1.1 At Headquarters, we respect the privacy and confidentiality of the personal data of our clients, customers, visitors and all others whom we interact with. We are committed to ensuring that all personal data provided to us remains secure, and is only utilised for purposes that our customers have consented to.
1.4 Headquarters is a web-based software-as-a-service platform which helps users who have created Headquarters accounts (“User(s)”) to share their content such as information, wallet addresses, files (“Content”) and analyse their pre-existing customers, prospective customers and third parties (“Viewer(s)”) on the basis of the content viewed by them. The Viewers are the non-registered users of the Services provided by Headquarters. We process your data in accordance with the applicable laws and regulations following industry best practices.
4.1 We may collect different types of Personal Data from or about you depending on how you use the Services:
4.2 In addition to the circumstances set out at Clause 4.1 above, we also receive your Personal Data when you:
4.3 In connection with the Services, and to the extent permitted by applicable laws (including Data Protection Laws), we may also be collecting from sources other than yourself, your Personal Data, for one or more of the Purposes, and thereafter using, disclosing and/or processing such Personal Data for one or more of the Purposes.
5.1 In connection with your use of the Website or the Services, we may collect the following Personal Data from you:
5.2 Note on collection of your blockchain wallet identifier: We collect the blockchain wallet addresses for each cryptocurrency holding that you connect to the Services and the associated transaction history, including the dates and amounts of each transaction. Depending on how you configure your Headquarters Account, we may pull the transaction history directly from the blockchain, collect it from the exchange that processed the transaction for you (if you give us read access to your account at the relevant exchange) or get it from materials or information you upload through the Services.
5.4 Note on collection of your national identification number (e.g. NRIC for Singapore Users): We are fully aware of the sensitive nature of your national identification number, and we only collect, use and disclose such information to the extent necessary under applicable laws and regulations, as well as in order to accurately establish and verify your identity to a high degree of fidelity. Please refer to the sections below for further information on how we use, disclose and maintain your Personal Data.
6.1 We may process and use your Personal Data for the following purposes:
6.2 Our legal basis to process and use the Personal Data of Users as the Data Controller is where:
6.4 Your Personal Data is processed at Headquarters’ operating offices and in any other places where the parties involved in the processing are located. Depending on the User's location, transfers of Personal Data may involve transferring the User's Personal Data to a country other than their own.
Within our organization, access to your data is limited to those persons who require access in order to provide you with the Services, which you purchase from us, to contact you, and to respond to your inquiries, including requests for refund. Those staff members may be on teams such as: marketing, events, product development, customer support. Employees only have access to data that is relevant to their team, on a ‘need to know’ basis.
8.1 We may need to disclose your Personal Data to trusted third-parties, whether located within or outside Singapore, for one or more of the Purposes, as such third-parties, would be processing your Personal Data for one or more of the above Purposes (“Third-Party Processors”). In this regard, you hereby acknowledge, agree and consent that we are permitted to disclose your Personal Data to such Third-Party Processors (whether located within or outside Singapore) for one or more of the above Purposes and for the Third-Party Processors to subsequently collect, use, disclose and/or process your Personal Data for one or more of the above Purposes. Without limiting the generality of the foregoing, such Third-Party Processors include:
8.2 Where we disclose your Personal Data, we will do so only in accordance with Data Protection Laws. This includes taking steps to ensure the security and privacy of your Personal Data, and where required, it will be subject to contractual terms ensuring the security and protection of any Personal Data under any sub-processor or data intermediary, whether within or outside of Singapore.
8.4 We may access, preserve and disclose your Personal Data in response to a request for information if we believe disclosure is in accordance with, or required by, any applicable law, regulation, legal process, audits or governmental request. We may also disclose information about you if we believe that your actions are inconsistent with our Headquarters Terms of Service or related guidelines and policies, or if necessary to protect the rights, property, or safety of, or prevent fraud or abuse of, Headquarters or others.
9.1 Security of your Personal Data is important to us. We will put in place reasonable security arrangements to ensure that your Personal Data is adequately protected and secured. Appropriate security arrangements will be taken to prevent any unauthorised access, collection, use, disclosure, copying, modification, leakage, loss, damage and/or alteration of your Personal Data. However, we cannot assume responsibility for any unauthorised use of your Personal Data by third-parties which are wholly attributable to factors beyond our control.
9.2 We will put in place measures such that your Personal Data in our possession or under our control is destroyed and/or anonymised as soon as it is reasonable to assume that (i) the purpose for which your Personal Data was collected is no longer being served by the retention of such Personal Data; and (ii) retention is no longer necessary for any other legal or business purposes.
Our Website and Services are not directed to children under the age of sixteen and we do not knowingly collect Personal Data from children or distribute such information to third parties. We screen users who wish to provide personal information in order to prevent children from providing such information. If we become aware that we have inadvertently received Personal Data from a child, we will delete such Personal Data from our records. If we change our practices in the future, we will obtain prior, verifiable parental consent before collecting any Personal Data from children.
11.2 Google Analytics is a web analytics service which undertakes the gathering, collection and analysis of data about the behaviour of visitors to websites. Among other things, a web analytics service collects data on which website a data subject has come to a website from (so-called referrers) and is mainly used to optimise a website and for the cost-benefit analysis of internet advertising.
11.3 You can prevent the storage of cookies by a corresponding setting of your browser software; however, please note that if you do this, you may not be able to use all the features of the Website to the fullest extent possible.
11.5 The Website also uses Google Analytics performance reports relating to demographics and interests and reports on Google Display Network impressions. You can disable Google Analytics for display advertising and customize the ads on the Google Display Network by visiting the ad settings at this link: https://adssettings.google.com.
11.6 For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: https://policies.google.com/privacy.
11.7 We also encourage you to review Google's policy for safeguarding your data: https://support.google.com/analytics/answer/6004245.
12.1 You should only provide us with Personal Data of third parties where expressly permitted under the Headquarters Terms of Service. Should you provide us with Personal Data of any individual other than yourself, you represent, undertake and warrant to us that:
The Website may contain links to third-party websites and applications whose data protection practices may differ from ours. We are not responsible for the content and privacy policies of these third-party websites and applications, and we encourage you to consult their privacy policies before accessing or using the third-party websites and applications.
14.3 We may be prevented by law from complying with any request that you may make. We may also decline any request that you may make if the law permits us to do so.
14.5 We may charge you a fee for responding to your request for access to your Personal Data which we hold, or for information about the ways in which we have (or may have) used your Personal Data. If a fee is to be charged, we will inform you of the amount beforehand and respond to your request after payment is received.
15.2 Should the changes affect the processing activities performed on the basis of your consent, Headquarters shall collect consent from you, where required under Data Protection Laws.