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Privacy Policy 

Last updated: 26 August, 2023 is a website owned and operated by Hamster Ltd, a company incorporated in the Marshall Islands with registration number 115596 and registered office at P O Box 405, Majuro, Marshall Islands (“we”).

This privacy policy describes how we manage our user’s (“you”) personal information which we may collect as a result of your use of and any pages or websites under our brand including any applications that are owned and operated by us (“website”) in provision of services (“services”). 

We are committed to ensuring that your personal information is protected and is used, stored and disclosed in accordance with this privacy policy and the laws of the Marshall Islands.

Website Use

In using the website, you agree to be bound by the terms of this privacy policy. We may review the privacy policy periodically and reserve the right to change the privacy policy at any time at its discretion by posting such changes on the website. Changes will be effective immediately when posted on the website. Your continued use of the website following posting will constitute your acceptance of those changes.

This privacy policy will not apply to any third-party or external websites which are linked to the and over which we have no control.

Personal Information

“Personal Information” means personal identifiable information that we directly associate with a specific person or entity, which may include without limitations, name, addresses, telephone numbers, email address, payment information, unique device ID, device location, IP address, usage date, and other such related information.

Collection & Purposes

To access the website and avail the services, we are legally required to identify you. When you register for the website and services and/or access them, or contact us through any interaction via emails, telephone calls or other correspondence, we may ask you to voluntarily provide us with certain information that personally identifies you or could be used to personally identify you. You hereby consent to the collection of such information by us. 

We shall be free to use, collect and disclose information that is freely available in the public domain without your consent.

We may use the Personal Information collected for a variety of business purposes, including the following:

  1. For maintaining your account;
  2. For providing customer services to you;
  3. For ensuring that our legal and statutory obligations are complied with;
  4. For identifying and suggesting products or services that might interest you;
  5. For verifying your identity and maintaining a record of your transactions and interactions with us;
  6. For processing any transaction as applicable;
  7. For making internal business decisions about current and future service offerings;
  8. For creating, modifying, improving, enhancing, removing or fixing our services and their performance;
  9. For providing you customized user experiences, including personalized services offerings;
  10. For protecting our rights, interests, safety and property and that of our customers, service providers and other third parties and affiliates;
  11. We may use Personal Information for investigations or for prevention of fraud, for consumer protection or network abuse and to protect our users;
  12. We may disclose and use personally identifiable information in the course of resolving disputes, problems troubleshoot, enforcement of the Terms of Use or other legal rights, or to alert you to changes in our policies or Terms of Use that may affect your use of the website
  13. For sending periodical information and updates on you pertaining to our present and future offerings.

How Personal Information About You is Collected

We collect information about you in three primary ways:

  1. Information you Voluntarily Provide. We collect information that you voluntarily provide to us when you register for or use the website, or otherwise communicate with us. Without limitations, provision of information by you may include the following: information provided when you contact us or register to participate in our affiliated products, KYC information, provide us with your personal contact information, billing information and any information shared with payment processors, all as may be necessary for the provision of the services, or the interaction executed by you.
  2. Upon the establishment or modification of an account, we may collect user identification information, passwords, security question responses or other elements related account security, or any other means of identification, which you will use for future sign on.
  1. Upon interaction with our Customer Service representatives or anyone acting on our behalf, or once you enter information on the website, submit survey responses, we may also collect Personal Information and other data. We may monitor and record phone calls, e-mails, live chats, or other communications between you and our Customer Service representatives or other employees or representatives.
  2. Due to the communications standards on the internet, when  you access our website, we automatically receive the URL of the site from which you have visited our website. We also receive the Internet Protocol (IP) address of your computer (or the proxy server you used to access the website), your computer operating system and type of web browser you are using, as well as the name of your ISP. This information is used to analyse overall trends to help us improve. The linkage between your IP address and your personally identifiable information is not shared with or disclosed to third parties. Notwithstanding the above, we may share and/or disclose some of the aggregate findings (not the specific data) in anonymized form (i.e., non-personally identifiable) with advertisers, sponsors, investors, strategic partners, and others in order to help grow its business.

The Use of Cookies

“Cookies” hereby refers to a small text file that a website can place on your hard drive, in order to collect information about your activities on the website. The cookie transmits information back to the website system, which is the only computer that can read it. We may use cookies on the website to enhance your experience and avoid multiple logins or password authentication requests.

In addition, your use of the website may direct you to certain advertisers or third-party website providers which may also use cookies or similar web tags (small data text files placed on your computer or device) or similar technologies to identify your computer or device and record your preferences and other data for the purpose of personalizing your visits, see which areas and features are popular, and improve your experience and use of the services and websites provided. We do not exercise control over the sites displayed as search results or links from the website. These other sites may place their own cookies or other files on your computer, collect data or solicit personal information from you, for which we are not responsible or liable. Accordingly, we do not make any representations concerning the privacy practices or policies of such third parties or terms and conditions of such platforms, nor do we guarantee the accuracy, integrity, or quality of the information, data, text, software, sound, photographs, graphics, videos, messages or other materials available on such websites. If you decide to visit a third-party link/website linked to the website, you do this entirely at your own risk.

