Sunny Side Up

SUNNY SIDE UP PRIVACY POLICY

  1. Introduction

    2. Sunny Side Up Privacy Policy last revised: 25 November 2021 Sunny Side Up Asia Limited (“SSU,” “Company,” “we,” or “us”) takes your privacy seriously. This Privacy Policy explains the steps we take to ensure information about you is kept secure and confidential and complies with the requirements of the Personal Data (Privacy) Ordinance (Cap. 486) of Hong Kong. Please read this Privacy Policy carefully. Once you access or use SSU, including any content, functionality, and services offered on or throughhttps://sunnysideup.io (the “Site”), you will be deemed to have read and consented to the uses of your Personal Information set out in this PrivacyPolicy. You will also be deemed to have read and accepted this PrivacyPolicy and the SSU terms and conditions of use (“Terms of Use “). You must not use the SSU Site or any services available via it if you do not accept this Privacy Policy and the Terms of Use.

  2. Personal Information We Collect

    3. “Personal Information” means information that identifies or is reasonably capable of identifying an individual, directly or indirectly, and information that is capable of being associated with an identified or reasonably identifiable individual.

    1. 2.1
      Personal Information we collect from you

      We may collect the following categories of Personal Information directly from you:

      • Identification Information such as name, email, phone number, postal address;
      • Commercial Activity such as trading activity, order activity, deposits, withdrawals, account balances;
      • Correspondence such as information you provide to us in correspondence, including account opening and customer support; and
      • Sensory Information such as images that you upload to your User Profile;
    2. 2.2
      Personal Information we collect automatically

      We may collect the following categories of Personal Information automatically through your use of our services:

      • Online Identifiers such as IP address, domain name;
      • Device Information such as hardware, operating system, browser;
      • Usage Data such as system activity, internal and external information related to SSU pages that you visit, clickstream information; and
      • Geolocation Data.

      Our automatic collection of Personal Information may involve the use of Cookies, described in greater detail below.

    3. 2.3
      Personal Information we collect from third parties

      We may collect and/or verify the following categories of Personal Information about you from third parties, including service providers and our affiliates:

      • Identification Information such as name, email, phone number, postal address
      • Transaction Information such as public blockchain data;
      • Financial Information such as bank account information, routing number, credit card number, debit card number; and
      • Additional Information at our discretion to comply with legal obligations.
    4. 2.4
      Accuracy and retention of Personal Information

      We take reasonable and practicable steps to ensure that your Personal Information held by us is (i) accurate with regard to the purposes for which it is to be used, and (ii) not kept longer than is necessary for the fulfilment of the purpose for which it is to be used.

  3. How We Use Your Personal Information

    4. We collect Personal Information about you in an attempt to provide you with the best experience possible, protect you from risks related to improper use and fraud, and help us maintain and improve our Services. We may use your Personal Information to:

    • Provide you with our Services. We use your Personal Information to provide you with our Services pursuant to the terms of our Terms of Use.
    • Comply with legal and regulatory requirements. We process your Personal Information as required by applicable laws and regulations.
    • Detect and prevent fraud. We process your Personal Information to detect and prevent fraud on your account, which is especially important given the irreversible nature of cryptocurrency transactions.
    • Protect the security and integrity of our Services. We use yourPersonal Information, including information about your device and your activity on SSU to maintain the security of your account and the SSU platform.
    • Provide you with customer support. We process your Personal Information when you contact our support team with questions about or issues with your account.
    • Market our products. We may contact you with information about our Services. We will only do so with your permission, which can be revoked at any time.
    • Other business purposes. We may use your Personal Information for additional purposes if that purpose is disclosed to you before we collect the information or if we obtain your consent.
  4. How We Share Your Personal Information

    We will not share your Personal Information with third parties, except as described below:

    • Service Providers. We may share your Personal Information with third-party service providers for business or commercial purposes, including fraud detection and prevention, security threat detection, payment processing, customer support, data analytics, InformationTechnology, advertising and marketing, network infrastructure, storage, transaction monitoring. We share your Personal Information with the service providers only so that they can provide us with the services, and we prohibit our service providers from using or disclosing your Personal Information for any other purpose.
    • You authorize us to collect and share with our payments provider Stripe your Personal Information including full name, email address and financial information, and you are responsible for the accuracy and completeness of that data.
    • Curators and Creators. In some circumstances, SSU may share your contact information with Curators and Creators to facilitate the delivery of Additional Items under the Terms of Use.
    • Affiliates. We may share Personal Information about you with our affiliates in the ordinary course of business and offering our Services to you.
    • Law Enforcement. We may be compelled to share your Personal Information with law enforcement, government officials, and regulators.
    • Corporate Transactions. We may disclose Personal Information in the event of a proposed or consummated merger, acquisition, reorganization, asset sale, or similar corporate transaction, or in the event of a bankruptcy or dissolution.
    • Professional Advisors. We may share your Personal Information with our professional advisors, including legal, accounting, or other consulting services for purposes of audits or to comply with our legal obligations.
    • Consent. We may share your Personal Information with your consent.
    • If we decide to modify the purpose for which your Personal Information is collected and used, we will amend this Privacy Policy.
  5. Cookies

    6. When you access SSU, we may make use of the standard practice of placing tiny data files called cookies, flash cookies, pixel tags, or other tracking tools (herein, “Cookies”) on your computer or other devices used to visit SSU. We use Cookies to help us recognize you as a customer, collect information about your use of SSU to better customize our services and content for you, and collect information about your computer or other access devices to: (i) ensure that your account security has not been compromised by detecting irregular, suspicious, or potentially fraudulent account activities; (ii) assess and improve our services and advertising campaigns. Please note that if you reject cookies, you will not be able to use some or all of SSU. If you do not consent to the placing of Cookies on your device, please do not visit, access, or use SSU.

  6. DIRECT MARKETING

    7. Subject to applicable laws and regulations, we may from time to time send direct marketing materials promoting services, products, facilities, or activities to you using information collected from or about you. You may also opt-out of such communications by following the directions provided in any marketing communication. It is our policy to not provide your Personal Information for those third parties’ direct marketing purposes without your consent.

  7. Information Security

    8. All payment processing and transactions are done via a secure server and data transmissions are protected using SSL encryption. Whilst we strive to protect your Personal Information, no data transmission over the Internet can be guaranteed to be totally secure and, therefore, we cannot ensure or warrant the security of any information you send to us. You provide us with information via SSU at your own risk. We do not store your payment card information, which is handled entirely by our payment processors.

  8. Contact Us

    9. If you have questions or concerns regarding this policy or our processing of your Personal Information, please feel free to email us at [email protected] or write to us at: SUNNY SIDE UP ASIA LIMITED 17/F, Fun Tower 35 Hung To Road Kwun Tong Hong Kong