Privacy Policy

Global Currency Organization User Agreement
Last updated: May 2019

This User Agreement (hereinafter “Agreement”) is a binding contract governing your use of the Global Currency Organization at www.gcodigital.com, any associated APIs and any mobile applications (collectively, the “GCO Sites”) operated by Global Currency Organization Pte.Ltd. (“GCO”). By signing up to use an account through the GCO Sites, you agree that you have read, understood, and accept all of the terms and conditions contained in this User Agreement, as well as our Privacy Policy and E-Sign Consent. If you do not agree to or accept all of the terms of this Agreement, please immediately discontinue access to, and use of, the GCO Sites.



1. Parties

1.1 Global Currency Organization Pte.Ltd. (the “Company”) is a company incorporated in Singapore under the laws of Singapore, and operates the Website https://www.gcodigital.com (the “Website”), which is a platform dedicated to the transaction of digital assets and the provision of related services (hereinafter referred to as the “Service”). For the convenience of wording in this policy (the “Privacy Policy”), the Company and the Website are referred to collectively as 'we' or other applicable forms of first-person pronouns in this Privacy Policy. We respect your privacy and are committed to protecting it through our compliance with this Privacy Policy.

1.2 All natural persons or other subjects who log onto this Website shall be users of this Website. For the convenience of wording in this Privacy Policy, the users are referred to as 'you' or any other applicable forms of the second-person pronouns.

1.3 For the convenience of wording in this Privacy Policy, you and we are collectively referred to as “both parties”, and individually as “one party”.



2. Purposes of the Privacy Policy

The Privacy Policy stipulates the types of information of yours that we may collect from you or that you may provide through your use of or logging into this Website, your registration with this Website, and/or use the services we offer, as well our practices for collecting, using, maintaining, protecting, and disclosing such information. This Privacy Policy also extends to information we collect in email, text, and other electronic messages between you and this Website and through mobile and desktop applications you download from this Website, which provides dedicated non-browser-based interaction between you and this Website.



3. Your Consent

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using this Website, you agree to this Privacy Policy. This Privacy Policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates. If you do not agree with or you are not comfortable with any aspect of this Privacy Policy, you should immediately discontinue access or use of our Services.

In particular, upon your logging into our Website or continued use of the Services, regardless of whether you register with this Website, you shall be deemed to accept, agree, undertake and confirm that:

3.1 You, on the basis of your own free will and your requisite consent, agree to disclose your personal information to us;

3.2 You will comply with all the terms, conditions and limitations of this Privacy Policy;

3.3 You agree that we may collect your information through your logging into this Website, your registration with this Website, and/or your using the Services offered by us, as well as through email, text, and other electronic messages between you and this Website and through mobile and desktop applications you download from this Website; you agree to any changes and modifications that we may make to our Privacy Policy in the future (see Changes to Our Privacy Policy);

3.4 You agree that our branches, affiliates and employees may contact you in connection with the products and services that you may be interested in (unless you have indicated that you do not want to receive such information).



4. Information We Collect About You and How We Collect It

As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

  • Details of your visits to our Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website.
  • Information about your computer and internet connection, including your IP address, operating system, and browser type.
  • We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking).

The information we collect automatically is statistical data and does not include personal information, but we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:

  • Estimate our audience size and usage patterns.
  • Store information about your preferences, allowing us to customize our Website according to your individual interests.
  • Speed up your searches.
  • Recognize you when you return to our Website.

The technologies we use for this automatic data collection may include:

  • Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.
  • Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see Choices About How We Use and Disclose Your Information.
  • Web Beacons. Pages of our the Website and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

We generally do not collect personal information automatically, but we may tie this information to personal information about you that we collect from other sources or you provide to us. You can find more information about how to change your browser cookie settings at http://www.allaboutcookies.org.



5. Third-Party Use of Cookies and Other Tracking Technologies

Some content or applications, including advertisements, on the Website are served by third-parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. To opt-out of third-party advertising networks and similar entities that use targeting/advertising cookies, go to http://www.aboutads.info/choices.



6. How We Use Your Information

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

  • To identify and confirm your identity when you use our Website.
  • To present our Website and its contents to you.
  • To provide you with information, products, or services that you request from us.
  • To fulfill any other purpose for which you provide it.
  • To provide you with notices about your account/subscription, including expiration and renewal notices.
  • 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 allow you to participate in interactive features on our Website.
  • To facilitate transactions (your information, whether public or private, will not be sold, exchanged, transferred, or otherwise provided to any other company on any grounds without your consent, except for where doing so is expressly for the purpose of completing the transaction you require).
  • To improve and upgrade the services of the Website (your information and feedback received by us can help us improve the service of the Website, so that we can more effectively respond to your service requests and support needs).
  • To notify you about changes to our Website or any products or services we offer or provide through it.
  • To keep statistics relating to the use of our Website and to be used for data analysis.
  • In any other way we may describe when you provide the information.
  • For any other purpose with your consent.
  • We may also use your information to contact you about our own and third-parties’ goods and services that may be of interest to you. For more information, see Choices About How We Use and Disclose Your Information.

