By accessing or using the Services you represent, warrant and undertake that you:
- are at least 18 years of age;
- have full legal capacity to consent and be bound by all of the terms, policies, practices and procedures set out herein;
Where you disclose Personal Data on behalf of any other individual you represent, you warrant and undertake all of the above on behalf of that individual.
1. Personal Data
“Data Protection Laws” means the Singapore Personal Data Protection Act 2012 (Act 26 of 2012) and the European Union’s General Data Protection Regulation (EU) 2016/679 (“GDPR”), as amended from time to time, together with any implementing acts or instruments, and any similar legislation that is applicable to you. The Data Protection Laws that will apply to you will largely be dependent on the jurisdiction in which you are located or resident.
“Personal Data” means any data relating to an identified individual or any data, whether true or false, about an individual who can be identified from that data on its own or from that data and other information to which we have or are reasonably likely to have access.
Personal Data that we may collect from you includes but is not limited to the following:
Name, date of birth, gender, place of birth, citizenship, home address, telephone number, fax number, email address, signature;
Passport information, national identity card information, driver’s license information, tax identification number, photograph, visa information, signature;
Proofs of address or residence such as bank statements, utility bills, phone bills, tax returns;
Payment related information such as bank account details, credit card information, credit history, Digital Payment Token addresses, source of funds information;
Trading data such as account balances, trading activity, deposits, withdrawals and orders; and
Information relating to your accessing the Website and Services such as username, password, account settings, preferences, membership details, cookies, IP addresses, domain names, browser details, server logs and device information.
2. Collection of Personal Data
We collect your Personal Data at various times including when you:
- Register for an Account or to use any of the Services;
- Contact us with a query or request for assistance;
- Interact with us in through any medium e.g. online forms, live chat, social media, email, telephone, letters, face to face meetings;
- Sign up for alerts, mailing lists, newsletters or similar;
- Participate in a competition, survey, promotion;
- Visit our Website or use any of the Services;
- Respond to requests from us for the provision of Personal Data; and
- Submit forms or enquiries to us online
3. Use of Personal Data
We generally use your Personal Data in connection with the following purposes:
- Processing registrations and carrying out KYC, CFT and AML checks;
- Verifying information provided and your eligibility to use the Services;
- Maintaining your Account;
- Operating, providing and administering the Services;
- Reviewing, monitoring, maintaining, developing, upgrading, improving and personalising the Services;
- Ensuring the security and integrity of the Services and their underlying infrastructure;
- Assessing and ensuring compliance with internal procedures and policies;
- Informing you of updates or amendments to our Terms and Conditions, policies, fees and other administrative information relevant to your use of the Services;
- Providing you with information relevant to your use of the Services which we consider may be of interest to you;
- Communicating with you and responding to complaints, queries and requests;
- Dealing with disputes and any related investigations or legal proceedings;
- Preventing, detecting and investigating fraud, money laundering and other crime;
- Providing assistance to and cooperating with law enforcement, judicial and governmental authorities;
- Protecting, performing and enforcing our legal rights and obligations;
- Complying with applicable law, regulatory requirements and guidelines;
- Conducting market research, data analytics and surveys to assist us in developing and improving our Services;
- Working with agents and third party service providers instructed in connection with the provision of the Services; and
- Facilitating any proposed acquisition, merger, partnership, joint venture, asset sale or purchase involving the Company or any of its affiliates.
The purposes set out above are non-exhaustive and you may be notified of additional purposes for which we use your Personal Data. We may also use your Personal Data in connection with the following marketing-related activities:
- Informing you of promotions, reward programmes, competitions, contests and events;
- Sending you newsletters and industry/market updates; and
- Targeted marketing in respect of third party goods and services that may be of interest you
Should you wish to opt out of such marketing activities please email us at email@example.com with the subject title “OPT-OUT Marketing” and once your email has been processed we shall no longer collect, process, use, share or disclose your Personal Data for such purposes. Should you wish to opt back in at any time thereafter please email us at firstname.lastname@example.org with the subject title “OPT-IN Marketing”.
4. Disclosure of Personal Data to Third Parties
We will take reasonable care to ensure that your Personal Data remains confidential and will only permit your Personal Data to be accessed by:
- Third parties that have a legitimate basis for accessing it.
We will generally only share your Personal Data with the following parties in the following circumstances:
- In order to satisfy KYC/AML/CFT requirements, confirm your identity and to assist with the prevention of illegal activity such as money laundering and fraud, we may share your Personal Data with identity verification providers, credit bureaus or credit reporting agencies and transaction monitoring services;
- In order to facilitate the provision of the Services, we may share your Personal Data with service providers, vendors and agents that have been contracted to provide various services including but not limited to administrative, payment, payroll, financial, technological, marketing, operational, training, research, custodial and storage services;
- In order to obtain and maintain insurance, credit lines and banking facilitates we may share your Personal Data with insurance providers, credit providers and other financial institutions;
- In order to facilitate the promotion of products or services of third parties with whom we do business, we may share your Personal Data with those third parties;
- In order to facilitate a proposed merger, acquisition, assignment, asset sale or disposal, or similar business transaction, we may share your Personal Data with other entities or investors involved therewith;
- In order to comply with a court or tribunal order, subpoena or any other formal legal procedure or process, any investigation whether instituted by a third party or us, any applicable law or regulation, or where we in our sole discretion deem it necessary or prudent to do so, we may share your Personal Data with law enforcement agencies, regulators and government and inter-governmental agencies;
- In order to enforce our rights under the Terms and Conditions we may share your Personal Data with debt collection agencies and dispute resolution bodies;
- In order to seek professional advice, we may share your Personal Data with our professional advisors; and
Please note that the above is not an exhaustive list and we may share your Personal Data in other circumstances and to other third parties, in accordance with applicable law.
