PRIVACY POLICY & PERSONAL DATA USE
Lejel Labs ("LEJEL LABS" "Company", "us", "we", "our" or "ours"), understand the importance of personal data (refers to data pertaining individuals, directly or indirectly, identifiable partially or in combination with other information via electronic or non-electronic system.), including but not limited to general personal data (e.g., full name, sex, nationality, religion, or marital status, etc.), specific personal data (e.g., health, biometric, genetic, criminal records, or financial information, etc.
We endeavor to protect our users or potential users ("users", "you", "your", "individual") personal data through our compliance with the Personal Data Law and this privacy policy and personal data use for processing Personal Data (“Privacy Policy”), and by appropriately processing the Personal Data of our users. Any terms not defined herein shall refer to the definitions made under Personal Data Law.
For the purposes as defined in the below section, we will, subject to this Privacy Policy and the Applicable Laws, collect and process your personal data, as follows:
1. General personal data, including but not limited to:
i. Full name;
ii. Sex;
iii. Date of birth;
iv. Nationality;
v. Religion;
vi. Marital status;
vii. Any other personal data that may be combined to identify the user;
2. Specific personal data, including but not limited to:
i. ID;
ii. Password;
iii. Registered email address;
iv. Registered phone number;
v. Registered address/domicile;
vi. Financial information;
vii. Any criminal records; and/or
viii. Any other personal data collected upon your consent in the future (individually or collectively "Personal Data").
The abovementioned list of Personal Data has borne adequate relevance for Personal Data Processing activities and purposes. You may inquire us for the relevance of a specific Personal Data processed by LEJEL LABS.
This Privacy Policy shall be deemed as a valid agreement between LEJEL LABS and the users, and shall serve as the basis of personal data processing, commenced herewith.
The following events shall be deemed as a valid explicit consent to the processing of your Personal Data, including but not limited to collecting, processing, analyzing, storing, correcting, updating, displaying, transferring, proliferating, disclosing, omitting, and/or terminating your Personal Data ("Personal Data Processing" or "Processing"), insofar the occurrence of the following events:
1. Upon signing up for and logging in to the users' account in Lejel Labs;
2. Upon your deliberate submission of Personal Data to Lejel Labs;
3. Upon making any transaction in LEJEL LABS, including but not limited to purchase and/or sale of crypto assets available in Lejel Labs;
4. Upon accessing Lejel Labs website;
5. Upon using the features available in Lejel Labs;
6. Upon interacting either offline or online with Lejel Labs or Lejel Labs' pesonnel; and/or
7. Upon establishing any form of agreements with LEJEL LABS ("Consent").
Upon the abovementioned Consent, you shall also be deemed to have consented to the Personal Data Processing, which may be delegated, from time to time, to a third-party as the Personal Data Controller or Personal Data Processor, provided that such third-party bears the same degree of obligation to maintain the confidentiality of the Personal Data as enshrined under this Privacy Policy.
We will collect Personal Data during your course of dealings with LEJEL LABS in any way or manner, including pursuant to any transactions, any event, and/or communications made from or between LEJEL LABS and users, in an appropriate manner, not limiting to the use of Personal Data for performance of contract, entering into contract, legal obligation, vital interests, and administration of justice.
The collection of your Personal Data by LEJEL LABS may be mandatory or voluntary in nature depending on the Purposes for which your Personal Data is collected. Wherein your Personal Data is obligatory to be disclosed and furnished to LEJEL LABS, and you fail or unilaterally choose not to furnish to us with such data, or do not consent to the purposes of the Personal Data Processing, we will not be able to provide products and/or services or otherwise process any transaction with you.
The Personal Data provided to LEJEL LABS by way of Consent pursuant to any transaction between LEJEL LABS and users will only be processed for the following purposes (“Purposes”):
1. to communicate with You;
2. to maintain and improve customer relationship;
3. to assess, process and provide Product, Services and/or facilities to You;
4. to administer and process any payments related to Product, Services and/or facilities requested by You;
5. to establish your identity and background;
6. to respond to Your enquiries or complaints and resolve any issues and disputes which may arise in connection with any dealings with us;
7. to provide You with information and/or updates on our Product and/or Services;
8. for direct marketing purposes via email, social media and/or any other appropriate communication channels;
9. for internal administrative purposes;
10. to send You seasonal greetings messages from time to time;
11. to monitor, review and improve our Product and/or Services;
12. to process any payments related to Your commercial transactions with us;
13. to process and analyze Your Personal Data either individually or collectively with other individuals;
14. to conduct market research or surveys, internal marketing analysis, customer profiling activities, analysis of User patterns and choices, planning and statistical and trend analysis in relation to our Product and/or Services;
15. to share any of Your Personal Data with the auditor for our internal audit and reporting purposes;
16. to share any of Your Personal Data pursuant to any agreement or document which You have duly entered with us for purposes of seeking legal and/or financial advice and/or for purposes of commencing legal action;
17. to share any of Your Personal Data with our joint venture/business partners to jointly develop products and/or services or launch marketing campaigns;
18. to share any of your Personal Data with insurance companies necessary for the purpose of applying and obtaining insurance claims, if necessary;
19. for any recruitment processes;
20. for audit, risk management and security purposes;
21. for detecting, investigating and preventing fraudulent, prohibited or illegal activities;
22. for enabling us to perform our obligations and enforce our rights under any agreements or documents that we are a party to;
23. to transfer or assign our rights, interests and obligations under any agreements entered into with us;
24. for the compliance to the Applicable Laws, court order, guideline, circular letter, or policy, whether or not LEJEL LABS acts as the Personal Data Processor and/or Personal Data Controller;
25. to enforce or defend our rights and/or your rights under, and to comply with, our obligations under the Applicable Laws; and
26. for other purposes required to operate, maintain and better manage our business and your relationship with us, which we notify you of at the time of obtaining your consent (collectively "Purposes").