    We may use the information we have collected from you to enable us to display advertisements to our advertisers’ target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.



7. Disclosure of Your Information

7.1 We may disclose aggregated information about our users, and information that does not identify any individual, without restriction. We may disclose personal information that we collect or you provide as described in this privacy policy:

  • To our subsidiaries and affiliates.
  • To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
  • 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 third parties to market their products or services to you if you have not opted out of these disclosures. For more information, see Choices About How We Use and Disclose Your Information.
  • To fulfill the purpose for which you provide it. For example, if you give us an email address to use the “email a friend” feature of our Website, we will transmit the contents of that email and your email address to the recipients.
  • For any other purpose disclosed by us when you provide the information.
  • 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 use https://www.gcodigital.com/#/terms 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 Company, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

7.2 Choices About How We Use and Disclose Your Information. We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

  • Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly. Some Internet browsers - like Internet Explorer, Firefox, and Safari - include the ability to transmit "Do Not Track" or "DNT" signals. Since uniform standards for "DNT" signals have not been adopted, our Sites do not currently process or respond to "DNT" signals.
  • Disclosure of Your Information for Third-Party Advertising. If you do not want us to share your personal information with unaffiliated or non-agent third parties for promotional purposes, you can opt-out by checking the relevant box located on the form on which we collect your data.
  • Mobile Advertising. You can opt out of having your mobile advertising identifiers used for certain types of advertising by accessing the settings in mobile device and following the instructions. If you opt-out, we will remove all data about you and will not collect any further data. The random ID previously assigned to you will be removed. Thus, if at a later stage, you decide to opt-in, we will be unable to continue and track you using the prior ID and you will for all practical purposes be a new user.
  • Promotional Offers from the Company. If you do not wish to have your contact information used by the Company to promote our own or third parties’ products or services, you can opt-out by checking the relevant box located on the form on which we collect your data (the registration process) or at any other time by logging into the Website and adjusting your user preferences in your account profile by checking or unchecking the relevant boxes or by sending us an email stating your request to contact@gcodigital.com. If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions. This opt out does not apply to information provided to the Company as a result of a product purchase, warranty registration, product service experience or other transactions.
  • Targeted Advertising. If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers’ target-audience preferences, you can opt-out by you can opt-out by checking the relevant box located on the form on which we collect your data (the registration process) or at any other time by logging into the Website and adjusting your user preferences in your account profile by checking or unchecking the relevant boxes or by sending us an email stating your request to contact@gcodigital.com. For this opt-out to function, you must have your browser set to accept all browser cookies.

We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (”NAI”) on the NAI’s website. California residents may have additional personal information rights and choices. Please see Your California Privacy Rights for more information.



8. Accessing and Correcting Your Information

You can review and change your personal information by logging into the Website and visiting your account profile page.

You may also send us an email at contact@gcodigital.com to request access to, correct or delete any personal information that you have provided to us. We cannot delete your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

If you delete your User Contributions from the Website, copies of your User Contributions may remain viewable in cached and archived pages, or might have been copied or stored by other Website users. Proper access and use of information provided on the Website, including User Contributions, is governed by our terms of use https://www.gcodigital.com/#/terms.

California residents may have additional personal information rights and choices. Please see Your California Privacy Rights for more information.



9. Your California Privacy Rights

If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to contact@gcodigital.com.



10. Data Security

10.1 We adopt appropriate physical, electronic, management and technical measures so as to protect and safeguard the security of your personal data. We will, to the greatest extent possible, ensure that any personal data collected through our Website shall be free from being subject to nuisance by any third party unrelated to us. The security measures that we may take include but are not limited to:

10.1.1 Physical measures: records of your personal data will be stored in a properly locked place.

10.1.2 Electronic measures: the computer data that contain your personal information will be stored in computer systems and storage media that are subject to strict login restrictions.

10.1.3 Management measures: only staff members duly authorized by us can access your personal data, and these staff members shall comply with our internal code concerning personal data confidentiality.

10.1.4 Technical measures: such encryption techniques as Secure Socket Layer Encryption may be used to convey your personal data.

10.1.5 Other measures: our network servers are protected by proper 'firewall'.

10.2 If you are aware of any security flaws in our Website, please contact us immediately so that we can take appropriate action as soon as possible.

10.3 Despite of the above-mentioned technical and security measures, we cannot guarantee that the information transmitted via the Internet is absolutely safe, so we cannot absolutely guarantee that the personal data that you provide to us through our Website will be safe at any time. The safety and security of your information also depend on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Website like message boards. The information you share in public areas may be viewed by any user of the Website.

10.4 Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website. We will not be held liable for any loss or damage arising from or caused by any event that may occur in connection with unauthorized access to your personal data, and we shall not be held liable for compensation for such loss or damage.



11. Changes to Our Privacy Policy

It is our policy to post any changes we make to our privacy policy where. If we make material changes to how we treat our users’ personal information, we will notify you by email to the primary email address specified in your account or through a notice on the Website home page. The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and this privacy policy to check for any changes.



12. Contact Information

To ask questions or comment about this privacy policy and our privacy practices, contact us at contact@gcodigital.com.