5. International Transfers of Personal Data
We are headquartered in Singapore and so your Personal Data will be stored, primarily, in our data storage facilities in Singapore. In order to facilitate the provision of the services we will also need to transmit your Personal Data to various third-party services based in various jurisdictions around the world. This means that your Personal Data may be transferred to, processed and stored in multiple jurisdictions outside of your home jurisdiction or, if you are a resident or citizen of the European Economic Area, UK or any other jurisdiction to which the GDPR applies, in jurisdictions falling outside of any of the foregoing.
6. Security of Personal Data
The security of your Personal Data is of the utmost importance to us and we take all reasonable care to ensure that the Personal Data that we collect remains secure and protected from unauthorised access or use. Further to this we have adopted various technical and operational measures specifically designed to protect your Personal Data.
However, the security of your Personal Data cannot be absolutely guaranteed. No means of transmitting information via the internet or method of storing data can ever be viewed as completely secure. Therefore whilst we strive to adopt measures in line with industry standards in order to protect your Personal Data, we cannot guarantee its security.
Cookies are small pieces of data, stored in text files, that are stored on your computer, mobile phone or tablet when you visit a website, that allows that website or a third party to remember you and your preferences.
When you access our Website, we and other companies that we partner or work with may store cookies on your web browser in order to help:
- Personalise your user experience;
- Monitor and improve the performance of the Website;
- Monitor how you arrive at the Website and what type of browser or operating system you are using;
- Monitor which pages you view, when you view them and for how long;
- Monitor the total number of visitors to the Website; and
- Facilitate advertising by us and third parties on the Website and third party websites.
By accessing or using the Services you consent to the storage of cookies on your electronic device as set out above. Notwithstanding all web browsers provide the option of disabling cookies and so you may exercise this option if you choose. Please note that disabling of cookies may affect your user experience and you may not be able to access all parts of the Website or enjoy the full functionality of the Services offered.
8. Retention of Personal Data
Under Singapore’s Limitation Act (Cap.163), contractual claims must be brought within six years from the date on which the cause of action accrued. Accordingly, we reserve the right to retain any Personal Data collected for six years following the date of termination or closure of your Account. Unless obliged by legal or regulatory requirements to retain your Personal Data for a longer period, or an ongoing dispute necessitates such longer retention, on the expiry of the aforementioned six year period we shall destroy, delete or anonymise your Personal Data and/or take any other steps required to comply with our legal and regulatory obligations.
9. Minor’s Privacy
Our Services are designed to be used only by individuals who are at least 18 years old and when a User provides any information to us, that User represents that he or she is at least 18 years old. We do not knowingly collect any Personal Data from individuals under 18 years old. If we have reason to suspect that an individual submitting information to us is younger than 18 years old we shall require the immediate closure of the relevant Account. We will then take steps to delete or destroy any Personal Data collected in connection therewith. If you become aware of any individuals under the age of 18 using our Services please inform us immediately so that appropriate steps can be taken.
10. Third Party websites
11. Your Rights
Depending on the Data Protection Laws applicable to you, you may be entitled to certain rights with respect to your Personal Data. We are only obliged to honour such rights to the extent that they have been conferred on you by applicable Data Protection Laws. We recommend you review your local Data Protection Laws in order to determine what right are available to you .
Such rights may include:
- Access to Personal Data. You may be entitled to confirmation that we process your Personal Data and, if so, to request access to the Personal Data which we hold. We may, to the extent permitted by applicable law, charge a reasonable administrative fee for the provision of such information.
- Erasure. You may be entitled to request that we erase some of the Personal Data which we hold about you.
- Restriction. You may be entitled to require that we restrict or limit the further use of your Personal Data, so that such Personal Data is restricted to being used for certain purposes only.
- Objection. You may be entitled to object to the use of your Personal Data so that we are required to no longer use some or all of your Personal Data.
- Rectification. You may be entitled to request that we rectify any incorrect Personal Data or complete any incomplete Personal Data which we hold about you.
- Data Portability. You may be entitled to a copy of your Personal Data in a structured, commonly used, and machine-readable format, and you may have the right to transmit that Personal Data to another entity.
- Right of Complaint. If you consider we have breached your legal rights you may have the right to submit a complaint to the relevant regulatory or supervisory body. We recommend you first contact us at email@example.com so that we can attempt to address your concerns directly.
The above rights are not in any way guaranteed and even if the Data Protection Laws applicable to you or the relevant scenario provide for such rights we may not, due to an exception or other applicable law, be obliged to comply.
12. Updating Personal Data
In order to be able to provide you with the Services, it is important that all Personal Data that you provide to us remains current and up to date. It is your responsibility to keep us updated of any changes to your Personal Data by emailing us at firstname.lastname@example.org. We shall not in any circumstances be held liable for any losses, costs, expenses, damages or liabilities arising from your failure to keep your Personal Data updated.
13. Governing Law
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