1. INTRODUCTION AND APPLICATION
1.4 The words "we", "us", "our" or any of their derivatives refer to Tradable Patterns and its successors and any novatee, assignee, transferee or purchaser of Tradable Patterns' rights and/or obligations hereunder and any reference to Tradable Patterns includes a reference to such successor, novatee, assignee, transferee or purchaser. The words "you", "your", "yours" or any of their derivatives refer to the person using our Services, operating any account maintained with us, accessing our Platform, website or mobile applications, or otherwise providing information to or communicating with us and shall include, as the context may require, personal representatives (as the case may be).
2. PERSONAL DATA THAT WE COLLECT
2.2 The Personal Data that we collect or may collect include:
(a) personal contact data including first name, last name, email address, city and country;
(b) company, job title, markets of interest;
(c) personal opinions made known to us (e.g. your feedback or responses to any surveys);
(d) browsing history, patterns or other unique information;
(e) your internet protocol address and information associated with such address;
(f) any other personal data reasonably required in order for us to provide the services requested by you; and
(g) any other personal data permitted by or required to comply with any applicable local or foreign laws, rules, acts, regulations, subsidiary legislation notices, notifications, circulars, license conditions, directions, requests, requirements, guidelines, directives, codes, information papers, practice notes, demands, guidance and/or decisions of any national, state or local government, any agency, exchange, regulatory or self-regulatory body, law enforcement body, court, central bank or tax revenue authority or any other authority whether in Singapore or elsewhere, whether having the force of law or not (including any intergovernmental agreement between the governments or regulatory authorities of two or more jurisdictions or otherwise), as may be amended from time to time ("Applicable Laws") and our internal control and compliance policies.
Section 2 sets out the type of Personal Data that we collect or may collect from you.
3. SOURCES OF INFORMATION
3.1 The Personal Data has/or will be obtained from the following sources, where applicable, or such other sources which we may see fit from time to time:
(a) information provided or submitted by you through among others, your dealings and agreements with us, which includes information provided when registering as a user, providing information regarding any account which you may open with us, providing answers to security questions, completing any confirmations, declarations or forms, or through your utilization of any of our Services, accessing or viewing our Platform;
(b) as applicable, publicly available or publicly accessible information; and
(c) such other written, electronic or verbal communications or documents delivered to us prior to and during the course of our contractual or pre-contractual dealings with you.
3.2 As the accuracy of your Personal Data depends largely on the information you provide to us, you should inform us as soon as practicable if there are any errors in the Personal Data or if there have been any changes to the Personal Data. We intend to keep the Personal Data accurate and up-to-date, and retain the Personal Data no longer than necessary for the above purposes or as required or permitted by any applicable law.
Section 3 sets out where we may obtain Personal Data from.
As the accuracy of your Personal Data depends largely on the information you provide to us, you should inform us as soon as practicable if there are any errors in the Personal Data or if there have been any changes to the Personal Data.
4. PURPOSE OF COLLECTING, USING AND DISCLOSING YOUR PERSONAL DATA
4.1 We may use your Personal Data for our business purposes, including the provision and continuing operation of the Platform and the Services provided to you. This includes, the following purposes ("Purposes"):
(a) provision of the Services as requested by you;
(b) carrying out any transactions on your behalf contemplated on the Platform and the Services thereto;
(c) assessing and processing applications, instructions or requests from you;
(d) communicating with you, including providing you with updates on changes to our Services;
(e) to verify your identity for the purposes of providing Services to you;
(f) conducting due diligence checks, screenings or credit checks as may be required by any Applicable Laws or our internal policies and procedures;
(g) for the specific purpose for which it was volunteered or provided to us;
(h) to detect and protect us or any third parties against negligence, fraud, theft and other illegal activities;
(i) to understand your needs and preferences;
(j) improving the content, appearance and utility of the Platform;
(k) to manage and develop infrastructure and business operations;
(l) to administer any account which you may open with us;
(m) to process payments;
(n) to comply with our internal policies and procedures;
(o) to respond to queries or feedback;
(p) to address or investigate any complaints, claims or disputes;
(q) as permitted by any Applicable Laws;
(r) to comply with any Applicable Laws or any request from any relevant governmental or regulatory authority;
(s) financial reporting, regulatory reporting, management reporting, risk management, audit and record keeping purposes;
(t) enforcing obligations owed to us;
(u) seeking professional advice, including legal advice;
(v) any other reasonable purposes in connection with the provision of our Services;
(w) with your consent, providing you with marketing materials in connection with the services we may provide;
(x) fulfilling any purpose directly related to the above Purposes; or
(y) any other purposes that are appropriate or authorized by any Applicable Laws.
