Privacy Policy 

Algorand Foundation Privacy Policy 

The purpose of this document (“Privacy Policy”) is to inform you of how Algorand Foundation Ltd. (theissuer of the ALGO Tokens and the corporate entity launching the Algorand Blockchain Network)manages personal data in accordance with the Personal Data Protection Act 2012 (“the Act”). Pleasetake a moment to read this Privacy Policy so that you know and understand the purposes for which wecollect, use and disclose your Personal Data.

By interacting with us, submitting information to us or signing up for any promotions or services offeredby us (“Services”), you agree and consent to Algorand Foundation Ltd. (a company limited byguarantee incorporated in Singapore with its registered address at 1 George Street, #10-01, OneGeorge Street, Singapore (049145)), its related corporations and affiliates, (collectively referred toherein as the “Foundation”, "us", "we" or "our"), as well as our respective and/or agents("Representatives") collecting, using, disclosing and sharing amongst themselves your Personal Data,and disclosing such Personal Data to the Foundation’s authorised service providers and relevant thirdparties in the manner set forth in this Privacy Policy.

This Privacy Policy supplements but does not supersede any other consents you may have previouslyprovided to us in respect of your Personal Data, and your consents herein are cumulative and additionalto any rights which the Foundation may have at law to collect, use, disclose and/or process yourPersonal Data. This Privacy Policy does not affect any rights which we may have at law in connectionwith the collection, use, disclosure and/or processing of your Personal Data.

The Foundation reserves, in its sole discretion, the right to revise this Policy at any time and if wechange our Privacy Policy, we will post the changes on this page and may place notices on other pagesof (the “Site”), so that you may be aware of how we collect, use, discloseand/or process Personal Data. Subject to your rights at law, you agree to be bound by the prevailingterms of this Privacy Policy as updated from time to time on our Site. Please check the Site regularlyfor updated information on the handling of your Personal Data.

    1.1 In this Privacy Policy, "Personal Data" means all data that falls within the definition of personal
    information, personal data, personally identifiable information or similar language under any
    applicable law relating to the protection, privacy and security, collection, use or disclosure of
    sensitive or other personally identifiable information, including the PDPA (collectively, "Data
    Protection Laws").

    1.2 Examples of such Personal Data which we collect and/or which you may provide us include
    (depending on the nature of your interaction with us):

    (a) personal details (such as name, gender, date of birth/age, nationality, passport or
    national ID number, social security number, tax identification number);

    (b) contact details (such as address, email address, telephone number, social media
    account details);

    (c) financial details (such as bank information, credit card information, utility bill, credit
    report, other financial details with respect to “Accredited Investor” verification)

    (d) corporate details (such as name, place of registration, registration number,
    transparency register number, details with respect to articles of association and other
    similar documents/certificates, details with respect to shareholders and/or beneficial
    owners (including their personal and contact details)

    (e) technical information of your device which you use for orders and communication (such
    as cell phone, tablet, notebook, personal computer, IP address)

    (f) log in information (such as email address, password);

    (g) your cryptocurrency wallet address; and

    (h) information about your visit and use of our Site and Services, including cookies,
    information about your domain name and IP addresses.

    1.3 To the maximum extent permitted under applicable law, we may anonymise your Personal Data
    so that it no longer identifies you, in which case we shall be entitled to retain, use, disclose,
    and/or process such anonymised data without restriction, including for business product related

    1.4 In the course of your interaction on the Algorand Blockchain Network, we may also create
    Personal Data about you, such as records of your interactions with us and details of your
    transaction history.

    1.5 In order to comply with international sanctions and applicable regulations for securities and to
    fight money-laundering or the financing of terrorism, we may need to check any Personal Data
    provided by you against publicly available databases.

    1.6 For the avoidance of doubt, in the event that Data Protection Laws permits the Foundation to
    collect, use, disclose and/or process your Personal Data without your consent, such permission
    granted by the law shall continue to apply.

    2.1 Generally, your Personal Data may be collected by us in the following ways:

    (a) when you contact us via e-mail, telephone or by any other means;

    (b) in the ordinary course of our relationship with you;

    (c) when we provide you with access to the Algorand Blockchain Network;

    (d) where you have manifestly chosen to make such Personal Data public, including via
    social media profiles;

    (e) when we receive your Personal Data from third parties who legally provide it to us, such
    as background/ credit reference checking agencies or law enforcement agencies;

    (f) when you visit any of our websites (including, the Site) or use any features or resources
    available on or through our websites (including but not limited to applying for the
    relevant ecosystem grant program and community champion award through links
    available on the Site). When you visit our website, your device and browser may
    automatically disclose certain information (such as device type, operating system,
    browser type, browser settings, IP address, language settings, dates and times of
    connecting to a website and other technical communications information), some of
    which may constitute Personal Data;

    (g) when you submit your resume/CV to us for a job application;

    (h) when you acquire ALGO Tokens directly from us; and/or

    (i) when you submit your Personal Data to us for any other reason.

