# PRIVACY POLICY

Last Updated: Oct.9, 2024

This privacy policy for DEBANK GLOBAL PTE. LTD. (together with our affiliates, “Company,” “we,” “us,” or “our”), describes how and why we might collect, store, use, and/or share (“process”) your information when you use our services (“Services”), such as when you:

Visit our website at https://rabby.io/ (opens new window), or any website of ours (“Website”) that links to this privacy policy;
Engage with us in other related ways, including any sales, marketing, or events.

Questions or concerns? Reading this privacy policy will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services.

If you still have any questions or concerns, please contact us at support@rabby.io.

# Personal Information That You Disclose to Us

We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

Personal Information Data. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:

Personal Data, such as your email address, billing and mailing address, phone number, or any other personal information that you provide to us.
Profile Data, such as your username and password that you choose to set up an online account for using or otherwise accessing the Service.

Communication Data. If you communicate with us, we collect your name, contact information and the contents of any messages you send, including without limitation, exchanges via our Discord discussion group or other social media means.

Payment Data. We may collect data necessary to process your payment if you make purchases, such as your payment instrument number, and the security code associated with your payment instrument.

User-Generated Data. When you use our Services, we may collect personal information that is included in the input, file uploads or feedback that you provide to our Services, as well as associated metadata, which encompasses information on how and where the content was created, formatted, or edited, and additional details like keywords.

Other Data that are not specifically listed here, which we will process as described in this Privacy Policy or as otherwise disclosed at the time of collection.

# Information We Collect Through Automatic Data Collection Technologies

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

The information we collect includes:

Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called “crash dumps”), and hardware settings).
Device Data. We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.

# HOW DO WE PROCESS YOUR PERSONAL INFORMATION?

We process information that we collect about you or that you provide to us, including any personal information:

To present our Website and its contents to you;
To provide, maintain, deliver and update the Services;
To create and maintain your account with our Service;
To communicate with you about the Service;
To develop new tools, products or services based on your feedback;
To carry out identify verification and authentication services;
To fulfill any other purpose for which you provide it;
To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection;
To comply with legal obligations and legal process and to protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or other third parties.
To notify you about changes to our Services, Websites, or terms and conditions of our Services, including this privacy policy; and
For any other legitimate interests or lawful business purposes.

We may disclose personal information that we collect or you provide as described in this Privacy Policy:

To our subsidiaries and affiliates;
To third-party service providers that are in the U.S. or in other countries where such service providers assist in providing our Services and/or facilitating our website;
To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the Company’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by the Company about our Website users is among the assets transferred;
To fulfill the purpose for which you provide it;
For any other purpose disclosed by us when you provide the information; and
With your consent.

We may also disclose your personal information:

To comply with any court order, law, or legal process, including to respond to any government or regulatory request;
To enforce or apply our terms of services at https://rabby.io/docs/terms/ (opens new window) and other agreements, including for billing and collection purposes.
If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

# HOW LONG DO WE KEEP YOUR INFORMATION?

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy policy, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements).

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if such actions are not reasonably practicable (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

# HOW DO WE KEEP YOUR INFORMATION SAFE?

We have implemented appropriate and reasonable technical and organizational security measures, such as all user data is securely stored on Amazon Web Services (AWS), a highly reputable and robust cloud service provider. AWS has been chosen for its exceptional security features and compliance with various international standards, designed to protect the security of any personal information we process.

However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

# WHAT ARE YOUR PRIVACY RIGHTS?

The following are the rights and choices available to all users:

Access: You may request to see the personal information we hold about you and understand how it’s being processed by logging in to your account settings and updating your user account or contact us using the contact information provided.
Deletion: You have the right to ask us to erase your personal information from our records.
Rectification: If your personal information is inaccurate or incomplete, you can have it corrected or completed.
Restriction: You may limit the ways we use your personal information.
Withdrawal of Consent: You can retract any consent given for processing your personal information at any time.
Objection: You may challenge the processing of your personal information by us.
Termination Account: We will deactivate or delete your account and information from our active databases upon your request. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.
Complaints: You can file a complaint with your local data protection authority regarding our handling of your personal information.

