PRIVACY AND DATA PROTECTION POLICY

The RealFuel website, having a domain address of www.RealFuel.io (“Site”), is owned and operated by RealFuel SG Pte Ltd, a Singapore private limited company (“RealFuel”).  

To help you understand the way in which we collect, use and disclose the personal data that you provide to us, we have created this Privacy and Data Protection Policy (“Privacy Policy” or “Policy”) The Privacy Policy discloses the type of personal data that we collect and how we use it, the choices you can make about the way your information is collected and used, and the way we protect your personal data. In this policy, “Personal Data” shall have the meaning ascribed to it in the EU General Data Protection Regulation 2016/679/EU (“GDPR”).

 

By signing up at RealFuel, you agree that RealFuel may share your Personal Data with Investacrowd Limited, a British Virgin Islands company limited by shares (“InvestaCrowd”), which operates a licensed real estate crowdfunding platform www.InvestaCrowd.com where RealFuel tokens will act as the native currency. RealFuel and InvestaCrowd will have an integrated platform whereby RealFuel members will automatically have an account on the InvestaCrowd platform (subject to offering and advertising restrictions applicable to certain users who may have limited access to the InvestaCrowd platform).  

By continuing to use our website, you signify that you have read and understood this Privacy Policy. If you do not wish to be bound by the terms of this Privacy Policy, please do not access or register on the Site. 

The term “you” or “User” as used herein refers to any member, user or viewer of our Site.

This Privacy Policy is an agreement between you and RealFuel, its subsidiaries and affiliated entities (collectively, “us”, “we” or “RealFuel”) regarding the treatment of the Personal Data you provide to us through the Site.  

CHANGES TO OUR PRIVACY POLICY

We will amend this Privacy Policy from time to time and the updated versions will be posted on our Site and date stamped so that you are aware of when the Privacy Policy was last updated. Please check back frequently to see any updates or changes to this Privacy Policy. If we make any material changes to this Privacy Policy, we will provide notice including by banner on our Site.  Your continued access or use of the Site after making any changes constitute your acceptance of the new Privacy Policy.

TYPES OF PERSONAL DATA COLLECTED

We collect personal information from you while you use the Site. Most of this collection occurs during registration. This includes:

In addition, we gather names and email addresses of Users who contact us through the Site with questions about our company or our platform. We do not collect more Personal Data than is necessary for the purposes for which they are collected.

WEB-RELATED INFORMATION COLLECTION

When you visit the Site, we may send one or more cookies to your computer.  “Cookies” are small text files containing a string of alphanumeric characters that may be placed on your web browser when you visit our Site that may convey anonymous information about your preferences and how you browse the Site to us. However, it does not collect Personal Data about you.  

We use cookies when you sign in, to keep track of your personal session, including some account identifiers so that we can ensure that you are the only person making changes to your account. We also use cookies to track your activity on the Site as a unique person.

All of this information is stored in an encrypted form, and no personal information about you is stored.  You can set your web browser to inform you when cookies are used or to prevent cookies from being used.  Please note, however, that if you decline to use cookies, the Site’s performance may be affected, or you may be prevented from using some of our services.

The Site uses Google Analytics, a web traffic analysis service provided by Google Inc. (“Google”). Please refer to http://www.google.com/policies/privacy/partners to find out more about how Google uses data when you use our Site and how to control the information sent to Google. You may prevent Google’s collection and processing of data by using the Google Ads Settings page or downloading and installing their browser plug-in (https://tools.google.com/dlpage/gaoptout).

In addition, we (or our service providers, such as Google Analytics) may also collect technical information related to your use of our services.  This may include (but is not limited to):

Such technical data may be used for administrative purposes, to assess the usage, value and performance of our online products and services, and to improve your experience with our services.  As with cookies, the web surfing information collected is aggregated, anonymous "click stream" and transactional data, and is not associated with any Users as individuals.

PURPOSES OF COLLECTING PERSONAL DATA

The Personal Data we collect is required for legal, compliance or security purposes. Where possible, we will inform you of the specific purpose for which such Personal Data is being collected. 

The Personal Data collected on the Site maybe used by RealFuel for the following purposes:

MINORS

Our services are not directed at persons under the age of 16. If you are a parent or guardian and you become aware that your child has provided us with personal data without your consent, please contact us. We will only process personal data of a child under the age 16 only where consent is given or authorized by the child’s parent or guardian. If we become aware that a child under the age of 16 has provided us with personal data without consent, we will delete such information from our files, including any accounts that may have been created.

HOW WE SHARE YOUR INFORMATION

RealFuel does not sell or rent personal information about its Users to third parties.  We do, however, work with a number of trusted partners who perform vital functions as part of our operations.  

In addition to Hubspot and MailChimp, we work with (among others) providers of hosting services for the Site, electronic signature providers, and electronic payment service providers, and other service providers who provide information technology and system administration services to us. We may engage third parties to help us to carry out certain other internal functions such as account processing, client services or other data collection relevant to our business; examples of such companies might include companies that perform data processing, reporting, tax or legal documentation, custody or escrow services.  Personal Data is shared with these third parties only to the extent necessary for us to process the transactions you initiate or perform other specific services, like collections.  Our partners are legally required to keep your information private and secure.

If you use our blog or other public forums on the Site, please note that any Personal Data you submit there is available to other Users. We are not responsible for the Personal Data you choose to submit.

