be collected, used and/or disclosed by us.

4. Cookie Policy

4.1. Certain features on the Website, the Platform or the Services may utilise cookie technology. A cookie is a small data file that certain websites write to your hard drive when you visit them. A cookie file can contain various types of information, including a user ID that the site uses to recognise users who visit the site and to track the pages users have visited.

4.2. The primary purpose of the use of cookies by us is to manage the Website, Platform and user experience. These cookies may be used to collect analytical data of non-personal user activity, manage personal preferences, provide relevant or timely information to you and/or offer focused advertisements. We may also use cookies to enhance your experience on our Website or our Platform or to determine user traffic patterns.

4.3. We only collect your Personal Data when you voluntarily create an account on the Platform and provide your Personal Data and consent to the specified use(s). No information transferred through cookies is used for direct promotional or marketing purposes without your consent.

4.4. Most browsers are initially set up to accept cookies; however, you can modify the settings of your browser to refuse all cookies or indicate when a cookie is being sent or you can flush your browser of cookies from time to time. If you choose to disable your cookies settings or refuse to accept a cookie, however, you may not be able to access all areas of the Website, Platform or the Services.

5 Disclosure of your information

5.1. You agree that we may disclose your Personal Data:

5.1.1. to a third party where such disclosure is reasonably necessary for the performance of any contract or agreement we enter with you;

5.1.2. to selected third parties including business partners, suppliers and sub-contractors (including any third party service providers) for the performance of any contract we enter into with them or you, including analytics and search engine providers that assist us in the running, operation, improvement and/or optimisation of our site;

5.1.3. to an Artist, Creator of the Works, User or any Third Party Service Provider in the event of any allegation or Claim or dispute relating to User Content, Mangaka Content and/or Intellectual Property Rights (as the case may be);

5.1.4. to third parties in the event that (i) we sell or buy any business or assets, in which case we will disclose your Personal Data to the prospective seller or buyer of such business or assets and/or (ii) if the Administrator or substantially all of its assets are acquired by a third party, in which case Personal Data held by it about its customers will be part of the assets transferred to such third party; and

5.1.5. if we are under a duty to disclose or share your Personal Data in order to comply with any applicable law or legal obligation, or in order to enforce or apply our Terms of Use or other agreements; or to protect the rights, property, or safety of the Platform, Website, Trophee, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction, provided always that (as far as is permitted under applicable law) the receiving party undertakes or is otherwise under an obligation to deal with, receive, use, handle, or otherwise process such Personal Data only in accordance with this Privacy Policy.

5.2. If we transfer any of your Personal Data to a country or territory outside Singapore, or to our group or affiliates companies located outside Singapore, or to a permitted third party located outside of Singapore, we will only do so if we ensure that the overseas receiving party is bound by legally enforceable obligations to afford the transferred data a standard of protection that is comparable to that under Singapore law. We will also ensure that any overseas recipient is able to provide appropriate technical and organisational measures to protect your Personal Data and its confidentiality.

6. Care of Personal Data

6.1. We will exercise care over Personal Data that is in our possession or under our control.

6.2. We will put in place sufficient administrative, technical and security measures and arrangements to protect such Personal Data in our possession or under our control to prevent (A) unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks; and (B) the loss of any storage medium or device on which your Personal Data is stored.

7. Where we store your Personal Data

7.1. We will store the Personal Data that we collect from you on internal servers that belong to us and/or our affiliated companies, and/or with commercial cloud storage providers engaged by us and/or our affiliated companies. These servers may be located in or outside of Singapore. Therefore, your data may be transferred to and stored in different jurisdictions and may also be processed by staff operating within the various countries who work for us or for one of our contractors and/or our affiliated companies.

7.2. By submitting your Personal Data, you agree to such transfer, storage or processing of your data. In such a case, we will ensure that the receiving organisations will provide a minimum standard of protection to your data that is comparable to the required protection under Singapore law.

7.3. Unfortunately, the transmission of information via the internet is not completely secure. We will take commercially reasonable steps to ensure that your Personal Data is handled securely and in accordance with this Privacy Policy and the relevant privacy laws, but are unable to guarantee the secure transmission of information via the internet.