    2.2 When you browse our Site, you generally do so anonymously but please see paragraph Error!
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    on our Site.

    2.3 If you provide us with any Personal Data relating to a third party (e.g. information on your
    dependent, spouse, children and/or parents), by submitting such information to us, you
    represent and warrant to us that you have obtained the consent of such third party to you
    providing us with their Personal Data, and for the further collection, use, disclosure and/or
    processing by us of their Personal Data, for the purposes contemplated hereunder, and that
    such consents have not been withdrawn.

    2.4 You shall ensure that all Personal Data submitted to us is complete, accurate, true and correct.
    Failure on your part to do so may result in our inability to provide you with the products and/or
    services which you have requested.

    3.1 In general, we collect, use, disclose and/or process your Personal Data for the following

    (a) to provide, maintain and improve our Services, including without limitation ensuring
    open access to and technical development on the Algorand Blockchain Network,
    minting and launching the ALGO Tokens, providing long-term governance, community
    and ecosystem, and being a treasurer of the funds raised;

    (b) to help us review, develop, improve, manage the delivery of and to the extent this
    requires the use of Personal Data, enhance our products and services, including
    analysing customer behaviour and future customer needs, conducting market research,
    list processing and data analytics (including by requesting feedback from you or your
    participation in surveys);

    (c) for authentication and verification purposes;

    (d) to enable, improve or update information on the use of the Algorand Blockchain

    (e) to grant you access to and participate in the governance of Algorand Blockchain

    (f) to enable you to apply to and be considered by the Foundation for operating nodes on
    Algorand Blockchain Network;

    (g) to enable you to apply to and be considered by the Foundation for the relevant grant
    for building projects on or relating to Algorand Blockchain Network;

    (h) to enable you the use of ALGO Tokens;

    (i) for the issuance, distribution, use and circulation of or exchange for ALGO Tokens,
    where you have submitted Personal Data to us for the purposes acquiring of the ALGO

    (j) specifically, in relation to the processing of your Personal Data:
    (i) as may be necessary in connection with any contractual relationship that you
    may enter into with us;
    (ii) as may be required by applicable law;
    (iii) as is necessary to protect the vital interests of any individual; and
    (iv) where we have a legitimate interest in carrying out the processing for the
    purpose of managing, operating or promoting our business, and that legitimate
    interest is not overridden by your interests, fundamental rights, or freedoms.

    (k) to respond to, handle, and process queries, requests, applications, complaints, and
    feedback from you;

    (l) detect, prevent, and address technical issues;

    (m) enhance security, monitor and verify identity or service access, combat spam or other
    malware or security risks;

    (n) send information including confirmations, technical notices, updates, security alerts,
    and support and administrative messages;

    (o) detect, prevent and mitigate fraud and abuse of our Services and to protect you against
    account compromise or funds loss;

    (p) to handle disputes and conduct and facilitate investigations and proceedings;

    (q) to prevent, detect and investigate crime, including fraud and money-laundering, and to
    analyse and manage other commercial risks;

    (r) to manage our infrastructure operations, administrative operations and business
    operations and to comply with internal policies and procedures;

    (s) to comply with, protect and enforce our contractual and legal rights and obligations;

    (t) to commence, respond to, or act in connection with any claims, actions or proceedings
    (including but not limited to drafting and reviewing documents, transaction
    documentation, obtaining legal advice, and facilitating dispute resolution);

    (u) to match any Personal Data held which relates to you for any of the purposes listed

    (v) to facilitate business asset transactions (which may extend to any merger, acquisition
    or asset sales);

    (w) to comply with any applicable rules, laws and regulations, codes of practice or
    guidelines or to assist in law enforcement and investigations by relevant authorities;

    (x) where required or permitted by law for any purpose; and/or

    (y) for purposes which are reasonably related to the aforesaid.

    3.2 In addition, and without prejudice to the generality of the foregoing, if you submit an application
    to us as a candidate for employment or an internship, or are an existing employee of the
    Foundation, we collect, use, disclose and/or process your Personal Data for the following

    (a) for management and/or evaluative purposes, including without limitation to process
    your employment application, to conduct pre-recruitment checks, and/or to provide or
    obtain employee references or other references where relevant for background
    screening and/or vetting;

    (b) for personnel administration, including to administer benefits and payroll processing, to
    administer or execute employee remuneration schemes, and/or to his/her employment related work activities;

    (c) to enter into an employment relationship with you or to appoint you to any office;

    (d) to manage or terminate the employment relationship with you or appoint you, including
    without limitation role assessment, job compatibility assessment, career progression
    and/or management of staffing requirements; and/or

    (e) for purposes which are reasonably related to the aforesaid.

