Last updated: 13 December 2019
Welcome to XBourse.
XBourse Global Pte Ltd, a Singapore-registered company with its registered address at 10 Collyer Quay, #16-01 Ocean Financial Centre, 049315 (“we”, “our” or “us”), values your privacy.
1.1 The terms as used in this Policy will have the following meanings:
“Personal Data” means data or a combination of data, whether true or not, about you or that relates to you and that is sufficient to enable us to identify you, either when considered in isolation or together with other information that we have or are likely to have access to – including:
(a) the data set out in clause 4.1;
(b) information that you have provided to or made available to us, including while accessing or using the Website or our Services;
(c) information which we have collected as a result of you using the Website or our Services; and
(d) information about you that others using the Website or our Services have made available to us.
“Personal Data Protection Act” means the Singapore Personal Data Protection Act 2012.
(b) any third party services (including any third party websites) that you may access through the Website or our Services; or
(c) companies or organisations that advertise products or services through the Website or our Services.
2.2 Your use of any third party services, including any Personal Data you provide to such third parties and their collection and use of your Personal Data, are subject to the relevant third party’s own terms of services and privacy policies and not this Policy.
2.3 We may from time to time send you service-related announcements when we consider it necessary to do so (e.g. maintenance, security, privacy, or administrative-related communications). We send these to your email address. You may not opt-out of these service-related announcements, which are not promotional in nature and used solely to protect your account and keep you informed of important changes to the Website and our Services.
4. Collection of Personal Data
4.1 In order to provide you with our Services, we may collect, use, disclose or store the following data about you:
(a) information that you provide by filling in forms on the Website or through another remote channel connected to the Website, or that you otherwise send to us. This includes information provided when registering to use the Website, subscribing to our Services, posting material on the Website, and reporting a problem you have with the Website;
(b) if you contact us, records of such correspondence;
(c) details of transactions you carry out on the Website and our Services – including your account balance, trading activity and account history, details of your external bank and your financial arrangements;
(d) details of your visits to the Website and the resources that you access;
(e) documents uploaded on to the Website by you or others and metadata associated with such documents;
(f) details of other accounts that you may link to our Website; and
(g) other information that you may disclose to us, including your use of our Services.
5. Use of Personal Data
5.1 By accessing the Website or using our Services, you grant us permission to collect, use, disclose, copy, transmit, store and back-up your Personal Data for the purposes of providing you with our Services or access to and use of the Website, or for any other purpose(s) as contemplated by this Policy.
5.2 The purposes for which Personal Data may be used by us include:
(a) assessing whether you should be allowed to access and use the Website or any of our Services;
(b) providing you with alerts, newsletters, education materials, or information that you have requested or signed up to;
(c) carrying out our obligations under any contracts you have entered into with us;
(d) investigating any suspicious activities;
(e) complying with Applicable Laws in Singapore or in any other jurisdiction;
(f) evaluating and improving upon our Services;
(g) promoting and marketing our Services and any other products or services we may offer (subject to clause 9.1(d) below); and
(h) purposes directly related to or incidental to any of the above.
5.3 We will keep your Personal Data that is within our possession and control confidential and take reasonable steps to prevent unauthorized disclosures of your Personal Data. However, we may disclose your Personal Data:
(a) to our Affiliates;
(b) to our personnel, employees, agents, advisers, auditors, lawyers, contractors, financial institutions, and service providers to the extent necessary for the provision and maintenance of the Website or our Services or in connection with any of our operations;
(c) pursuant to Applicable Laws
(d) to Governing Bodies; or
(e) in the event of an internal restructuring of our or our Affiliate’s businesses, or the sale of the Website or our Services or any of its assets to a third party, the entity that consequently operates the Website or our Services may be a different entity to us and we will transfer your information accordingly so that your service can continue.
5.4 We may aggregate your Personal Data together with similar data from other users. This aggregate data will be produced in a manner that means it is no longer identifiable to any specific user, including yourself. We may share such aggregated data with third parties to help us improve or enhance our products and services and for marketing, research, or academic purposes.
6.1 A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer and of your other devices. Cookies contain information that is transferred to your computer’s hard drive.
6.4 You can block or restrict cookies by activating the relevant settings on your device or internet browser. Please note that such blocking or restrictions of our cookies may impact our provision of the Website or our Services to you, including not being able to provide them at all.
7. Security of your personal data
7.1 We use a variety of security technologies and procedures for the purpose of preventing loss, misuse, unauthorised access, or disclosure of Information – for example, we use encryption technology (such as SSL) to protect certain sensitive information provided by you to us.
7.2 Please be aware that despite our efforts, no data security measures can guarantee 100% security at all times. We do not warrant or guarantee the security of, or any information you provide to us through, the Website or our Services.
7.3 We may allow you to share certain Personal Data publicly on the Website or via our Services. Such shared Personal Data will remain publicly-available for so long as you or a user that has shared such information retains it. Even after you delete such shared information, it may still be separately cached, copied, or stored by, or remain public through, other users or third parties who are not affiliated with and not controlled by us. Please consider carefully what you post and communicate via the Website and Our Services.
8. Retention and transfer of your Personal Data
8.1 We will retain your Personal Data until the purpose for which that Personal Data was collected is no longer being served by the retention of the Personal Data, and the Personal Data does not need to be retained any longer for any purpose.
8.2 Subject to Applicable Laws– should you or we terminate your account for any reason, we will take steps to ensure that your Personal Information is no longer available through the Website or our Services, or otherwise used by us, within a reasonable period of time (subject to technical limitations) after such account termination.
8.3 We may retain, transfer or process your Personal Data outside Singapore. We will comply with Applicable Laws in relation to such retention, transfer, or processing for as long as the data remains within our possession or control. We will take reasonable measures to ensure that the recipient(s) of your Personal Data located outside Singapore will treat your Personal Data with a level of protection that is comparable to that required by the Personal Data Protection Act. You may at any time inform us that you wish to withdraw your consent to such disclosure, transfer, storage, or processing of your Personal Data. However, this may affect or remove our ability to provide you with certain or all of the Website or our Services.
9. Your consent and rights
9.1 Under the Personal Data Protection Act, you have the right to (amongst other things):
(a) access your Personal Data held by us;
(b) require us to correct any data relating to you that is inaccurate as soon as reasonably practicable;
(c) ascertain our policies and practices in relation to Personal Data and the kind of Personal Data held by us; and
(d) object to the use of your Personal Data for marketing purposes and require that we do not use your Personal Data for marketing purposes after you communicate your objection to us.
9.2 However, please note that Singapore law allows us to refuse such requests under certain circumstances, such as where:
(a) the burden or expense of providing access to the relevant data would be unreasonable to us or disproportionate to your interests; or
(b) disclosing such Personal Data would reveal confidential commercial information that could reasonably be expected to harm our competitive position.
9.3 Please send any such objections, and any requests for:
(a) access to or correction of Personal Data;
(b) information regarding this Policy;
(c) the Personal Data we hold; and
(d) any questions or complaints,
to our Data Protection Officer via email at firstname.lastname@example.org. We reserve the right to charge a reasonable fee for processing any such data access objections or request(s).
10. AGE RESTRICTIONS
10.1 We do not knowingly collect Personal Information from anyone under the age of 18 years old (and do not permit anyone under such age to use the Website and our Services). Please contact our Data Protection Officer if you believe we have any Personal Information from any such person – we will promptly investigate (and remove) such Personal Information.