7.4. Where we have given you (or where you have chosen) a password for your account which enables you to access certain parts of our Platform, you are responsible for keeping this password and account secure and confidential. We ask you not to share the password with anyone. If your password or account is compromised, or if you suspect that it has been compromised, please contact us by using the “Submit a request” link here immediately.

8. Your rights

8.1. You may withdraw your consent and request us to stop using and/or disclosing your Personal Data for any or all of the purposes listed in this Privacy Policy. You may do so by submitting your request(s) via email to our Data Protection Officer at the contact details provided below. We will endeavour to process your request within seven (7) business days from the day of receipt of your request.

8.2. If you have consented or signed up to receive marketing materials, you may withdraw your consent at any time and request us to stop sending you marketing materials or to stop using your Personal Data for any other marketing activities by submitting your request via email to our Data Protection Officer at the contact details provided below. We will endeavour to process your request within seven (7) business days from the day of receipt of your request.

8.3. Please note that depending on the nature and scope of your request for withdrawal of consent, we may not be in a position to continue providing the Platform or our Services to you. In our acknowledgement email to you upon your request for withdrawal of consent, we will inform you of the likely consequences of withdrawing consent.

8.4. If you do withdraw your consent, we will work with all relevant stakeholders such as data intermediaries and agents who have been authorised to collect, process or use your Personal Data to ensure that such relevant stakeholders also cease to collect, process or use your Personal Data.

9. Access to Personal Data

9.1. You may send our Data Protection Officer requests for:

9.1.1. access to Personal Data which we hold about you; and/or

9.1.2. access to information about the ways in which we use or disclose or may have used or disclosed your Personal Data for the year immediately preceding the date of your request.

9.2. Subject to unforeseen circumstances, any access request will be subject to a fee of approximately USD 50 to meet our costs in providing you with details of the information we hold about you.

9.3. If we are unable to respond to your requests within thirty (30) days after receipt of your request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to the request.

10. Accuracy of and correction of Personal Data

10.1. We will make reasonable efforts to ensure the accuracy and completeness of the Personal Data you provide to us. However, we also will require you to provide us with accurate, up-to-date and complete information. In order to ensure that the Personal Data that we maintain is accurate, you may send our Data Protection Officer at any time requests to update your information or for correction of errors or omissions in Personal Data which we hold about you.

10.2. We will generally not charge for correction requests, although we reserve the right to do so under unforeseen circumstances. If we are unable to respond to your requests within thirty (30) days after receipt of your request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to the request.

11. Data Porting Request

11.1. To the extent applicable under the Personal Data Protection Act 2012, as long as you have an existing direct contractual arrangement with us or if you are using our Platform or Services, you may send our Data Protection Officer a request for us to transmit your Personal Data, which was collected or created by us prior to the date of your request, which is in our possession or under our control, to another organisation in Singapore.

11.2. If we are unable to respond to your requests within thirty (30) days after receipt of your request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to the request.

12. Retention of Personal Data

12.1. We will cease to retain records of your Personal Data, or remove them from our records, as soon as it is reasonable to assume that:

12.1.1. the purpose for which the Personal Data was collected is no longer relevant; or

12.1.2. where you have deleted your account with us, whichever is later.

12.2. Notwithstanding the above, we may retain the archived copies of the Platform’s or Website’s content containing your Personal Data for as long as it is required by law or for other legitimate business purposes.

13. Other websites

13.1. Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers, affiliates and third party service providers.

13.2. If you follow a link to any of these websites, please note that these websites will likely have their own privacy policies, and that we do not accept any responsibility or liability for your access of these websites. Please check their individual privacy policies for more information on how your Personal Data will be handled by these websites.

14. Changes to our Privacy Policy

14.1. We reserve the right to amend this Privacy Policy at any time without any prior notice to you.

14.2. Any changes we make to our Privacy Policy in the future will be posted on this page or by any other means in our sole discretion. You agree that it is your responsibility to check periodically for any updates or changes to our Privacy Policy.

15. Contact Information

15.1. If there are any questions or concerns related to this Privacy Policy or our data protection practices generally or if you wish to make a request for access, correction, or porting of your Personal Data, please contact our Data Protection Officer by using the “Submit a request” link here.

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