    3.3 Furthermore, and without prejudice to the generality of the foregoing, and where permitted
    under Data Protection Laws, we may also collect, use, disclose and/or process your Personal
    Data and/or share your Personal Data with our business partners for any of the following

    (a) providing or marketing services, products and benefits to you, including promotions;

    (b) to enable you to apply to and be considered and selected by the Foundation for the
    relevant marketing initiatives and campaigns for promotion relating to the Foundation
    and Algorand Blockchain Network (including but not limited to you, if selected by the
    Foundation, appearing on the relevant Foundation marketing, promotion or community
    webpage and may be contacted by other members in our communities or any visitor of
    our websites)

    (c) for us or our business partners to inform you via e-mail about upcoming opportunities
    and promote our respective products and services;

    (d) to administer a contest, promotion, survey or other site feature;

    (e) matching Personal Data with other data collected for other purposes and from other
    sources (including third parties) in connection with the customisation, provision or
    offering of products, services, marketing or promotions, whether by the Foundation or
    other third parties; and

    (f) conducting research, analysis and development activities (including data analytics,
    surveys, product and service development and/or profiling), understanding and
    analysing customer behaviour, location, preferences and demographics for us to offer
    you products and services as well as special offers and marketing programmes which
    may be relevant to your preferences and profile.

    3.4 In relation to particular products or services or in your interactions with us, we may also have
    specifically notified you of other purposes for which we collect, use, disclose and/or process
    your Personal Data. If so, we will collect, use, disclose and/or process your Personal Data for
    these additional purposes as well, unless we have specifically notified you otherwise.

    3.5 We also reserve the right to monitor, check and process your Personal Data if necessary to
    investigate or obtain evidence concerning any complain, claim or dispute or any actual or
    suspected illegal or unlawful conduct or to aid in such investigation or evidence gathering by
    any law enforcement or regulatory authorities.

    3.6 You may withdraw your consent by contacting us using the contact details set out at paragraph
    8 below.

    4.1 Subject to the provisions of any applicable law, you hereby agree, acknowledge and consent
    that your Personal Data may be disclosed for any of the purposes listed above in this Privacy
    Policy (as applicable) to the following entities or parties, regardless of whether they are located
    overseas or in Singapore:

    (a) our service providers and contractors, including third party vendors that provide data
    processing or management services;

    (b) our business partners and members of our communities (and in particular, where you
    have consented to receiving information/ newsletters/ marketing/ promotion from us);

    (c) our group affiliates;

    (d) other holders or users of ALGO Tokens;

    (e) any person or entity involved in the handling of ALGO Tokens or Services provided to
    you; and

    (f) law enforcement authorities, regulatory authorities, statutory bodies or public agencies
    for the purposes of complying with their requirements, policies, directives or requests;

    (g) banks, credit agencies and other financial and/or payment service providers;

    (h) IT-service providers;

    (i) members of Algorand Blockchain Network communities (actual or prospective);

    (j) any business partner, investor, assignee or transferee (actual or prospective) to
    facilitate business asset transactions (which may extend to any merger, acquisition or
    asset sale); and/or

    (k) any other party to whom you authorise us to disclose your Personal Data to.

    4.2 We may share information about you in aggregate or anonymised form, for example,
    information regarding business product related reviews, with the abovementioned entities or
    parties (e.g. our business partners).

    We encourage you to contact us as soon as possible to enable us to update any Personal Data
    we have about you. Incomplete or outdated Personal Data may result in our inability to provide,
    or delays in providing you with products and services you have requested, or processing any
    requests and applications you may have made to us.

    6.1 Our websites (including our Site) and platforms use cookies and other technologies. Cookies
    are small text files stored in your computing or other electronic devices when you visit our
    website (including our Site) and platforms for record keeping purposes. Cookies are stored in
    your browser’s file directory, and the next time you visit the website (including our Site) or
    platform, your browser will read the cookie and relay the information back to the website
    (including our Site), platform or element that originally set the cookie. Depending on the type of
    cookie it is, cookies may store user preferences and other information.

    6.2 Web beacons (also known as pixel tags and clear GIFs) involve graphics that are not apparent
    to the user. Tracking links and/or similar technologies consist of a few lines of programming
    code and can be embedded in our websites (including our Site) or platforms. Web beacons are
    usually used in conjunction with cookies and primarily used for statistical analysis purposes.
    This technology can also be used for tracking traffic patterns on websites (including our Site)
    and platforms, as well as finding out if an e-mail has been received and opened and to see if
    there has been any response.

