Last updated: 14th August, 2022

PLEASE READ THIS POLICY CAREFULLY BEFORE USING THE FLIPPY PLATFORM

The Flippy Platform (“Platform”) is made available by Psila Tech Pte. Ltd. (“our”, “us”, “we”, “Company”), having its registered office at 68 Circular Road, #02-01, Singapore 094422. In order to provide you with access to our Platform, we need to collect various data and information from you. This Privacy Policy (“Policy”) details how this data and information is collected, retained, shared, stored, and processed by us. We may revise this Policy as well as update the Platform from time to time. Please visit this page regularly to take notice of any changes we make. Continued use of the Platform after an update constitutes consent to the updated policy. If you do not agree with any part of this Policy, please stop using our Platform immediately. This Policy is incorporated within and is to be read with our Terms of Use available here. Words and phrases not defined in this Policy shall have the same meaning as provided in the Terms of Use.

Information We Collect

We collect the data you provide only to ensure that we can provide you access to our Platform in the best manner possible. By using the Platform, you consent to provide us data in the ways listed below.

1.1. Data you input: We collect the information that you actively input into the Platform:

1.1.1. Flippy Account data: We collect the data you provide to us when you create or update your Flippy Account. This includes your name, phone number, email id, and Bitbns account details and any information provided therein by you (including details of all executed orders on Bitbns, all open orders on Bitbns, rupee deposits and withdrawal history, user ID assigned by Bitbns, and email address used for creating a Bitbns account). We may require you to share further data at a later date to confirm the veracity of your information or pursuant to any additional features added to the Platform.

1.1.2. Feedback and other data: We collect and record: (i) any emails you write to us; (ii) the calls you make to our call centres and/or customer service personnel; and (iii) feedback or comments you provide to us on the Platform, including any crash reports and log reports generated by you.

1.2. Data collected from your use. We collect the following data generated owing to and pursuant to your use of the Platform:

1.2.1. Platform usage data: We collect data on your interaction with our Platform, i.e., Platform access dates and times, features or pages viewed, crashes and other system activity like the comment, like, shares and type of browser used to access the Platform, and third-party sites or services used before or in the course of interacting with our Platform. In particular, we use YouTube API services to embed YouTube videos into our Platform. We and YouTube may collect data about your interactions with YouTube videos embedded into our Platform. To learn more about how YouTube collects and handles your data, you can refer to the Google Privacy Policy available at http://www.google.com/policies/privacy.

1.2.2. Device data: We may collect data about the devices used to access our Platform, including the hardware models, device IP address, operating systems and versions, software, preferred languages, unique device identifiers, serial numbers, browser type, mobile app, file names and types, plugins.

1.2.3. Gallery and image access: We may access the media gallery on your mobile device, including without limitation, images and videos on the storage space of your phone to allow you to upload a profile picture to your Flippy Account.

1.2.4. SMS data: We may access your SMS data to verify the one-time password (OTP) sent to your mobile device.

1.2.5. Cookies, log files, web beacons and tracking pixels: We also collect information through the use of “cookies”, “log files”, “web beacons” and “tracking pixels”, and similar technologies to understand how you navigate through the Platform to learn your preferences. Cookies are small text files that web servers place on your device; they are designed to store basic information and to help websites and apps recognize your browser. We may use both session cookies and persistent cookies. A session cookie disappears after you close your browser. A persistent cookie remains after you close your browser and may be accessed every time you use the Platform. Log files track actions that occur on our Platform, and collect data including your IP address, browser type, internet service provider, referring and exit pages, and date and time stamps. Web beacons, tags and pixels are electronic files used to record information about how you browse the Platform.

1.3. Information received from third parties.

We may also be working closely with third parties (including, for example, business partners, technical sub-contractors, analytics providers such as Google Analytics) and may receive information about you from such sources. Such data may be shared internally and combined with data collected under Section 1.2 (Data collected from your use) above.

Use of Collected Data

The data we collect from you will be used for the following purposes:

2.1. For enabling the Platform. We use the data collected to enable, personalize, maintain and improve our Platform. This includes using the data to:

2.1.1. Authenticate your Flippy Account and connect it to your Bitbns account;

2.1.2. Conduct data analysis, testing, and research; and to monitor and analyze usage and activity trends;

2.1.3. Create and update your Flippy Account;

2.1.4. Perform internal operations necessary to provide you and improve our Platform, including troubleshooting software bugs and operational problems; and

2.1.5. Suggest new crypto-baskets to you, and rearrange the order in which baskets may be displayed to you.

2.1.6. Serve relevant content to you, including content served by third-parties.

2.2. For enabling customer support and communication. We use the information to provide customer support and train our customer service executives. We may further add features that allow you to call us (through the Platform or otherwise), similarly, we may also need to contact you through the Platform.

2.3. For marketing and outreach. We use the data we collect to market our Platform. This includes sharing your feedback, ratings and screen names for purely promotional and marketing purposes. Such promotion and marketing may be done via hoardings, banners, pamphlets etc.

2.4. For fraud detection and preventing misuse. We use the data we collect to detect fraudulent usage of the Platform and/or misuse of any of the features of the Platform.

2.5. For legal compliance and requirements. We use the data we collect to address claims or disputes relating to the use of our Platform, or as otherwise allowed by applicable law, or as requested by regulators, government entities, and official inquiries.

Sharing of Data

We do not share any personal data about you with any third parties unless necessary. We may enter into agreements or arrangements to enable the use of our Platform. Our agreements with third-parties impose an obligation on these third-parties to handle your personal data with the same level of protection as outlined in this Privacy Policy. We have detailed the manner in which we share the collected data below:

3.1. Service Providers. We work with third party service providers, including Bitbns, to execute various functionalities of the Platform, and we may share your information with such service providers to help us provide you with our services on the Platform.

3.2. Change in Control. While negotiating or in relation to a change of corporate control such as a restructuring, merger or sale of our assets, we may have to disclose our databases and information we have stored in the course of our operations.

3.3. Law Enforcement. We may disclose and otherwise use your personal and other information where we or they reasonably believe such disclosure is needed to:

3.3.1. satisfy any applicable law, regulation, legal process, or governmental request;

3.3.2. enforce applicable terms of use, including investigation of potential violations thereof;

3.3.3. detect, prevent, or otherwise address illegal or suspected illegal activities (including payment fraud), security or technical issues; and/or

3.3.4. protect against harm to our rights, property or safety, our users or the public, as required or permitted by law.