Neka VC Privacy Policy

Date of Last Update: December 11, 2023

Neka VC and its affiliates (collectively, “Neka”) are committed to protecting and respecting your privacy. This privacy policy (“Privacy Policy”), together with our Terms of Use (“Terms”) governs our collection, processing, and use of your personal data. By accessing our website, you confirm that you have read this Privacy Policy and consent to the information collection and specific purposes described herein. Capitalized terms not otherwise defined herein have the meaning used in the Terms.

Definitions

As used herein:

“personal data” means any information relating to an identified or identifiable natural person (“data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person;

“processing” means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination, or otherwise making available, alignment or combination, restriction, erasure, or destruction;

“controller” means the natural or legal person, public authority, agency, or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by European Union or Member State law, the controller or the specific criteria for its nomination may be provided for by European Union or Member State law;

“processor” means a natural or legal person, public authority, agency, or other body which processes personal data on behalf of the controller;

“consent” of the data subject means any freely given, specific, informed, and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.

The legal person that determines the purposes and means of the processing of personal data is Neka VC, with a registered office at Level 42, Suntec Tower Three, 8 Temasek Blvd, Singapore 038988. Our legal department may be reached by email at legal@nekavc.com.

Why do we process your data?

We collect, process, and use personal data on our website to offer you better products and services, adapt our business processes to our users’ needs, and steer you to the most suitable product information and online applications. In particular, we process data to:

  • Provide our services efficiently and effectively;
  • Develop, enhance, market, and deliver products and services to you;
  • Find bugs;
  • Understand your needs and your eligibility for products and services; and
  • Conduct surveys

Moreover, we may directly or indirectly collect and temporarily store personally identifiable information for operational purposes, including identifying blockchain addresses or IP addresses that may indicate the use of the website from prohibited jurisdictions or by sanctioned persons or other prohibited uses.

Which personal data do we process?

When using the website, we usually only collect the personal data that your browser transmits to our server. When you view our website, we collect the following data:

  • IP address;
  • Browser type (e.g. Google Chrome, Firefox);
  • Device resolution;
  • Type of device;
  • Device name (e.g. iPhone 12 Pro Max);
  • Device brand;
  • Operating system and version (e.g. Windows 10);
  • Returning visitor or not;
  • The origin point of traffic (Direct link or search engine);
  • Geographic location.

To conduct data analysis aiming at improving the user experience of our website, we additionally process the following data from time to time:

  • Number of visits;
  • Page views;
  • Entry and exit pages (e.g. visited home exited via the contact page);
  • Search engine keywords;
  • Outlinks;
  • Downloads (if anyone saves an image from our website);
  • Content copy (anyone who copies content from our website by dragging their mouse and highlighting text);
  • Engagement and transitions (user flow);
  • Websites that direct to our website (which website directed to us);
  • Traffic from a social network;
  • Heatmaps of where a user clicks on our website;
  • Data on how fast or slow a person scrolls on our website;
  • Website load times and other performance metrics.

Based on publicly available information concerning the users’ cryptographic wallets and the connected holdings of digital assets, Neka VC may also conduct research and analyses regarding the use of the smart contracts that the user accesses through the website and the type and number of crypto-assets held by the user. The processing aims to subdivide users into different categories for statistical and research purposes.

Use of Cookies

Cookies are small text files sent to your computer to ensure the technical functionality of the website. Neka VC uses cookies in some areas of this website to make it easier for you to use the pages and to make them more personalized. Where required by law, we will use cookies only if you have given your consent.

Retention of Personal Data

We will hold your personal data only for as long as it is necessary for us to do so to achieve the purposes described in this Privacy Policy and our own legal and regulatory requirements. From time to time, we perform analysis concerning the use of our website using personal data. Please be aware that public blockchains provide transparency into transactions and Neka VC is not responsible for preventing or managing information broadcasted on a blockchain.

Security, Protection, and Use of Personal Data

Neka implements appropriate technical and organizational measures to ensure a level of security appropriate to the risk, including:

  • The pseudonymization and encryption of personal data;
  • The ability to ensure the ongoing confidentiality, integrity, availability, and resilience of processing systems and services;
  • The ability to restore the availability and access to personal data in a timely manner in the event of a physical or technical incident;
  • A process for regularly testing, assessing, and evaluating the effectiveness of technical and organizational measures for ensuring the security of the processing.

The security measures in place will, from time to time, be reviewed in line with legal and technical developments.

Recipients of Personal Data

Neka may make available the personal data that you provide to us to our affiliates and related entities, agents, representatives, service providers, and contractors for the purposes outlined in this Policy. Any information shared with such service providers is subject to the terms of this Privacy Policy. All service providers that we engage with are restricted to only using the information according to our instructions.

We also reserve the right to disclose personal data that we believe, in good faith, is appropriate or necessary to enforce our Terms of Use, take precautions against liability or harm, to investigate and respond to third-party claims or allegations, to respond to a court order or official requests, to protect security or integrity of Neka VC and to protect the rights, property, or safety of Neka VC, our users or others.

Data Subjects’ Rights

The user has the right to obtain confirmation as to whether or not personal data concerning him or her are being collected, processed, used, or disclosed. Where that is the case, the user has the right to access the personal data and all relevant information, as well as to request deletion of the personal data. Furthermore, users have the right not to receive discriminatory treatment for exercising these rights.

According to the website’s Terms of Use, users must be at least eighteen years of age, of sound mental capacity, and possess all technical knowledge necessary or advisable to understand and evaluate the risks of the website. Neka VC does not knowingly collect or store any personal information about users under 18. If you believe such information has been inadvertently processed, we will take necessary steps to remove such information from our database.

Updates

Our policies, content, information, promotions, disclosures, disclaimers, and features may be revised, modified, updated, and/or supplemented at any time and without prior notice at the sole and absolute discretion of Neka VC. If we change this Privacy Policy, we will take steps to notify all users by email or by a notice on our website, and will publish the amended Privacy Policy on the website.

Additional information for users located in the European Economic Area and in the United Kingdom
Transparency

The privacy policy informs you about the processing of personal data in accordance with articles 12, 13, and 14 of EU Regulation 2016/679 on the protection of natural persons with regard to the processing of Personal Data and on the free movement of such data and repealing Directive 95/46/ EC (“GDPR”).

Lawful Basis for the Processing of Personal Data

The GDPR requires a “lawful basis” for processing personal data. In principle, our lawful basis is established by Art. 6(1)(b) GDPR as the processing is necessary for accessing the services of the website. Moreover, pursuant to Art. 6(1)(f), the processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, in matters related to crimes and legal compliance and in order to ameliorate the efficiency and the user experience of the website. Where you have given your specific consent, according to Art. 6(1)(a) GDPR, we may also use your data for specific purposes that will be outlined from time to time.

Data Subjects’ Right

According to the GDPR, the user has the right to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her (Art. 16 GDPR); the right to obtain the erasure of personal data concerning him or her without undue delay in one of the situations outlined in Art. 17 GDPR; the right to obtain from the controller restriction of processing (Art. 18 GDPR); the right to data portability (Art. 20 GDPR); and the right to object (Art. 21 GDPR).

Complaint

Every data subject has the right to lodge a complaint with a supervisory authority, in particular in the Member State of his or her habitual residence, place of work, or place of the alleged infringement, if the data subject considers that the processing of personal data relating to him or her infringes the GDPR.

Contact

If you have any questions about this Privacy Policy or your personal data, please contact us at legal@nekavc.com.

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