Privacy Policy

Privacy Policy

Pomerium (hereinafter the "Company") strives to protect users' personal information. All the personal information that the Company holds is collected, used, disclosed, and protected according to the Singapore Personal Data Protection Act (“PDPA”). When a user visits a website indicating a link to the personal information protection policy or uses the service, he/she is considered to agree to the contents of the privacy policy.

1. Personal Information to be Collected

Personal information, as defined in the PDPA, refers to information about an individual that can be identified in certain information or in relevant information and other information that the Company can access or has a possibility to access. Personal information that the Company may hold includes:

i. Google account login information, referral code

ii. MetaMask wallet account information and connection information

iii. User's service use history

iv. Details on the transaction between the user and the Company

v. Third-party wallet addresses and transaction information

vi. Additional information provided for participation in the event

vii. Additional information provided for consultation processing when inquiries and consultations

viii. SNS account linking information (Twitter, Discord, Telegram, etc.)

ix. Other personal information that users may provide from time to time

The Company collects information directly from users as much as possible. The Company collects, uses, and discloses personal information only when permitted in accordance with the PDPA or other applicable law. The Company can collect not only the personal information that the user provides, but also certain information relating to the user which is not considered as personal information according to the PDPA. Information such as terminal information (OS, screen size, device ID, phone model, terminal model name), IP address, cookies, visit date & time, unauthorized use records, service use records, etc. can be automatically generated and collected while using PC web homepage or mobile web/app. Users can accept or reject cookies by modifying their browser settings.

2. Use of Personal Information

The personal information that the Company collects is used only for the purposes of providing the services of Pomerium, including member management, service provision/improvement, new service development, etc. The Company collects the minimum personal information necessary for providing services as follows through the website or individual applications or programs while registering membership or using service.

i. User identification/confirmation of intention to join, identification, prevention of unauthorized use

ii. Provision of various services, treatment of inquiries or complaints, and delivery of notices

iii. Prevention and sanction against acts that disrupt the smooth operation of the service (including account theft and unauthorized use, etc.)

iv. Development of new services and utilization for marketing

v. Service use records, statistics on access frequency and service use, service environment establishment in terms of privacy protection, and use for service improvement

vi. Anti-money laundering, fraud prevention & detection

User’s personal information may be used at the Company's sole discretion in exceptional circumstances, such as national emergencies, security concerns, or other circumstances that are regarded as reasonable. For the above purposes, the Company may contact users through other means of communication, such as e-mail. The Company tries further to observe the EU's General Data Protection Regulation (“GDPR”), particularly to protect the personal information of data subjects within the European Union. A Company or a third party that uses personal information may not belong to a country within the European economic zone (“EEA”) as needed. The user recognizes that the protection of personal information provided by the corresponding country may not be an appropriate level of protection for the personal information determined by the European Commission.

3. Provision of Personal Information

The Company does not provide the user's personal information to a third party except when there is a user's separate consent or when laws and regulations stipulate it.

4. Other Companies’ Links

The Company’s platform may include links to websites of the Company’s partner network, advertisers, etc. These websites and all the services that users can access through them have their own privacy policies, and the Company does not take any responsibility for personal information that may be collected through them.

5. Destruction of Personal Information

The Company holds the user's personal information for the period required according to the purpose of collection or by applicable laws. If users withdraw their joining, the Company will keep their personal information in a separate database in accordance with applicable laws. When a user complains about the use of personal information before the user withdraws his/her joining, the Company may extend the possession of personal information for up to 3 years from the date when the complaint is presented. The Company can anonymize users' personal information for the purpose of research or statistics, in which case the Company can use the information indefinitely without further notice to the user. Users can contact the Company to request information related to their personal information. The Company will try to respond within 30 days of receiving the request and will respond in accordance with applicable laws. If the Company accepts the user’s request to withdraw his/her personal information, the Company will permanently delete all electronic files and destroy any physical documents disclosing the user’s personal information. Those who are under the age of 14 cannot use the service of Pomerium. The Company does not request or collect information from anyone under the age of 14. If the Company identifies users who are under the age of 14, it will immediately suspend their account and delete their personal information.

6. Security

Although there are inherent risks in the electronic data transmission over the Internet, the Company takes proper proactive measures to avoid exposing users' personal information to unnecessary risks. The measures are as follows:

i. The Company is encrypting users’ personal information.

ii. The Company is installing and monitoring related systems in an accessible area to protect personal information from hacking or computer virus. The Company blocks the use of external Internet services with a PC for business within the Company.

iii. The Company minimizes the person who can access personal information and prepares and continuously checks the systematic criteria for the creation, change, and access to passwords for the database system that stores personal information and the system that processes personal information.

7. Modification of Privacy Policy

The Company may modify the privacy policy for the purpose of reflecting changes in laws or services. The updated privacy policy will be posted on the Company's website with the date of the modification. If there is a material change in user rights due to a change in the policy, the Company will notify the user of it at least 30 days in advance. Unless otherwise requested or rejected by the user, the user is considered to agree to the policy change.

8. Inquiry

If there are inquiries, complaints, advice, and other matters related to personal information protection that occur while using the service, please contact the person in charge of personal information protection.

Contact: [e-mail]

9. Governing Law

The privacy policy follows the Singapore’s Personal Data Protection Act. All the articles are governed by the laws of the Republic of Singapore, and users agree to follow the exclusive jurisdiction of the courts of Singapore.

This policy will be applied from on August 6, 2024.