Privacy Policy

This Privacy Policy describes the policies and procedures of Mamoru Global Limited (“Mamoru”, “We” or “us”) in terms of the collection, use and disclosure of your information when you use the Services and tells you about your privacy rights and you are protected.

We use your Personal Data to provide and improve the Services. By using the Services, you agree to the collection and use of information in accordance with this Privacy Policy.

Definitions

For the purposes of this Privacy Policy:

Account means a unique account created for you to access our Services or parts of our Services.

Device means any device that can access the Services such as a computer, a cellphone or a digital tablet.

Personal Data is any information that relates to an identified or identifiable individual.

Services refers to www.mamorucrypto.io and the associated application program interface or mobile applications.

Service Provider means any natural or legal person who processes the data on behalf of Mamoru. It refers to third-party companies or individuals employed by Mamoru to facilitate the Services, to provide the Services on behalf of Mamoru, to perform services related to the Services or to assist Mamoru in analyzing how the Services are used.

Usage Data refers to data collected automatically, either generated by the use of the Services or from the service infrastructure itself (for example, the duration of a page visit).

Website refers to www.mamorucrypto.io

Types of Data Collected

While using our Services, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you. Personal identifiable information may include, but is not limited to:

  1. Full name, date of birth, nationality, gender, signature, proof of address (e.g. utility bills), phone numbers, residential / office address and email address.
  1. Identification document such as passport, driver license, national identity card and the relevant particulars prescribed therein.
  1. Corporate supporting documents including Certificate of Incorporation, Certificate of Incumbency, company search report and constitution documents (e.g. Articles of Incorporation).
  1. Bank account information, regular statements and transaction history over a certain period of time.

Usage Data are collected automatically. Those may include, but is not limited to:

  1. Internet Protocol address (e.g. IP address),
  1. browser type and browser version,
  1. the pages of our Services that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When you access the Services by or through a mobile device, we may collect certain information automatically, including but not limited to, the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data.

Use of Personal Data

We may use Personal Data for the following purposes:

  1. To provide and maintain our Services, including the monitoring of the usage of our Services.
  1. To manage your Account: The Personal Data you provide can give you access to different functionalities of the Services that are available to you as a registered user.
  1. To contact you: through emails, telephone calls, SMS, or other equivalent forms of electronic communication, we provide you with updates related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
  1. To protect you: we rely on the use of Personal Data to protect our Services against cybersecurity issues such as spam, phishing and Distributed Denial of Service (DDoS) attacks.
  1. To protect us: we are required to comply with all applicable legal and regulatory requirements relevant to our provision of Services.
  1. To provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information.
  1. To manage your requests: we attend and manage your requests to us on an on-going basis.
  1. For other purposes: we may use your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Services and your experience.

We may share your personal information in the following situations:

  1. With Service Providers: We may share your personal information with Service Providers to monitor and analyze the use of our Services.

In preventing fraud by utilizing identity verification services, Personal Data will be furnished to a third-party Service Provider who provides identity verification and fraud prevention services.

We use Twilio's services for the purpose of receiving and sending text messaging from / to you. For more information about Twilio's Terms of Service and Messaging Policy, please visit the following links: Terms of Service and Messaging Policy.

We use SMS.to's services for the purpose of receiving and sending text messaging from / to you. For more information about SMS.to's Terms of Service and Privacy Policy, please visit the following links: Terms of Service and Privacy Policy.

We use Vonage's services for the purpose of receiving and sending text messaging from / to you. For more information about Vonage's Terms of Use and Privacy Policy, please visit the following links: Terms of Use and Privacy Policy.

We use the hCaptcha anti-bot service (hereinafter "hCaptcha") on our website. This service is provided by Intuition Machines, Inc., a Delaware US Corporation ("IMI"). hCaptcha is used to check whether the data entered on our website (such as on a login page or contact form) has been entered by a human or by an automated program. To do this, hCaptcha analyzes the behavior of the website or mobile app visitor based on various characteristics. This analysis starts automatically as soon as the website or mobile app visitor enters a part of the website or app with hCaptcha enabled. For the analysis, hCaptcha evaluates various information (e.g. IP address, how long the visitor has been on the website or app, or mouse movements made by the user). The data collected during the analysis will be forwarded to IMI. hCaptcha analysis in the "invisible mode" may take place completely in the background. Website or app visitors are not advised that such an analysis is taking place if the user is not shown a challenge. Data processing is based on Art. 6(1)(f) of the GDPR (DSGVO): the website or mobile app operator has a legitimate interest in protecting its site from abusive automated crawling and spam. IMI acts as a "data processor" acting on behalf of its customers as defined under the GDPR, and a "service provider" for the purposes of the California Consumer Privacy Act (CCPA). For more information about hCaptcha and IMI's privacy policy and terms of use, please visit the following links: Privacy Policy and Terms of Service.

