Privacy Policy

Last Updated: 2 Jun 2022

Thank you for visiting abtdex.com (collectively, “the Site”). The Site is operated for ABT Ltd. (“ABT Ltd.”) under a license and services arrangement with ABT Ltd. (“ABT”, and together “we,” “ our,” or “us”). This Data Protection Notice (“Notice”) sets out the basis which ABT may collect, use, disclose or otherwise process personal data of our customers in accordance with the Personal Data Protection Act (“PDPA”).

This Privacy policy (“Privacy Policy”) together with ABT’s Cookie Policy (which can be found at https://abtdex.com/cookie-policy) (“Cookie Policy”) set out the basis on which any Personal Information we collect from you (“you”, “your”, or “ customer”), or that you provide to us, will be processed by us. By “Personal Information”, we mean any information which, either alone or in combination with other data, enables you to be directly or indirectly identified, for example your name, email address, username, contact details or any unique identifier such as an IP address, device ID or other online identifier.

Please read the following carefully to understand what data we collect, how that data is used and the ways it can be shared by us. If you do not wish for your Personal Information to be used in the ways described within this Privacy Policy then you should not access or use the Site or use the services, functions, or features offered from time to time on the Site (“ Services”).

What information do we collect?

• Information you give us. We collect information about you when you:
• Register for an account with ABT Dex Limited. on the Site or on “Supplier Deposit” tab on ABT Dex Limited.;
• Use the Support Centre on the Site; or
• Correspond with us by phone, e-mail or otherwise. The Personal Information most often collected and maintained in a customer file includes customer identification, transaction history including records of payments made.
• Information we collect about you. Each time you use the Services, we may automatically collect the following information, which may be considered to be Personal Information when combined with other information about you:
• Technical information, including the Internet protocol (IP) address used to connect your computer or other device to the Internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; and
• Information about your visit, including the dates and times you use the Site length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call the contact phone number provided on our Site.
• Special categories of data. We do not collect any special categories of Personal Information about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data).

Purposes for which we collect your Personal Information.

If you wish to transact on and use the Site or use the Services, ABT will collect information about you for the purposes set out below. Information you provide to ABT may be used to:

• establish and maintain a responsible commercial relationship with you;
• understand your needs and your eligibility for products and services;
• inform you about trading and financing features;
• provide information to you about developments and new products, including changes and enhancements to the Site;
• develop, enhance, and market products and services, and provide products and services to you;
• process billing and collection of any fees;
• conduct surveys and get feedback from you;
• deliver products and services to you;
• provide you with news and other matters of general interest to you as an ABT customer;
• meet ABT’s legal and regulatory requirements; and,
• permitted or required by the PDPA or other supporting laws

It is important that the Personal Information we hold about you is accurate and current. Please keep us informed if your Personal Information changes during your relationship with us.

Information we collect about you.

We use IP addresses to analyze trends, administer the Site, track customer movements, and gather broad demographic information for aggregate use. For systems administration and detecting usage patterns and troubleshooting purposes, our web servers also automatically log standard access information including browser type, access times/open mail, URL requested, and referral URL. This information is not shared with third parties and is used only within ABT and their affiliates on a need-to-know basis. We reserve the right to block access for any customer accessing the Site via a proxy service intending to conceal originating identity. This includes access via the Tor anonymity network.

Legal bases on which we process your Personal Information.

We will process your Personal Information on the following grounds:

• where it is necessary for us to perform pursuant to your contract with ABT or in your interests; and/or
• where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. Legitimate interests means the interest of our organization to conduct and manage our business to enable us to better serve you and provide you with a secure experience on the Site.

We ensure that we balance any potential impact on you and your rights before we process your Personal Information for our legitimate interests. We do not use your Personal Information for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Generally we do not rely on consent as a legal basis for processing your Personal Information other than in relation to our use of cookies (please refer to our Cookies Policy) or when we send third party direct marketing communications to you via email or text message.

Security and confidentiality

• We are committed to protecting your privacy. Internally, only people with a business need to know Personal Information, or whose duties reasonably require access to it, are granted access to customers’ Personal Information. Such individuals will only process your Personal Information on our instructions and are subject to a duty of confidentiality.
• The Site’s systems and data are reviewed periodically to ensure that you are getting a quality service and that leading security features are in place. We have put in place procedures to deal with any actual or suspected data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Disclosures

You agree that we have the right to share your Personal Information with:

• Any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries including their respective contractors, affiliates, employees or representatives.
• Our service providers, to the extent necessary to supply the Services to you.
• Selected third parties, including analytics and search engine providers that assist us in the improvement and optimization of the Services
• Authorities and law enforcement agencies worldwide either when ordered to do so or on a voluntary basis if this appears reasonable and necessary to us (please refer to our Law Enforcement Requests Policy).

We will also disclose your Personal Information to third parties:

• If ABT or substantially all of its assets are acquired by a third party, in which case Personal Information held by it about its customers will be one of the transferred assets.
• If we are under a duty to disclose or share your Personal Information in order to comply with any legal obligation, or in order to enforce or apply our Terms of Sale and Service and other agreements; or to protect the rights, property, or safety of us, our clients, or others.

We reserve the right to share current and historical bids, asks, and market prices; opening and closing range prices; high–low prices; trade prices; estimated and actual trade volumes; settlement prices; and other aggregate data and information related to the digital tokens purchased or redeemed on the Site.

Transfers

• Your Personal Information will be stored in Ireland and/ or Switzerland and may be transferred worldwide.
• Personal Information and other data may therefore be exported outside of the jurisdiction in which you reside.Your Personal Information may be processed and stored in a foreign country or countries.Under those circumstances, the governments, courts, law enforcement, or regulatory agencies of that country or those countries may be able to obtain access to your Personal Information through foreign laws.You need to be aware that the privacy standards of those countries may be lower than those of the jurisdiction in which you reside.
• Unfortunately, the transmission of information via the Internet is not completely secure.While we do our utmost to protect your Personal Information, we cannot guarantee the security of your data transmitted to us over email or through the Site; any transmission is at your own risk.Once we have received your data, we will use strict procedures and security features to try to prevent unauthorized access.

Your rights

All Customers. You may access and verify your Personal Information held by ABT Dex Limited. by submitting a written request to: [email protected]

Contact

Questions, comments and requests regarding this Privacy Policy should be addressed to [email protected].