Privacy Policy

Last Update: May 16, 2019

We take privacy very seriously and have incorporated into the business model of (the “Platform”), the fight against data privacy attacks and security breaches. We are true believers in the principle that good technology products should not come at the sacrifice of your privacy and security and have designed the Platform as much as possible to enable a 1st class service without retaining your personal information.

As use of the Platform can involve our obtainment of some of your personal information (in the light of the broad scope of the definition of personal data under the GDPR), we ask that you read this website privacy policy (the “Policy”) carefully as it contains important information on who we are, how and why we collect, store, use and share the limited personal information we do collect, your rights in relation to your personal information and on how to contact us and supervisory authorities in the event you have a complaint.

This Policy also helps us in complying with our applicable global data privacy laws, including the EU General Data Protection Regulation (the “GDPR”).

Who we are

This website is operated by Clearflow PTE. Ltd, a company registered in Singapore under UEN number: 201842687D, and the following address: 24 RAFFLES PLACE #27-01 CLIFFORD CENTRE SINGAPORE (“We”, “we”, “our ”, or “us”).

We collect, use and are responsible for certain personal information about you. If you are located in the European Union including the United Kingdom when we do so, then we are regulated under the GDPR which applies across the European Union (including in the United Kingdom), and we are responsible as ‘controller’ of that personal information for the purposes of those laws.

Our website

This privacy policy relates to your use of our website, only (the “Platform”).

Throughout our website we may link to other websites owned and operated by certain trusted third parties to make additional products available to you. These other third party websites may also gather information about you in accordance with their own separate privacy policies. For privacy information relating to these other third party websites, please consult their privacy policies as appropriate.

Our collection and use of your personal information

We collect personal information about you directly when you carry out a transaction (“Transaction Event”), or contact us (“Contact Event”).

The following details the only personal information we collect about you:

We use this personal information to:

This website is not intended for use by children and we do not knowingly collect or use personal information relating to children.

Our legal basis for processing your personal information

When we use your personal information we are required to have a legal basis for doing so. There are various different legal bases upon which we may rely, depending on what personal information we process and why.

The legal bases we may rely on include:


So, to sum

In every Contact Event, we process your Contact Details to enable our Customer Service function, on the legal basis of the terms and conditions of the Platform;

In every Transaction Event we process a Bitcoin address to enable Transaction Processing, on the legal basis of the terms and conditions of the Platform; and

In Regulatory Communications we may process your Regulatory Information on the legal basis of our Legal Obligation.

Who we share your personal information with

Other than law enforcement or other authorities if required by applicable law, we do not share your information with any other third parties!

Whether information has to be provided by you, and if so why

We require you to provide the Bitcoin address to enable Transaction Processing, the Contact Details to enable our Customer Service and Regulatory Information for Regulatory Communications.

The impact of our use of your personal information

We are also located in Singapore, which is a jurisdiction outside the EEA, which may not have the same safeguards in relation to personal information as the safeguards that exist in EEA member states.

However, we implement internal safeguards (see ‘Keeping your information secure’ below); and have designed the product to obtain as little personal information as possible, to essentially heavily reduce the gravity of any losses that can occur via a data breach.

We do not otherwise transfer your personal information outside the EEA.

Cookies and similar technologies

A cookie is a small text file which is placed onto your device (eg computer, smartphone or other electronic device) when you use our website. We use cookies on the Platform. These help us recognise you and your device and store some information about your preferences or past actions.

For further information on our use of cookies, please see our Cookie policy

Your rights

Under the GDPR you have a number of important rights free of charge. In summary, those include rights to:

If you would like to exercise any of those rights, please:

Keeping your personal information secure

We have appropriate security measures in place to prevent personal information from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

How to complain

We hope that we can resolve any query or concern you raise about our use of your information. The GDPR also gives you the right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred.

Changes to this website privacy policy

This Policy was published on 20190507 and last updated on 20190507

We may change this website privacy policy from time to time, when we do we will inform you via a notice on the Platform or an email to the email address you provided.

How to contact us

Please contact us via email at, if you have any questions about this privacy notice or the information we hold about you.