  1. For business transfers: We may share or transfer your Personal Data in connection with, or during negotiations of, any merger, sale of Mamoru’s assets, financing, or acquisition of all or a portion of our business to another company.
  1. With Affiliates: we may share your information with our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include our parent company and any other subsidiaries, joint venture partners or other companies that we control or that are under common control with us.
  1. With business partners: We may share your information with our business partners to offer you certain products, services or promotions.
  1. With regulators: We may share your personal information with the appropriate regulators whenever necessary; any financial dispute resolution scheme to which we subscribe. This includes law enforcement bodies; regulatory agencies; courts; arbitration bodies; and dispute resolution schemes. This may be both in the jurisdiction where we incorporate and internationally, as may be required by law.
  1. With other users: when you share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside.

You should note that you are not obliged to give your personal information to us. If you choose not to do so, we may not be able to provide our services, or your access to our services may be limited.

Except where disclosure of your personal information is required by law or requested by you, we will generally require any third party which receives, or has access to, personal information to protect it and to use it only to carry out the services they are performing for you or for us, unless otherwise required or permitted by law.

Retention of Your Personal Data

We will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable anti-money laundering and counter-terrorist financing regulations), resolve disputes, and enforce our legal agreements and policies.

We will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Services, or we are legally obligated to retain this data for longer time periods.

In general, personal information relating to you is held for at least a period of five years after we cease providing you with our Services.

Transfer of Your Personal Data

Your information, including Personal Data, is processed at Mamoru’s operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of the jurisdiction where you are residing. Further, the data protection laws by which Mamoru complies may differ than those in your residing jurisdiction.

Your consent to this Privacy Policy followed by your submission of such Personal Data represents your agreement to that transfer.

We will take all steps reasonably necessary to ensure that your Personal Data is treated securely and in accordance with this Privacy Policy and no transfer of Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Personal Data and other personal information.

Withdrawal of Consent

Upon reasonable notice being given by you of your withdrawal of any consent given or deemed to have been given in respect of our collection, use or disclosure of your Personal Data, we will inform you of the likely consequences of consent withdrawal. We will cease (and cause any of our data intermediaries and agents to cease) collecting, using or disclosing your Personal Data unless it is required or authorized under applicable laws.

Law enforcement

Under certain circumstances, we may be required to disclose your Personal Data if required to do so by law or in response to valid requests by competent authorities of relevant jurisdictions where Mamoru operates.

We may disclose your Personal Data in the good faith belief that such action is necessary to:

  1. Comply with a legal obligation
  1. Protect and defend the rights or property of us
  1. Prevent or investigate possible wrongdoing in connection with the Services
  1. Protect the personal safety of users of the Services or the public
  1. Protect against legal liability

Security of Your Personal Data

The security of Personal Data is important to us, but please also keep in mind that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect the Personal Data, there’s no guarantee on the absolute security.

Links to Other Websites

Our Services may contain links to other websites that are not operated by us. If you click on a third-party link, you will be directed to that third party's site. We strongly advise you to review the Privacy Policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.

Access, Accuracy and Correction of Personal Data

You acknowledge that it’s your sole and ultimate responsibility to ensure the accuracy and correctness of your Personal Data. Please inform us as soon as possible if any changes to your Personal Data provided. You may update the accuracy or completeness of such information, and request that corrections by sending inquiries, requests and notifications to contact@mamorudigital.io.

We will usually respond to your request within 14 days. You may also request the deletion or destruction of your personal information, your account details or your transaction details by sending an email to us.

Upon your written request, we will inform you of the use and general disclosure of your personal information. Depending on the nature of your request, there may be a minimal charge for accessing your personal information.

Changes to this Privacy Policy

We may update this Privacy Policy from time to time and without prior notice at the sole and absolute discretion of us. We will notify you of any changes by Email. You are advised to review the updated Privacy Policy for any changes. Changes to this Privacy Policy are effective when they are posted.

We will let you know via email and/or a prominent notice on our Services, prior to the change becoming effective and update the "Last updated" date at the bottom of this Privacy Policy.

Contact Us

If you have any questions, comments, or concerns regarding our privacy policy and/or practices as it or they relate to the platform, please contact us at contact@mamorudigital.io. If you have a complaint about how your personal information has been used, please contact us in the first instance. If we cannot resolve your complaint to your satisfaction, you may complain to the competent authority who may investigate your complaint further."

Last updated: December 2021