You hereby agree that the above Purposes, individually or collectively, have been reasonably informed to you for the Personal Data Processing conducted or will be conducted by LEJEL LABS.
LEJEL LABS will not disclose, furnish, or transfer the Personal Data obtained from the users to any third-parties within the authorized jurisdiction, unless where mandatory and/or necessary for the purposes elaborated above, without your prior consent, except where:
1. You have consented to the Personal Data Processing governed under this Privacy Policy, including by agreeing to this Privacy Policy;
2. It is necessary for the preservation of life, body or property, and the relevant consent(s) cannot be easily obtained;
3. The handling of Personal Data has been entrusted in whole or in part to a third-party as the Personal Data Processor within the scope necessary to fulfill the purposes of Processing (such third-party shall have the same degree of obligation to keep and maintain the Personal Data as confidential from time to time, and LEJEL LABS shall take measures to prevent any leakage, loss, or falsification of Personal Data, such as by carefully selecting our contractors, entering into agreements with contractors regarding the handling of personal data, and directing and supervising our contractors as necessary. LEJEL LABS shall be relieved of any legal liability where leakage, loss, or falsification of Personal Data occurred due to the third-party's negligence);
4. Your Personal Data is processed on behalf of LEJEL LABS by third party intermediaries providing adequate level of data protection.
5. Personal Data is provided in connection with the succession of business due to merger or other reason;
6. LEJEL LABS as the Personal Data Controller appoints a third-party Personal Data Processor to process the Personal Data in whole or in part; and
7. Disclosure and/or furnishing of Personal Data is required by Applicable Laws or regulations, or by virtue of court order.
Users of LEJEL LABS shall have, among others, the following rights to:
1. be informed of Personal Data, basis and purpose of Personal Data Processing, LEJEL LABS's accountability as the Personal Data Controller, and whether Personal Data pertaining to you are being or have been processed;
2. complete, update, and/or correct any false Personal Data in accordance with the purpose of Personal Data Controller;
3. to the extent that the Applicable Laws allow, reasonable access to the Personal Data and be furnished of a copy of such information, which are being or have been processed, thereof;
4. terminate and/or end the processing of your Personal Data, subject to the Applicable Laws and regulations;
5. withdraw the consent which previously has been given to LEJEL LABS as the Personal Data Controller;
6. reserve and pursue your legal rights to claim for damages and be entitled of compensation due to breach of Personal Data in accordance with the Applicable Laws;
7. be furnished of the following information before the commencement of Personal Data Processing:
i. Legality of Personal Data Processing;
ii. Purpose of Personal Data Processing;
iii. Types and relevance of which such information is being processed;
iv. Retention period of the documents, in which Personal Data is contained;
v. Details and description of the Personal Data to be or have been processed;
vi. Time frame of which Personal Data will be processed;
vii. Rights of the owner of the Personal Data, inter alia access to the Personal Data, right to correct, update, request for a copy of, withdraw the consent in whole or part to the Processing, file an objection against the Processing, etc; and
viii. etc., in accordance with Personal Data Law.
Users may exercise their rights under points 2-5 above by submitting a written request to LEJEL LABS, as further governed under the next section.
Notwithstanding the preceding, we reserve our rights to rely on any statutory exemptions and/or exceptions to collect, use and disclose your Personal Data.
This Privacy Policy shall be effectively in force since the date of your Consent ("Effective Date"), upon which LEJEL LABS shall have the immediate right to process your Personal Data until the date where you no longer exercise or conduct any action of Consent in the above section ("Expiry Date").
LEJEL LABS shall have the right to retention of your Personal Data for 5 years since the Expiry Date ("Retention Period") for the following purposes:
1. Archival purposes;
2. Compliance to the Applicable Laws, including but not limited to completion of reporting and audit process, surveillance to suspicious transaction (prevention and eradication of money laundering activities);
3. Business development and marketing activities; and/or
4. Any other purposes to the extent allowed under the Applicable Laws.
Upon expiry of the Retention Period, LEJEL LABS shall, unless otherwise consented by the user, destroy the original and any copy of users' Personal Data.
Users of LEJEL LABS may exercise their rights to request for a copy of, correction, update of their Personal Data through their respective user account in LEJEL LABS website, within the effective period of this Privacy Policy.
For omission, withdrawal (in full or in part) of consent, and/or termination of use of Personal Data, Customer may request, and upon the receipt of such request, we will promptly respond within reasonable time frame to such requests upon confirming the eligibility of the requester through prescribed procedures. For any inquiries regarding Personal Data, please contact our Customer Service at the following contact details: support@lejellabs.io
Please be informed that communications over the internet (e.g., emails, or webmails) are not secure, unless they have been encrypted. Your communications may be routed through a number of countries before being delivered – this is the nature of the World Wide Web/Internet. We hereby declare that we do not assume the responsibility for any unauthorized access or interception or loss of Personal Data, beyond our reasonable control, and shall be exempted from any liability or legal claim resulting from any unforeseeable breach of Personal Data beyond our reasonable control.
Please beware of certain promotional/marketing activities through third-party applications/websites/companies. Any disclosure of your Personal Data through third-party avenues, including their privacy practices and operation of the websites, neither fall within the scope of this Privacy Policy, nor our reasonable control, and may only be disclosed by your actions. We will not disclose any of your Personal Data to those third-party companies.
We do not endorse or make any representations about any third-party sites that may be accessible through the sites. Third-party advertising networks may issue their separate cookies to your hard drive when serving advertisements. We encourage you to review the privacy policy of any company before submitting your Personal Data. The Personal Data you choose to give to unrelated third-parties is covered by their privacy policies, not this Privacy Policy.