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This policy sets out the basis on which Levain Pte. Ltd., a company incorporated under the laws of the Republic of Singapore with its registered office address 20 Cecil Street, #18-01 PLUS, Singapore 049705 (Unique Entity Number 202302955C) (together with our affiliates, our holding company, and affiliates of our holding company from time to time, collectively called “Levain” or “we”) collects personal data from you and how we process such data.

By visiting our website (our “Site”) or by using Levain or any other applications or software we provide from time to time (collectively called our “App”), you accept and consent to the practices set out below.

All capitalized terms used in this Privacy Policy and not otherwise defined herein shall have the meanings assigned to them in the Levain Software as a Service Agreement or other Terms and Conditions that may be available on our Site and in our App.


1.1 For the purposes outlined in Clause 2, we may collect and process the following information about you:

a. Information you give us – information that you provide us (which may include your name, company name, job title, email address, telephone number and other personal or business information) by filling in forms on our Site or our App, or by corresponding with us by email, or through marketing activities, for example:
i. when you register for an account with us on our Site and in our App;
ii. when you report any problem to us;
iii. when you use certain features on our Site or our App;
iv. when you request any support from us; or
v. when you complete any survey or questionnaire we send you; or
vi. when you attend our marketing events or visit our booth at conferences and share your business contact information.

b. Information we collect about you – information automatically collected when you visit our Site or use our App, for example:
i. technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your log-in information, browser type and version, time zone setting, browser version, operating system and platform;
ii. details of any transactions, purchases and payments you initiated or made on our Site and in our App, whether paying for a subscription for the use of our App, or transaction made on public blockchains; and
iii. information about your visit, including the full Uniform Resource Locators (URLs), clickstream to, through and from our site (including date and time), content you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page; and
iv. publicly available information, such as public blockchain addresses, balances of digital assets and funds flow that goes through our App, which may be readily available on public blockchain explorers.

c. Information we receive from third parties – We work with third parties and we may receive information about you from them, for example, affiliates, business partners, sub-contractors in due diligence, technical, payment and delivery services, analytics providers, or search information providers. We will notify you when we receive information about you from them and the purposes for which we intend to use that information.

We only retain personal data for so long as it is necessary and in order to meet regulatory and compliance obligations.


We use information held about you for the following purposes:
a. to fulfil parties’ respective obligations as stated in the Levain Software as a Service Agreement or such other agreement governing the relationship between you and/or your Company and Levain, or to take steps at your request prior to you and/or your Company entering into such an agreement;
b. providing, improving and developing our services in our App;
c. researching, designing and launching new features or products in our App;
d. presenting content and information on our Site and in our App in the most effective manner for you and for the device you use;
e. providing you with alerts, updates, materials or information about our services or other types of information that you requested or signed up to;
f. verifying your identity;
g. authenticate your access to services in our App;
h. processing payments or transactions, whether for our App, or on public blockchains;
i. complying with laws and regulations and/or legal obligations that are applicable to us in any part of the world;
j. assisting in law enforcement and investigations conducted by any governmental and/or regulatory authority;
k. responding or taking part in legal proceedings, including seeking professional advice;
l. communicating with you and responding to your questions or requests; and
m. purposes directly related or incidental to the above.


We will keep your personal data we hold confidential but you agree we may provide information to:
a. any member of our group, which means our subsidiaries and/or related companies, as defined in Section 5 and Section 6 of the Companies Act 1967, Singapore;
b. personnel, agents, advisers, auditors, contractors, financial institutions, and service providers in connection with our operations or services (for example customer due diligence and the provision of support services), who may be unaffiliated third parties whether in Singapore or abroad;
c. our overseas offices, affiliates, business partners and counterparts (on a need-to-know basis only);
d. persons under a duty of confidentiality to us;
e. persons to whom we are required to make disclosure under applicable laws and regulations in any part of the world; or
f. actual or proposed transferees of our operations (or a substantial part thereof) in any part of the world.