For your specific rights under the applicable laws, please refer to “WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?”.

# DO WE COLLECT INFORMATION FROM MINORS?

We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data that we may have collected from children under age 18, please contact us at support@rabby.io.

# WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?

# IF YOU ARE A CALIFORNIA RESIDENT, THE FOLLOWINGS MAY APPLY TO YOU

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.

If you are under 18 years of age, reside in California, and have a registered account with Services, you have the right to request removal of unwanted data that you publicly post on the Services. To request removal of such data, please contact us using the contact information provided below and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Services, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g., backups, etc.).

The California Code of Regulations defines a “resident” as:

every individual who is in the State of California for other than a temporary or transitory purpose
every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose.

All other individuals are defined as “non-residents.”

If this definition of “resident” applies to you, we must adhere to certain rights and obligations regarding your personal information.

What Categories of Personal Information Do We Collect?

We have collected the following categories of personal information in the past twelve (12) months:

Category	Examples	Collected
A. Identifiers	Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name	NO
B. Personal information categories listed in the California Customer Records statute	Name, contact information, education, employment, employment history, and financial information	NO
C. Protected classification characteristics under California or federal law	Gender and date of birth	NO
D. Commercial information	Transaction information, purchase history, financial details, and payment information	NO
E. Biometric information	Fingerprints and voiceprints	NO
F. Internet or other similar network activity	Browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems, and advertisements	NO
G. Geolocation data	Device location	NO
H. Audio, electronic, visual, thermal, olfactory, or similar information	Images and audio, video or call recordings created in connection with our business activities	NO
I. Professional or employment-related information	Business contact details in order to provide you our Services at a business level or job title, work history, and professional qualifications if you apply for a job with us	NO
J. Education Information	Student records and directory information	NO
K. Inferences drawn from other personal information	Inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics	NO
L. Sensitive Personal Information		NO

We will use and retain the collected personal information as needed to provide the Services or for:

Category A - As long as the user has an account with us
Category G - As long as the user has an account with us
Category I - As long as the user has an account with us
Category K - As long as the user has an account with us

We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of:

Receiving help through our customer support channels;
Participating in customer surveys or contests; and
Facilitating in the delivery of our Services and to respond to your inquiries.

More information about our data collection and sharing practices can be found in this privacy policy.

You may contact us via the contact information provided in “HOW CAN YOU CONTACT US ABOUT THIS NOTICE?”.

If you are using an authorized agent to exercise your right to opt out we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf.

# Will Your Information Be Shared with Anyone Else?

We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Each service provider is a for-profit entity that processes the information on our behalf, following the same strict privacy protection obligations mandated by the California Consumer Privacy Act (the “CCPA”).

We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be “selling” of your personal information.

We have not disclosed, sold, or shared any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. We will not sell or share personal information in the future belonging to website visitors, users, and other consumers.

# Your Rights with Respect to Your Personal Data

Right to request deletion of the data.

You can ask for the deletion of your personal information. If you ask us to delete your personal information, we will respect your request and delete your personal information, subject to certain exceptions provided by law, such as (but not limited to) the exercise by another consumer of his or her right to free speech, our compliance requirements resulting from a legal obligation, or any processing that may be required to protect against illegal activities.

Right to be informed.

Depending on the circumstances, you have a right to know:

whether we collect and use your personal information;
the categories of personal information we collect;
the purposes for which the collected personal information;
whether we sell or share personal information to third parties;
the categories of personal information that we sold, shared, or disclosed for a business purpose;
the categories of third parties to whom the personal information was sold, shared, or disclosed for a business purpose;
the business or commercial purpose for collecting, selling, or sharing personal information; and
the specific pieces of personal information we collected about you.

