Privacy Policy

[Privacy Policy Updates] Latest Update Time: 2023-12-25

This Privacy Policy explains how Scratch (“we,” “us,” “our”) collects, uses, shares, and protects user information obtained through the Scratch website (https://scratchcrypto.com), or our mobile applications, or any other related services provided by Scratch. When we ask for certain personal information from users, it is because we are required by law to collect this information or it is relevant for specified purposes. Any non-required information you provide to us is done so voluntarily. You decide whether to provide us with this non-required information; you may not be able to access or utilize all of our services if you choose not to.

By using this site and related Application Programming Interfaces (API) or mobile applications, you agree to the policies and practices of our Privacy Policy, so please read this document carefully.

This Privacy Policy explains what data we collect, how we use and store such data, and how we share such data. If you do not wish to have your Personal Data (as defined below) used in the manner described in this Privacy Policy, you may not use the site or any of the services, software, APIs, technologies, products, and/or features offered by

Scratch.

Definitions

Virtual Financial Asset

As used herein, “Virtual Financial Asset” also called “convertible virtual currency”, “cryptocurrency” or “digital goods”, such as bitcoin or ether, which is based on the cryptographic protocol of a computer network that may be (i) centralized or decentralized, (ii) closed or open-source, and (iii) used as a medium of exchange and/or store of value.

Personal Data

As used herein, “Personal Data” means any information relating to an identified or identifiable natural person, such as a name, an identification number, location data, an online identifier, or one or more factors specific to the physical, economic, cultural, or social identity of you as a natural person.

2. WHAT PERSONAL DATA WE COLLECT

Scratch collects, processes, and stores Personal Data collected from you via your use of the Service or where you have given your consent. This Personal Data may include contact details, copies of identification documentation provided by you or derived from publicly accessible databases, your government identification number, as well as information relating to your device or internet service (such as an IP address and a MAC number).

Operating within certain jurisdictions around the world, Scratch collects, stores, and processes your personal data inaccordance with the various regulations to which we are subject. We aim for the highest standards of compliance and adherence to all data privacy requirements. The following provisions in this Privacy Policy are an amalgamation of these regulations to which our company is subject and serve as a single policy point to govern our data collection, storage, and processing activities. As these regulations may be amended from time to time, we are required to ensure that our data practices are up to date by amending the provisions in this Privacy Policy accordingly.

We collect the information you provide during the Scratch onboarding process, which may be a completed, incomplete, or abandoned process. We also collect personal data when you communicate with us through customer support, subscribe to marketing messages, or contact us by phone, email, or other communication channels. We collect, use, store, and transfer your Personal Data, which may include the following:

Individual users:

Email address
Mobile phone number
Full legal name (including former name and names in the local language)
Nationality
Passport number or any government-issued ID number
Date of birth (“DOB”)
Proof of identity (e.g., passport, driver’s license, or government-issued ID)
Residential address
Proof of legal existence
Additional Personal Data or documentation at the discretion of our Compliance Team
IP address
Device ID

Corporate users:

Corporate legal name (including the legal name in the local language)
Incorporation/registration Information
Full legal name of all beneficial owners, directors, and legal representatives
Address (principal place of business and/or other physical locations)
Proof of legal existence
Description of the business
Percentage of ownership for individual/corporate owners
Contact information of owners, principals, and executive management (as applicable)
Proof of identity (e.g., passport, driver’s license, or government-issued ID) for the significant individual beneficial owner of the institutional customer entity
Personal Data for each entity’s significant beneficial owner of the institutional customer entity (see the “Individual users” section above for details on what Personal Data we collect for individuals)
Source of wealth
Amount of fiat money injected
Amount of bitcoin or other digital assets projected to be injected

3. COLLECTION AND TRANSFER OF DATA OUTSIDE OF YOUR JURISDICTION

As we (Scratch) may collect Personal Data from users located in different jurisdictions, and most of these jurisdictions will require consent for the transfer of such Personal Data from your jurisdiction to outside of the area, your explicit consent is required and hereby assumed by way of your use and/or continued use of Scratch. If you decline to consent to such transfer, you will no longer be able to use Scratch’s platform and/or services. You will have the ability to withdraw your digital assets; however, all other functionalities will be disabled.