We may share your personal data with law enforcement or other government agencies as required by law or for the purposes of limiting fraud. We reserve the right to disclose your personally identifiable information when we believe that disclosure is necessary to protect our rights or to comply with a judicial proceeding, court order or legal process. We further reserve the right to disclose any of your personal information that we believe, in good faith, appropriate or necessary to take precautions against liability, to investigate and defend against any third-party claims or allegations, to assist government enforcement agencies, to protect the security or integrity of the Site or our Services, or to protect the rights, property or personal safety of RealFuel, its Users, or or any other person.

NOTIFICATIONS AND COMMUNICATIONS FROM OUR SITE

We will send you email notifications from time to time. These will typically relate to your activities on our Site. In other cases, these notifications involve changes to various legal agreements or Site policies.  By using our services, you consent to receiving such service-related emails.

From time to time, we may also send user surveys, requests for user feedback regarding user experience and Site operations.  Completing these surveys or requests for feedback or acceptance of any offer is strictly voluntary. If you do not wish to receive these offers, surveys or user feedback emails, please opt out in any offer email you receive from us.

LINKS TO OTHER SITES

The Site may contain links to other websites which are not maintained by RealFuel. If you follow any links that direct you away from the Site, this Privacy Policy will not apply to your activity on the other websites you visit. We do not control the privacy policies or the privacy practices of any third parties. We encourage you to review each website’s privacy policy before disclosing any Personal Data.

TRANSFERRING INFORMATION OVERSEAS

Personal data collected through this Site may be stored and processed outside of Singapore or any other country in which RealFuel or its agents maintain offices.  By providing your personal data and using the Site, you consent to any such transfer of information outside of your country.  

Where the third-party recipient of Personal Data is located in a country which has not been deemed by the European Commission to have adequate laws in place to protect it, we may transfer such Personal Data using one of the following measures:

If you submit any personal information relating to another person on or through the Site to RealFuel and such personal information is protected by another state or country, you will be responsible for compliance with the applicable laws in so far as they relate to your right to use such personal information, your transfer of it to RealFuel, RealFuel’s storage of that personal information in electronic form on the Site and collection, use, processing and transfer of that personal information in accordance with this Privacy Policy.

SECURITY POLICY

We limit access to your Personal Data to those employees or third parties who have a legitimate business need to access such information.  We conform to industry standards and practices and maintain appropriate physical, electronic and procedural safeguards and controls to protect your information. This includes partnerships with Amazon Web Services, which allows us to rely on ISO 27001 security certification and extended validation SSL Plus certificate provided by Digicert.  The Site is built upon a secure infrastructure with multiple layers of protection and we use industry standard encryption technologies to safeguard your information.

RealFuel takes the protection of your Personal Data seriously but, unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your Personal Data, we cannot guarantee the security of your Personal Data transmitted through the Site; any transmission is at your own risk.

If your Personal Data is compromised as a result of breach of our security measures, we will promptly notify you of such a breach.  

RealFuel will never send you an email asking you for your login information.  In general, you can protect yourself against phishing by never providing personal or login information via a link contained in an email; instead, go to the Site directly.  

YOUR RIGHTS

Access to information:

The GDPR gives you the right to find out whether we are processing your Personal Data and, where that is the case, to receive a copy of the Personal Data we process.  We will endeavor to provide you with an account of your Personal Data in our possession or control within a reasonable time.  Such account shall be in respect of how your Personal Data has been or may have been generally used or disclosed.

We reserve the right to charge you a reasonable administrative fee for carrying out such request. Where your personal data is inseparable from the Personal Data of others, we reserve the right to withhold your Personal Data if permitted by applicable law.

Right to request rectification or erasure of Personal Data:

You have the right to request the amendment of your Personal Data at any time if it is inaccurate. If it is incomplete, you have the right to have such Personal Data rectified. You also have the right to require us to delete your Personal Data as soon as possible by emailing delete@realfuel.io where one of the following applies:

Please not that it may take up to 30 working days for any request for consent withdrawal to be reflected in our systems.

Right to restrict personal data:

You have the right to request the restriction of processing of Personal Data if you think that is inaccurate, that we are processing it illegally, or that we no longer need it for the purposes for which it was collected. While we consider your request, we will stop processing your Personal Data within a reasonable time from the date we receive your request. We will notify you of our decision and any justifications for continuing to process your Personal Data as soon as we can.

Right to withdraw:

If we process your Personal Data with your consent, you have the right to withdraw your consent at any time. This will not affect the legality of our processing of your Personal Data up until the point at which you withdraw your consent. Please also note that we may still need to process your Personal Data on other grounds, for example to fulfil a contract with you or as required by law.

Right to object:

You have the right to object, at any time, on grounds relating to your particular situation, to the processing of Personal Data. If we cannot demonstrate compelling legitimate grounds to continue processing the Personal Data, processing of such data will cease.

DATA PROTECTION OFFICER AND ACCESSING YOUR RIGHTS

If you wish to withdraw your consent to any or all use of your Personal Data, or request amendment, restriction or erasure of such Personal Data, or exercise any other of your rights, please contact privacy@realfuel.io.

Do note that if you withdraw your consent to any or all use of your Personal Data or request for erasure of your Personal Data, depending on the nature of your request, we may not be in a position to continue to provide services to you, or administer any contractual relationship already in place. Any withdrawal of consent or request to erase your Personal Data may also result in the termination of any agreements you have with us. Our legal rights and remedies in such event are expressly reserved.

By giving or making available your Personal Data, you expressly agree and consent to the collection, use, processing and disclosure of your Personal Data in accordance with the terms of this Privacy Policy, including but not limited to, consenting and receiving communications and materials from us, from time to time.

Questions?  Please email us at privacy@realfuel.io

Last updated:  July 16, 2018, 2018

Copyright ©2018 RealFuel SG Pte Ltd.  All Rights Reserved.