In accordance with applicable law, we are not obligated to provide or delete consumer information that is de-identified in response to a consumer request or to re-identify individual data to verify a consumer request.

Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights.

We will not discriminate against you if you exercise your privacy rights.

Right to Limit Use and Disclosure of Sensitive Personal Information.

We do not process consumer’s sensitive personal information.

Verification Process.

Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with information you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we may contact you through a communication method (e.g., phone or email) that you have previously provided to us. We may also use other verification methods as the circumstances dictate.

We will only use personal information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for the purposes of verification. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes. We will delete such additionally provided information as soon as we finish verifying you.

Other Privacy Rights.

You may object to the processing of your personal information.
You may request correction of your personal data if it is incorrect or no longer relevant or ask to restrict the processing of the information.
You can designate an authorized agent to make a request under the CCPA on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with the CCPA.
You may request to opt out from future selling or sharing of your personal information to third parties. Upon receiving an opt-out request, we will act upon the request as soon as feasibly possible, but no later than fifteen (15) days from the date of the request submission.

To exercise these rights, you can contact us via the contact information provided in “HOW CAN YOU CONTACT US ABOUT THIS NOTICE?”.

IF YOU ARE LOCATED IN ANY STATE OF THE UNITED STATES OTHER THAN CALIFORNIA, THE FOLLOWINGS APPLY TO YOU.

Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Montana, Oregon, Tennessee, Texas, Utah, and Virginia provide (now or in the future) their state residents with rights to:

Confirm whether we process their personal information.
Access and delete certain personal information.
Correct inaccuracies in their personal information, taking into account the information’s nature processing purpose (excluding Iowa and Utah).
Data portability.
Opt-out of personal data processing for:
targeted advertising (excluding Iowa);
sales; or
profiling in furtherance of decisions that produce legal or similarly significant effects (excluding Iowa and Utah).
Either limit (opt-out of) or require consent to process sensitive personal data.

The exact scope of these rights may vary by states. To exercise any of these rights please contact us via the contact information provided in “HOW CAN YOU CONTACT US ABOUT THIS NOTICE?”.

IF YOU ARE LOCATED IN THE EEA, SWITZERLAND, OR THE UNITED KINGDOM, THE FOLLOWINGS APPLY TO YOU.

As of May 25, 2018, a new data privacy law known as the EU General Data Protection Regulation (the “GDPR”) becomes effective through the European Economic Area (“EEA”), Switzerland, and the United Kingdom. The GDPR requires us and those using the Services to provide users with certain information about the processing of their “Personal Data.” “Personal Data” is a term used under the GDPR that means, generally, data that identifies or can identify a particular unique user or device – for instance, names, addresses, cookie identifiers, mobile IDs, precise location data, and biometric data.

To comply with the GDPR, we provide the below representations and information, which are specific to persons located in the EEA, Switzerland, or the United Kingdom.

Legal Grounds for Processing Personal Data

The GDPR requires us to tell you about the legal ground we are relying on to process any Personal Data about you. The legal grounds for us to process your Personal Data for the purposes set out above will typically be because:

You Provided Your Consent: To store and/or gain access to information, we rely on your consent.
The Processing is in Our Legitimate Interest: In some cases, we rely on legitimate interest as a legal basis for processing Personal Data to provide our and/or other data controllers’ services. For instance, legitimate interests may include the tailoring of promotional communications, improving our Website and Services, and maintaining the security of the Services, etc.
Contractual Relationships: Sometimes we process certain data as necessary under a contractual relationship we have.
Legal Obligations: Some processing of data may be necessary for us to comply with our legal or regulatory obligations.

Transfer of Personal Data

To the extent we work with global companies and technologies, we may need to transfer your Personal Data outside of the country from which it was originally provided. For instance, we may transfer your data to third parties that we work with who may be located in jurisdictions outside of the EEA, Switzerland, or the United Kingdom, and which have no data protection laws or laws that are less strict in comparison to those in Europe.