    6.3 We may employ cookies and other technologies as follows:
    (a) tracking information such as the number of visitors and their frequency of use, profiles
    of visitors and their preferred sites;

    (b) making our websites (including our Site) and platforms easier to use. For example,
    cookies may be used to help speed up your future interactions with our websites
    (including our Site) and platforms;

    (c) to better tailor our products and services to your interests and needs. For example,
    cookies information may be identified and disclosed to our vendors and business
    partners to generate consumer insights;

    (d) collating information on a user’s search and browsing history;

    (e) when you interact with us on our websites (including our Site) and platforms, we may
    automatically receive and record information on our server logs from your browser. We
    may collect for the purposes of analysis, statistical and site-related information
    including, without limitation, information relating to how a visitor arrived at the website
    (including our Site) or platform, the browser used by a visitor, the operating system a
    visitor is using, a visitor's IP address, and a visitor's click stream information and time
    stamp (which may include for example, information about which pages they have
    viewed, the time the pages were accessed and the time spent per web page);

    (f) using such information to understand how people use our websites (including our Site)
    and platforms, and to help us improve their structure and contents;

    (g) using cookies that are necessary in order to enable our websites (including our Site)
    and platforms to operate, for example, cookies that enable you to log onto secure parts
    of our websites (including our Site) and platforms; and/or

    (h) personalising the website (including our Site) and platform for you, including delivering
    advertisements which may be of particular interest to you and using cookie related
    information to allow us to understand the effectiveness of our advertisements.

    6.4 Some cookies we use are from third party companies to provide us with web analytics and
    intelligence about our websites (including our Site) and platforms. These companies collect
    information about your interaction with our websites (including our Site) and platforms. We use
    such information to compile statistics about visitors who interact with the websites (including
    our Site), platforms and other Foundation’s online content, to gauge the effectiveness of our
    communications, and to provide more pertinent information to our visitors.

    6.5 If you do not agree to such use of cookies, you can adjust your browser settings. Unless you
    have adjusted your browser settings to block cookies, our system will issue cookies as soon as
    you visit our website (including our Site) or click on a link in a targeted email that we have sent
    you, even if you have previously deleted our cookies.

    6.6 The way which cookies can be managed depends on your browser. The following links provide
    information on how to configure or disable cookies in each browser:

    (a) Google Chrome:

    (b) Mozilla Firefox:

    (c) Internet Explorer:

    (d) Safari:

    (e) Safari for iPhone, Ipad, or iPod touch:

    6.7 If you do not agree to our use of cookies and other technologies as set out in this Privacy
    Statement, you should delete or disable the cookies associated with our websites (including
    our Site) and platforms by changing the settings on your browser accordingly. However, you
    may not be able to enter certain part(s) of our websites (including our Site) or platforms. This
    may also impact your user experience while on our websites (including our Site) or platforms.

    Certain links contained on the Site may direct you to co-branded websites maintained by the
    Foundation or to companies which the Foundation has established business relationships.
    When you submit information to one of these co-branded sites or partner companies, you may
    be submitting it to both the Foundation and these business partners. This Privacy Policy does
    not apply to any information that you may provide to third parties, such as through other sites
    linked to the Site. The Foundation is not responsible for those sites and cannot control the
    content of what is offered on those sites, or links from those sites, or the privacy policy or data
    security, if any, of those sites, and we therefore strongly encourage you to read their respective
    privacy policies as they may differ from ours.

    8.1 If you:
    (a) have any questions or feedback relating to your Personal Data or about this Privacy

    (b) would like to withdraw your consent to any use of your Personal Data as set out in this
    Privacy Policy; or

    (c) would like to obtain access and make correction to your Personal Data records,
    please contact us as follows:

    Method Contact Particulars
    By mail : Algorand Foundation Ltd.
    1 George Street, #10-01
    Singapore 049145
    By email :

    8.2 Please note that if your Personal Data has been provided to us by a third party (e.g. your
    employer), you should contact that organisation or individual to make such queries, complaints,
    and access and correction requests to the Foundation on your behalf.

    8.3 If you withdraw your consent to any or all use of your Personal Data, depending on the nature
    of your request, the Foundation may not be in a position to continue to provide its products and
    services to you, or administer any contractual relationship in place, which in turn may also result
    in the termination of any agreements with the Foundation, and your being in breach of your
    contractual obligations or undertakings. the Foundation’s legal rights and remedies in such
    event are expressly reserved.

    This Privacy Policy shall be governed in all respects by the laws of Singapore.