Depending upon the device used, you may be able to set your browser to reject cookies or delete cookies, but that may result in the loss of some functionality on the website.

Use for Marketing and Advertising

Occasionally we may use your Personal Information to inform you about new products or services or about promotional activities which we believe may be of interest or of benefit to you. We may do this via email, SMS, telephone or mail. If you no longer wish to receive marketing or promotional material from us at all or in any particular form, you may contact us at any time by email to [email protected] with your request with which we will comply as soon as is practical.

From time to time, we may contact you in relation to the management and administration of your account. These communications can be via any of the modes of contact recorded when registering as a user. Such communication does not affect your opt-in or opt-out status for direct marketing communications.

When We Share Information Collected About You

Except as detailed in this privacy policy, we do not sell, license or otherwise provide your Personal Information to unaffiliated third parties, without your consent. 

We may, however, disclose your information to unaffiliated third-parties with your consent obtained in either writing, online, through “click-through” agreements and downloads, upon acceptance by you of the terms of disclosures for certain services, in writing (including without limitations by chat or email) or orally, when you interact with our customer service representatives.

How We Store and Protect Personal Information

We may use a variety of physical, electronic, and procedural safeguards to protect Personal Information from unauthorized access, use, or disclosure while it is under our control. Unfortunately, no data transmission over the internet can be guaranteed to be completely secure. As a result, although we utilize security measures, we may not guarantee you against the loss, misuse, or alteration of Personal Information under our control, and you provide Personal Information to us at your own risk. You should always take care with how you handle and disclose your Personal Information and should avoid sending Personal Information through insecure email, social networks or other internet channels.

No administrator will have knowledge of your password. It is important for you to protect against unauthorised access to your password, your computer and your mobile phone. Be sure to log off when finished. We do not undertake any liability for any unauthorised use of your account and password. If you suspect any unauthorised use of your account, you must immediately notify us by sending an email. You shall be liable to indemnify us due to any loss suffered by us due to such unauthorised use of your account and password.

We make all information accessible to our employees, agents or partners and third parties only on a need-to-know basis, and bind them to strict confidentiality obligations.

We are not responsible for the confidentiality, security or distribution of your personal information by our partners and third parties outside the scope of our agreement with such partners and third parties. Further, we shall not be responsible for any breach of security or for any actions of any third parties or events that are beyond our reasonable control including but not limited to, acts of government, computer hacking, unauthorised access to computer data and storage device, computer crashes, breach of security and encryption, poor quality of Internet service or telephone service etc.

Retention and Disposal 

We retain information for as long as we have a business or tax need or as required under the applicable laws, regulations and/or government orders from time to time. Following termination of the Account, we shall endeavor to erase and discard of your data subject to the limitations and requirements under the applicable laws and regulations.

Transfer to other countries

For the purpose of providing you with the services, we may transfers your information to different countries outside your country where we have the infrastructure facilities. By using the website, you consent to the transfer of your information outside of your country.

Your rights

1. Right to Access & Correction: You have the right to access your Personal Information and to require the correction, updating and blocking of inaccurate and/or incorrect data by sending an email [email protected].

Upon your written request, we will inform you of the Personal Information relating to you that we hold and the use and general disclosure of your Personal Information. We will also give you a copy of the Personal Information that we have retained. There may be a minimal charge for providing you additional copies of your Personal Information to cover administrative costs.

2. Right to Delete: You may also request the deletion or destruction of both your account and Personal Information by sending an email to us at [email protected]. We will action your request immediately, except, where this is not consistent with its legal and regulatory obligations.

3. Right to Transfer: You may also ask us to transfer your Personal Information to an authorised representative or agent appointed by you.

4. Right to Restriction on Processing: In the event that you wish to restrict or process the personal information due to the information (i) being incorrect (ii) being not lawfully processed (iii) being deemed by you as not required by us or (iv) you decide so in sole discretion, we shall cease from processing your personal information upon receiving a written request.

5. Right of Notification: If in case, despite our best efforts, we suffer a data breach which in our opinion may put your personal information at risk, we shall notify you and relevant authorities within 72 hours of us becoming aware of such breach.

To ensure the confidentiality, integrity and availability of your information to yourself, we may request you to confirm your identity by providing identification documentation and/or other methods prior to assisting you in exercising any of your rights. 

If you refuse to prove your identity, we may decline to take actions in respect of your data, save restricting processing, until we can ensure that such actions are the true wish of the data subject.

We may use automated processing and profiling to reduce the risks of fraud, money laundering and abuse of our services.  


The Company has appointed a data protection manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the data protection manager at [email protected]

Governing Law

This Privacy Policy shall be governed by the laws of the Marshall Islands; and, shall be subject to the exclusive jurisdiction of courts at Majuro.