To transfer your Personal Data outside of the EEA, Switzerland or the United Kingdom, we rely on the European Commission’s adequacy decisions on certain countries and, for other jurisdictions, we rely on the Standard Contractual Clauses as approved by the European Commission and any applicable country addenda. Please contact us at the contact information below for more information about the safeguards we have put in place to protect your Personal Data and privacy rights in these circumstances.

Personal Data Retention

As a general matter, we retain your Personal Data for as long as necessary to provide the Services, or for other important purposes such as complying with legal obligations, resolving disputes, and enforcing our agreements. If you are a client of ours and thus have an account with us, we will typically retain your Personal Data for the period of time in which you have an account with us.

Your Rights as a Data Subject

The GDPR provides you with certain rights in respect to Personal Data that data controllers (as explained further below) hold about you, including certain rights to access Personal Data, to request correction of the Personal Data, to request to restrict or delete Personal Data, and to object to our processing of your Personal Data (including profiling for online ad targeting).

Right to Access: If you wish to exercise your right to access Personal Data we process as a data controller, you may do so by requesting access via the contact information provided in “HOW CAN YOU CONTACT US ABOUT THIS NOTICE?”. Upon receiving your request, we will assess requests on a case-by-case basis, verify your identity and whether the data truly and solely belongs to you, and may limit the Personal Data we make available. Please note that we will only grant requests submitted for Personal Data for which we are a data controller. Where we act as a data processor for one of our clients, we will refer your request to that client. Please identify the client your request refers to (if possible) to simplify this process.
Right to Correct: If you wish to exercise your right to correct or update your Personal Data, you may do so by contacting us at the contact information below.
Right to Object to Processing or to Withdraw Consent: You may withdraw consent for processing your Personal Data.
Right to Erasure: You also have the right to request that we erase the Personal Data concerning you that we hold as a data controller. Please note, however, that we may retain copies of certain Personal Data on inactive or back-up files, for our own internal and necessary purposes, including but not limited to auditing, accounting and billing, legal, or bug detection. We will retain your Personal Data for the period necessary to fulfill any important purposes that we have in retaining it, principally regarding legal, auditing, accounting, and billing obligations.
Right to Lodge Complaints: You have the right to lodge a complaint with a supervisory authority. However, we hope that you will first consult with us, so that we may work with you to resolve any complaint or concern you might have.

Questions or Concerns

If you are a resident of the EEA, Switzerland, or the United Kingdom and have concerns regarding this Section VIII, please contact us via the contact information provided in “HOW CAN YOU CONTACT US ABOUT THIS NOTICE?”.

Complaints

If you are located in the EEA or the United Kingdom and you believe we are unlawfully processing your personal information, you also have the right to complain to your Member State data protection authority (opens new window) or UK data protection authority (opens new window).

If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner. (opens new window)

IF YOU ARE LOCATED IN CANADA, THE FOLLOWINGS APPLY TO YOU.

We may process your information if you have given us specific permission (i.e., express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time.

In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:

If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way;
For investigations and fraud detection and prevention;
For business transactions provided certain conditions are met;
If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim;
For identifying injured, ill, or deceased persons and communicating with next of kin;
If we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse;
If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province;
If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records;
If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced;
If the collection is solely for journalistic, artistic, or literary purposes; and
If the information is publicly available and is specified by the regulations.

# CONTROLS FO DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy policy.

# DO WE MAKE UPDATES TO THIS NOTICE?

We may update this privacy policy from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy policy frequently to be informed of how we are protecting your information.

# HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions about our approach to privacy or would like to make a complaint, please contact our Data Protection Officer, whose details are provided below. We will endeavor to respond to your complaint as soon as possible.

Address	44-02A, 10 anson road, 079903
Email Address	jeff@debank.com
Contact No.	+65-85288553

# HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it. To request to review, update, or delete your personal information, please fill out and submit a data subject access request