4.1 Our App may place and access certain cookies on your computer and/or any other electronic device used to access the App. We use cookies to improve your experience using the Site and to improve the efficacy of our services. We have carefully chosen these cookies and have taken steps to ensure that your privacy is protected and respected at all times.

4.2 Users of the App are advised that if they wish to deny the use and saving of cookies from this App onto their computers and/or other electronic devices, they should take the necessary steps within their browsers’ security settings to block all cookies from this App.

4.3 You can choose to delete the cookies at any time. However, you may lose any information that enables you to access the App more quickly and efficiently including but not limited to personalisation settings.

4.4 We have implemented the following tracking across our Site and our App:

  • Google Analytics
  • HubSpot
  • Mixpanel

4.5 We use Google Analytics across our Site and our App. Like many services, Google Analytics uses first party cookies to track user interactions and in our case, they are used to collect information about how users use our App. You can control the use of such cookies through your browser settings, or opt-out from Google Analytics here. To learn more about Google Analytics’ privacy practices, please visit Google’s Privacy Policy page here

4.6 We do not allow third party behavioral tracking.

5. Third Party Disclosure

We do not sell, trade, or otherwise transfer to outside parties your personally identifiable information unless we provide you with advance notice. This does not include website hosting partners and other parties who assist us in operating our website, conducting our business, or servicing you, so long as those parties agree to keep this information confidential. We may also release your information when we believe release is appropriate to comply with the law, enforce our site policies, or protect ours or others’ rights, property, or safety. However, non-personally identifiable visitor information may be provided to other parties for marketing, advertising, or other uses.


Our Site, our App or our communication with you may contain links to third-party websites, over which we have no control. If you follow a link to any of these websites, please note that they have their own practices and policies. We accept no responsibility or liability for any practices of third-party websites.


7.1 We implemented information security best practices to protect the access to your data, and we continuously review our information collection, storage and processing practices from time to time to guard against unauthorized access, processing or use.

7.2 Please note, however, 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 data transmitted to our Site; any transmission is at your own risk.


8.1 Subject to any applicable legal and regulatory exemptions, you have the right to:
a. check whether we hold personal data about you;
b. access any personal data we hold about you;
c. require us to correct any inaccuracy or error in any personal data we hold about you; and
d. request erasure of any personal data we hold about you.
8.2 Any request under Clause 8.1 may be subject to a small administrative fee to meet our cost in processing your request.
8.3 You may refuse to provide or withdraw your consent for us to collect, use or disclose your personal data by giving us reasonable notice in writing via email to our Data Protection Officer at the contact details provided below, as long as there are no legal, regulatory or contractual restrictions preventing you from doing so. In general, we shall seek to process your request within thirty (30) business days of receiving it.
8.4 If you refuse to provide or withdraw your consent for us to use your personal data, depending on the nature and scope of your request, we may not be able to continue providing you and/or your Company with our Services (as defined in our Terms and Conditions), and may not be able to provide you with access to our Site or App. In such a situation, withdrawing your consent will require you and/or your Company to exit all Services that you have with us, and may require that you withdraw the assets from your Company’s Account. We may also be required by operation of legal or regulatory guidelines to suspend, restrict, or terminate your and/or your Company’s Account upon your withdrawal of consent. We shall, in such circumstances, notify you before completing the processing of your request. Should you decide to cancel your withdrawal of consent, please inform us in writing via email to our Data Protection Officer at the contact details provided below.

8.5 Please note that your withdrawal of consent does not affect our right to continue to collect, process, retain and disclose your personal data where such collection, use and disclosure without consent is permitted or required under applicable laws and/or regulatory guidelines.


We may amend this policy from time to time by posting the updated policy on our Site. By continuing to use our Site and our App after the changes come into effect means that you agree to be bound by the revised policy.


You may contact our Data Protection Officer if you have any enquiries or feedback on our personal data protection and privacy policies and procedures, or if you wish to make any request, in the following manner:

The Data Protection Officer
Address: 20 Cecil Street, #18-01 PLUS, Singapore 049705
Email address: