NetLeaders is a software platform that provides access to the DasCoin Ecosystem and its associated products and services through the sale of Licenses. NetLeaders License are available in a range of sizes and can be purchased from www.netleaders.com Larger Licenses include a larger number of Cycles, as well as other benefits. Cycles represent network capacity in the DasCoin Ecosystem. They can be submitted to the Minting Queue to mint DasCoin or used to purchase network services or products.
Members of the NetLeaders community are rewarded for contributing to and expanding the network via an incentivized marketing program.
NetLeaders is run by CL Singapore PTE ltd. with its registered office in Singapore at 6 Raffles Quay #11-07, Singapore 048580, ACRA Singapore number 201615510K (further referred to as “CL Singapore” ). All references to NetLeaders should be construed as references to CL Singapore PTE ltd. as the context requires. The term “we”, “us” or “our” used in this document shall refer to CL Singapore PTE ltd.
All terms written with capital letters and not defined in this Policy shall bear the meaning specified in the official NetLeaders documents, such as Terms and Conditions, Rules and Regulations and KYC Policy.
NetLeaders considers it essential that the personal details of its customers (and business relations) are processed and secured with the utmost importance. NetLeaders also wants to be open about the way your data is processed. That is why you will find an explanation below. This Policy provides you as the data subject with the information required by the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation-GDPR). We apply General Data Protection Regulation because we offer our services and products to the European Union citizens through our website.
The latest version of this policy is EN-61nKt7l18 applicable since 25 May 2018.
1. Customer Data
If you create a user account at our Website, you are a “user,” as further described in the Terms and Conditions. Customer Data as specified below is controlled by the CL Singapore being the data controller. When NetLeaders collects or processes Customer Data, it may engage the processor to do so on behalf of the CL Singapore.
If you are using the Services by invitation of an Advocate, whether that Advocate is your employer, another organization, or an individual, that Advocate may determine their own policies regarding sharing of Customer Data. Please check with the Advocate about the policy they have in place.
Users may provide information while registering an account such as;
Users registering as a company may provide information such as;
2. Other information
NetLeaders may also collect and receive the following information:
3. Legal grounds for collecting and processing Customer Data
The legal grounds for processing of your personal data are the following:
1. Processing is necessary for the performance of the contract to which you are the party, i.e. License Agreement and/or Advocate agreement and account agreement and to take steps at your request prior to entering into any of the above contracts
2. Processing is necessary for the purposes of the legitimate interest pursued by NetLeaders, especially for direct marketing purposes and for protection of Netleaders' rights in case of claims and lawsuits
3. Processing is necessary for compliance with legal obligation, especially tax and accounting duties.
You are not legally bound to provide us with your personal data, however without your personal data we are not able to open your account at our website nor enter into the License Agreement or Advocate’s agreement. Please be informed that we apply Know Your Customer and Anti Money Laundering procedures, so you will be asked to provide us with additional data before execution of any transaction.
Our main purpose for collecting personal information is to provide you with a secure, smooth, efficient, and customized experience.
NetLeaders may collect, access and use Customer Data for the following purposes:
1. Set up, maintain and manage the user’s account
2. Conclude and execute the License Agreement
3. Conclude and execute the agreement with you as an Advocate if you apply for an Advocate status
4. Provide, maintain, measure and improve the Services
5. Process transactions and send communication about your transactions
6. Resolve disputes and collect fees
7. To prevent or troubleshoot technical problems and security issues
8. As required by law for invoicing and fulfilling tax duties
9. As permitted by the Data Request Policy
10. Verify your identity according to the KYC standards with your explicit consent through a processor
We also use other kinds of information in providing the Services. This information is used to:
This policy is not intended to place any limits on what we do with data that is aggregated and/or de-identified so as to no longer be associated with an identifiable user of the Services.
We will not use your personal information without your permission for purposes other than those purposes we have disclosed to you.
We will never sell or rent your personal information to third parties.
From time to time we may request your permission to allow us to share your personal information with third parties. You may opt out of having your personal information shared with third parties.
CL Singapore Pte. Ltd, will be the data controller of your personal data provided to, or collected by or for the purposes indicated above. Data controller registered office is in Singapore at 6 Raffles Quay #11-07, Singapore 048580, ACRA Singapore number 201615510K.
CL Singapore Pte. Ltd has appointed the following representative in the European Union:
Vision Exchange Building
Mriehel Birkirkara BKR 3000 Malta
Identification number C78511
We or companies we work with may place small data files called cookies or pixel tags on your computer or device. We use these technologies to distinguish you from other users of our website. This helps us to provide you with a better experience when you browse our website and also allows us to improve our site.
Privacy choices: The help section of most browsers or browser add-ons provides instructions on blocking, deleting, or disabling cookies. You are free to decline our cookies if your browser or browser add-on permits, but doing so may interfere with your use of DNE Services.
If you use your NetLeaders account in connection with the purchase or sale of goods or services, we or you may provide the seller with:
The seller is not allowed to use this information to market their services to you unless you have explicitly agreed to it.
If an attempt to transfer to your seller fails or is later invalidated, we may provide your seller with details of the unsuccessful transfer.
In connection with a transfer between you and a third party, including merchants, a third party may share information about you with us, such as:
This information may be used to inform you that a transfer has been sent to or received from the third party. We may use this information to confirm that you are a NetLeaders customer. If you request that we validate your status as a NetLeaders customer with a third party, we will do so. Please note that merchants you interact with may have their own privacy policies, and NetLeaders is not responsible for their operations.
If you authorize one or more third-party applications to access your NetLeaders account, the information you have provided to NetLeaders may be shared with those third parties. Unless you provide further authorization, these third parties are not allowed to use this information for any purpose other than to facilitate your transactions.
Sharing within the network matrix: If you are an Advocate in our system, we or you may also provide members in your upline or downline with your name and contact information to enhance communication within the Advocate network. The recipient is not allowed to use this information to market other services to you unless you have explicitly agreed to it.
We may share your personal information with the following processors:
Identity verification services in order to prevent fraud (this allows NetLeaders to confirm your identity by comparing the information you provide us to public records and other third-party databases; these service providers may create derivative data based on your personal information that can be used solely in connection with provision of identity verification and fraud prevention services).
Service Providers under contract who help with parts of our business operations such as bill collection, marketing, and technology services (our contracts require these service providers to only use your information in connection with the services they perform for us, and prohibit them from selling or disclosing your information to anyone else).
The current list of processors can be found here.
NetLeaders accounts can only be created on netleaders.com and we are not responsible for accounts set up on a third-party website or via a third-party application.
We may disclose your data when we are compelled to do so by a subpoena, court order, or similar legal procedure; or we believe in good faith that the disclosure of personal information is necessary to prevent physical harm or financial loss, to report suspected illegal activity or to investigate violations of our License Agreement.
NetLeaders implements industry standard access controls and detection capabilities for the internal networks that support its products. Network access control mechanisms are designed to prevent network traffic using unauthorized protocols from reaching the product infrastructure.
A selection of NetLeaders' employees have access to the products and to customer data via secured interfaces. Employees are granted access by role, and reviews of high risk privilege grants are initiated weekly. Employee roles are reviewed at least once every six months.
NetLeaders and the data center providers use commercially reasonable efforts to ensure a minimum of 99% uptime.
NetLeaders makes HTTPS encryption (also referred to as SSL or TLS) available on every one of its login interfaces. The HTTPS implementation uses industry standard algorithms and certificates.
NetLeaders maintains a record of known security incidents that includes description, dates and times of relevant activities, and incident descriptions. Suspected and confirmed security incidents are investigated by security, operations, or support personnel; and appropriate resolution steps are identified and documented. For any confirmed incidents, NetLeaders will take appropriate steps to minimize product and Customer damage or unauthorized disclosure.
If NetLeaders becomes aware of unlawful access to Customer data or any data breach, NetLeaders will:
1. Communicate high-risk breaches to affected data subjects without undue delay
2. Notify the relevant Data Protection Authority of high-risk breaches within 72 hours of the breach.
3. Provide the Customer with a description of the steps NetLeaders is taking to resolve the incident.
4. Provide status updates to the Customer contact, as NetLeaders deems necessary.
Notification(s) of incidents, if any, will be delivered to one or more of the Customer’s contacts in a form NetLeaders selects, which may include via email or an online notice in case email communication would involve disproportionate effort.
We provide access options about the collection, use and sharing of your data, including correcting your account data, marketing opt-outs and processor controls. We also offer deletion of the personal data we have about you. Detailed information on your rights relating to the processing of personal data can be found in the Data request Policy, constituting an enclosure to this Policy.
While verifying your identity according to the KYC standards we may apply the automated decision-making procedures and ask you for additional documents if the results of the verification will be negative. However, in such a case, you have the right to request an investigation of your case by our personnel. State your case and object our decision. If you fail the KYC verification you will not be allowed to perform any transactions. More information regarding this policy can be found in our KYC Policy.
We will keep your profile open, unless you decide to close your account. If you choose to close your NetLeaders account, your personal data will generally be deleted within 30 days of account closure, except as noted below. We will keep some de-personalized information after your account has been closed.
We retain your personal data even after you have closed your account in the following situations:
In cases specified above we will retain your information only to the extent required for a particular purpose for a period of maximum ten (10) years (claims’ limitation period) as of closing your account. In some cases, we choose to retain certain information (e.g., visits to pages) in a depersonalized or aggregated form.
We process data both inside and outside of the European Union and EEA countries. When in transit, the data will remain encrypted with at least the then current industry standard, and the appropriate safeguards as defined in Art. 46 of GDPR shall be applied.
Your personal data may be transferred to the following third countries outside EU and EEA: Serbia, Hong Kong, Singapore, India, which are not covered by the adequacy decisions of European Commission, to Canada and Switzerland, which are covered by the adequacy decisions of European Commission, and to the USA.