5. HOW WE USE YOUR PERSONAL DATA

Scratch uses Personal Data to communicate with you and to administer, deliver, improve, and personalize the Service. Scratch might also generate generic data out of any Personal Data we collect and use it for our own purposes. We may also use such data to communicate with you in relation to other products or services offered by Scratch and/or its partners. We do not share your Personal Data with third parties (other than partners in connection with their services to Scratch) except where you have given your consent and further detailed below.

We may share your Personal Data with third parties:

(a) if we think that sharing it is necessary to enforce the Terms of Service;

(b) to comply with government agencies, including regulators, law enforcement, and/or justice departments;

(d) in connection with the sale or transfer of our business or any part thereof.

Additionally, we have implemented international standards to prevent money laundering

and terrorist financing and will implement final regulations when effective, which will likely require us to undertake due diligence on our users. This may include the use of third-party data and service providers which we will cross-reference with your personal information.

To enhance the sharing functionality, Scratch uses MobTech’s ShareSDK product. The privacy policy for this product can be found at: [insert link to privacy policy]

HOW WE STORE YOUR PERSONAL DATA

We aim to protect users and Scratch from unauthorized access, alteration, disclosure, or destruction of the personal data that we collect and store. We take various measures to ensure information security. We store your data securely in fault-tolerant secure storage that is encrypted with industry standards, and take multiple security measures to ensure that user data will not be lost, abused, or altered.

Please note that while we take these security measures, it is impossible to guarantee 100% security of information. Therefore, we request that you understand the responsibility to independently take safety precautions to protect your own personal information.

6. ACCESS, CORRECTION, AND DELETION OF YOUR PERSONAL DATA

You have the right to obtain a copy of your Personal Data upon request and ascertain whether the information we hold about you is accurate and up-to-date.

If any of your Personal Data is inaccurate, you may request to update your information. You may also request to delete your Personal Data, with the exception that we may refuse your deletion request in certain circumstances, such as compliance with law or legal purposes. For data access, correction, or deletion requests, please contact support@scratch.com with the subject “DATA INQUIRY”.

In response to a data access, correction, or deletion request, please note that we will take steps to verify the identity of the requester before taking any action. This is to ensure the legitimacy of the request and protect the privacy and security of your Personal Data. Due to possible complexities and time differences, we are unable to commit to a specific timeline for fulfilling such requests, but we will make reasonable efforts to do so.

7. MARKETING

We may communicate company news, promotions, and information relating to our products and services provided by Scratch. We may share Personal Data with third parties to help us with our marketing and promotional efforts, or send marketing communications. By using Scratch, you accept this Privacy Policy and you agree to receive such marketing communications.

You have the option to opt out of these marketing communications at any time. If you do not want to receive these communications, please send an email to support@scratchapp.com with the subject “MARKETING OPT-OUT”.

For product-related communications, such as policy/terms updates and operational notifications, you will not be able to opt out of receiving such information.

8. COOKIE USAGE

While you access Scratch, we may use the industry practice of placing a small amount of data that will be saved by your browser (Cookies). This information can be placed on your computer or other devices used to visit Scratch. This information helps us recognize you as a user and collect information about your use of Scratch to better customize our services and improve your experience. We may also use the information collected to ensure compliance with our compliance program, and to ensure the security of your account by detecting irregular or suspicious account activities.

Most browsers are set up to accept cookies automatically. Some cookies expire when you end the session, while others remain on your computer or devices until deleted or expired. You have the option to decline the use of our cookies, but this may impact the functionality of Scratch services or your user experience.

9. CONTACTING Scratch ABOUT PRIVACY QUESTIONS OR CONCERNS

If you have any questions or concerns about this Privacy Policy or the use of your Personal Data, please contact us by sending an email to support@scratchapp.com with the subject “PRIVACY INQUIRY”.

For users in the European Economic Area, you have the right to request that unresolved issues regarding the collection, use, or disclosure of your personal information comply with the requirements of the applicable regulatory authority in your jurisdiction.

10. CHANGES TO OUR PRIVACY POLICY

Any changes we make to our Privacy Policy in the future will be posted on this page and, when appropriate, we will notify you by notification on the Scratch website. Please check back regularly for any changes and updates. As mentioned in this Privacy Policy, your use and/or continued use of Scratch constitutes your implicit agreement to the terms herein as well as any amendments, changes, or updates that may be made. It is your responsibility to review this Privacy Policy for any such amendments, and Scratch shall not be held legally or financially liable for any consequences resulting from your failure to do so.

LANGUAGE OF USE

This Privacy Policy may be published in multiple languages. In the event of any discrepancy, please refer to the English version.