General

1. This is the policy adopted by Czar Exchange Pvt. Ltd. for the collection, use, disclosure and/or process of personal data that is provided by you in the course of your use of the Platform (as defined in the Terms of Use) and the Services (as defined in the Terms of Use).

2. In this Policy:

  • the terms “we”, “us” and “our” refer to Czar Exchange Pvt. Ltd. 

  • the terms “you” and “your” refer to an individual who provides personal data to us.

3. We treat all personal data provided by you in strict confidence, and will only use your personal data in the manner set out in this Policy.

4. By providing us with your personal data, you consent to our collection, use, disclosure and/or process (including transfer) of your personal data in accordance with this Policy. Please DO NOT provide any personal data to us if you do not accept this Policy.

What personal data is collected

5. “Personal data” means data, whether true or not, about an individual who can be identified from that data, or from the data and other information to which an organization has or is likely to have access. Examples of personal data that we may collect about you include your name, nationality, date of birth, sex, contact details (e.g. address, email address, telephone numbers), passport or identification number and your bank account number

6. We collect personal data about you and where required, also about other persons, including people who are authorised to act on your behalf and other third parties in all matters relating to your use of the Platform and the Services. The purposes for collecting such personal data are set out below

7. Your provision of personal data to us is voluntary. However, if you choose not to provide us with the personal data we require, it may not be possible for us to provide you with the Services or the use of the Platform.

8. If you provide the personal data of anyone other than yourself, you warrant that you have informed him/her of the purposes for which we require his/her personal data and that he/she has consented to your disclosure of his/her personal data to us for those purposes.

9. You must ensure that all personal data that you provide is true, accurate and complete

Purposes for Collection, Use or Disclosure of Personal Data

10. We may collect, use and disclose the personal data received from you for the purposes listed below (collectively the “Purposes”).


11. Service related purposes. Generally, we collect, use or disclose your personal data for the following service related purposes:

  1. to manage your relationship with us;

  2. to set up your customer account;

  3. to process payment and deliver the Services to you;

  4. to assist you with your enquiries;

  5. to obtain feedback on the Services; and

  6. to keep you updated on the Services


12. Business purposes. We may also use your personal data for purposes connected or relevant to our business, such as:

  1. complying with our legal obligations and requirements;

  2. enforcing obligations owed to us;

  3. carrying out research into the development of new services or improvement of our existing services; and

  4. accounting, risk management and record keeping.

13. Additional purposes. If you have consented, we may use your personal data from time to time for additional purposes such as:

  1. Marketing our services; and

  2. Informing you of the latest activities, special offers and promotions offered by us.


14. Contacting you. We may use your personal data to contact you for the above Purposes via post, fax, e-mail, SMS, telephone or any other means.


Disclosure of Information

15. We will not sell or rent your personal data to third parties.

16. Disclosure to service providers. You agree that we may disclose your personal data to third parties who provide necessary services to us, including but not limited to:

  1. service providers and data processors working on our behalf and providing services such as accounting, hosting and maintenance services, analysis services, email message services, delivery services, handling of payment transactions, and marketing; and

  2. our consultants and professional advisers (such as accountants, lawyers, auditors).

17. In disclosing your personal data to third parties, we endeavor to ensure that such parties protect your personal data from unauthorised access, collection, use, disclosure, or similar risks and the third parties only retain your personal data for as long as they are either required to by law and/or as is relevant for the purposes for which such personal data was collected and retention of the personal data is necessary for legal or business purposes.

18. Other permitted disclosure. You agree that we may also disclose your personal data as required or permitted by law.  We may disclose your personal data to regulatory authorities, statutory bodies or public agencies for the purposes of complying with their respective requirements, policies, and directives.


Transfer of Personal Data out of Nigeria

19. Transfer outside Nigeria. You consent to us transferring your personal data to any location outside of Singapore for the Purposes set out above.

20. While reasonable precautions will be taken to ensure that the information you provide is protected against unauthorized or unintended access, we cannot be held responsible for unauthorized or unintended access by third parties that is beyond our control.

Access to and Correction of personal data 

21. You may request for correction or access to the personal data we have collected about you. We may levy a charge for processing your access request. Please contact our Data Protection Officer (see “How to contact us” section below) to find out how to request for correction or access.

22. We may be prevented by law from complying with your request. We may also decline your request if the law permits us to do so or if our records have been destroyed in accordance with our internal data retention policies.

Withdrawal of consent

23. You may withdraw your consent given for any or all Purposes set out in this Policy by submitting your request to our Data Protection Officer (see “How to contact us” section below). We will process your request within a reasonable time from such a request for withdrawal of consent being made, and we will thereafter refrain from collecting, using and/or disclosing your personal data in the manner stated in your request. However, we may not be in a position to continue to provide the Services to you and/or allow you to use the Platform if you withdraw your consent for purposes that are necessary for the provision of the Services and/or use of the Platform.


How to contact us

27. If you have any questions or concerns regarding any aspect of this Policy or the personal data you have provided or wish to make a request or withdraw your consent given for any or all Purposes set out in this Policy, you can contact our Data Protection Officer at Support@czarexchange.com


Amendments and Updates

28. We may amend this Policy from time to time and will make available the updated Policy on our website at https://czarexchange.com/en/privacy-policy/. The updated Policy will supersede earlier versions and will apply to personal data provided to us previously. Each time you use the Platform and/or the Services, you acknowledge and agree that the latest version of this Policy shall apply to you.

Governing Law

29. This Policy is governed by the laws of the Republic of Nigeria