1. Acceptance of Privacy Policy

1.1. This is the privacy policy (“Privacy Policy”) for Synfindo Singapore Pte. Ltd. (UEN:202225548E), a company incorporated in Singapore with its registered address at 83 Clemenceau Avenue, #02-01, UE Square, Singapore 239920 (“Synfindo”). In this Privacy Policy, “we”, “us” and “our” refers to Synfindo.

1.2. This Privacy Policy describes how we may collect, use, disclose and process your personal data when you: (i) access or use our websites (including synfindo.com or www.apixplatform.com, (including all its sub-domains) “Websites”) and services and applications provided therein; and/or (ii) provide us with your personal data.

1.3. By accessing and using our Services, you agree to be bound by the terms of this Privacy Policy which is subject to our Terms of Use, and consent to our collection, use and disclosure of your personal data in accordance with this Privacy Policy. If you do not agree to the Terms of Use and/or do not consent to such collection, use and disclosure of your personal data, please do not download, access or use our Services.

1.4. By reading and accepting this Privacy Policy you acknowledge that you have been notified of the purposes for which the data is collected and you (or your authorised representative) have provided consent to the collection and usage of your personal data for those purposes, some of which are listed under Section 5 of this Privacy Policy. We shall seek your consent before collecting any additional personal data and before using your personal data for a purpose which has not been notified to you (except where listed in this Privacy Policy, or permitted or authorised by law).

1.5. We will only use your personal data where you have given us your consent or where we have other lawful basis for doing so, and in the manner set out in this Privacy Policy.

1.6. By providing us with personal data, you acknowledge that our collection, use, disclosure and processing of personal data will be in accordance with this Privacy Policy, including, for the avoidance of doubt, the cross-jurisdictional transfer of your data. DO NOT provide any personal data to us if you do not accept this Privacy Policy.

1.7. This Privacy Policy supplements but does not supersede nor replace any consents you may have provided to us, or any other agreements or arrangements that you may have with us, in respect of your personal data.

1.8. If you have any feedback or issues in relation to your personal data, or about this Privacy Policy, or wish to make a complaint to us, you may contact our Data Protection Officer at: Email: [email protected] When you contact us, we may require that you submit certain forms or provide certain information, including verification of your identity, before we are able to respond.

1.9. Personal Data Protection Act 2012 of Singapore ("PDPA”) shall be the governing law for this Privacy Policy.

2. Changes to Privacy Policy

We reserve the right, at our sole discretion, to modify or update this Privacy Policy at any time and all changes will become immediately effective upon posting. Your continued access to or use of our Services after such changes have been posted shall bind you to such changes and the amended Privacy Policy. It is your sole responsibility to check this Privacy Policy regularly for changes. If you do not agree to the amended Privacy Policy, please do not continue to access or use our Services.

3. Collection of Information

3.1. “Personal data” is data that can be used to identify a natural person. The types of personal data that we may collect and store include, but are not limited to: (a) Identity and Contact Data. This includes your name, NRIC or passport number, address, contact details, telephone numbers, email address, geographic location given to us through our Website or through signing up for our mailers; (b) Profile Data. This includes: (i) unique identifiers such as your username, decentralised identifier, account number or password, and (ii) details of your use of our products and services; (c) Feedback, messages and survey responses. This includes any messaging you send us in a service request, question or concern including via email, telephone or via our Websites. (d) Verifiable Credentials containing personal data which are either issued by you (as Issuer) or to you (as Holder). “Verifiable Credentials” shall refer to tamper-evident data in a machine-readable format (i.e. expressed as structured code) that contains information/ pertains to a certain data point about a natural person or legal entity.

3.2. Personal data collected from cookies and similar technologies. We use commonly used tools to automatically collect information that may contain personal data from your computer or mobile device as you visit our Websites or in general use our services. This includes your internet protocol (IP) addresses, browser and device information, internet service provider (ISP), referring/exit pages, the files viewed on our Websites (e.g., HTML pages, graphics, etc.), operating system, date/time stamp, and/or clickstream data. We, and the parties with whom we share your personal data, may use cookies, web beacons and other similar tracking technology in connection with your access to or use of the Services and third party services. Cookies are small data files stored on your computer or mobile device which may track information about you and your access to and use of the Services. It may be possible for you to disable some but not all cookies through your device or browser settings, but doing so may affect your ability to access or use the Services.

3.3. Voluntary provision of personal data. We may collect personal data (i) that you voluntarily provide to us; or (ii) from third parties; or (iii) through your use of our (or our services provider’s) digital technologies and services. What personal data we collect depends on the purposes for which the personal data is collected and what you have chosen to provide.

3.4. Providing personal data belonging to others. In certain circumstances, you may also provide us with personal data of persons other than yourself (such as your colleagues, family members and friends). If you do so, you represent and warrant that you have brought this Privacy Policy to his/her attention, informed him/her of the purposes for which we are collecting his/her personal data and that he/she has consented to your disclosure of his/her personal data to us for those purposes and accepts this Privacy Policy. You agree to indemnify and hold us harmless from and against any and all claims by such individuals relating to our collection, use and disclosure of such personal data in accordance with the terms of this Privacy Policy.

3.5. Accuracy and completeness of personal data. You are responsible for ensuring that all personal data that you provide to us is true, accurate and complete. You are responsible for informing us of any changes to your personal data.

3.6. Minors. Our Websites and/or services are not intended to be accessed or used by children, minors or persons who have not attained the age of 18 years and therefore not able to give consent to the collection, use or disclosure of personal data (relying on the Civil Law Act and PDPC Advisory Guidelines). If you are a parent or guardian and you have reason to believe your child or ward has provided us with their personal data without your consent, please contact us.

3.7. Verifiable Credentials. You acknowledge and consent to the collection, use, disclosure, processing, transfer and storage of your personal data by us and/or third party service providers that facilitate the transactions and activities between you and other users or third parties on or through our Websites, for the purposes of generating, creating, providing, storing, processing, facilitating, transferring, transmitting and managing Verifiable Credentials. You acknowledge and consent for us (or our service providers) to disclose your data and information (including Verifiable Credentials) to third parties at your instruction and/or direction.