4.2 You may, at any time, withdraw your consent to receive marketing information from us. If you wish to do so, please click on the “Unsubscribe” option available on all marketing/newsletter emails that you may receive from us or contact our Data Protection Officer at [email protected]
Section 4 sets out how we may use your Personal Data. This includes using your Personal Data for the provision of our Services / Platform to you, for marketing purposes, and to comply with regulatory requirements.
5. DISCLOSURE AND SHARING OF YOUR PERSONAL DATA
We may from time to time disclose and share your Personal Data to our directors, officers, employees, representatives, agents or delegates or any third parties, whether located in Singapore or otherwise, to carry out the Purposes. This includes, disclosing and sharing your Personal Data with the following:
(a) any of our directors, officers, employees, representatives, agents or delegates;
(b) any of our shareholders or related corporations, and any of their successors or assigns, and their directors, officers, employees, representatives, agents or delegates;
(c) our professional advisers, consultants and auditors;
(d) any service providers, agents, contractors, delegates, suppliers or third parties which we may appoint from time to time to provide us with services in connection with the Platform or the Services that we offer to you, and their directors, officers, employees, representatives, agents or delegates;
(e) any sub-contractors which any of our service providers, agents, suppliers, delegates or contractors may appoint from time to time to provide them with services in connection with the Platform or the Services that we offer to you, and their directors, officers, employees, representatives, agents or delegates;
(f) anyone who takes over or may take over all or part of our rights or obligations under any agreement we have with you or anyone any agreement we have with you (or any part thereof) is transferred to or may be transferred to;
(g) any person who we believe in good faith to be your legal advisers or other professionals;
(h) any relevant governmental or regulatory authority, in so far as we need to do so to keep to any Applicable Laws, or which we in good faith believe that we should keep to; and
(i) pursuant to a request by any relevant governmental or regulatory authority (regardless of the reason for such request and whether such request is exercised under a court order or otherwise);
(k) any person to whom we are, in our belief in good faith, under an obligation to make disclosure as required by any Applicable Laws,
provided that in the case of disclosures under any of the circumstances in (a) to (d), we shall procure that the recipient is subject to the same duty of confidence.
We may also disclose and share your Personal Data with other persons in connection with the Purposes described in Section 4
6. TRANSFER OF YOUR PERSONAL DATA OUTSIDE SINGAPORE
We may transfer, store, process and/or deal with your Personal Data outside Singapore. In doing so, we will comply with the PDPA and other applicable data protection and privacy laws.
We may transfer your Personal Data outside Singapore. If we do, we will comply with applicable data protection and privacy laws.
7. RETAINING YOUR PERSONAL DATA
Your Personal Data is retained as long as the purpose for which it was collected remains and until it is no longer necessary for any other business purposes or to comply with any Applicable Laws.
We may retain your Personal Data for as long as it is necessary for the purpose it was collected, for business purposes or to comply with applicable laws.
8. YOUR RIGHTS
However, you may also request access to Personal Data we hold, or request the rectification of any inaccurate data. If you would like to do so, please contact our Data Protection Officer at [email protected]
You may contact our Data Protection Officer to access or request changes to your Personal Data.
9.2 A pixel tag, also known as a web beacon, is an invisible tag placed on certain pages of our web site but not on your computer. Pixel tags are usually used in conjunction with cookies and are used to monitor the behaviour of users visiting the web site.
9.3 You may set up your web browser to block cookies which will in turn disable the pixel tags from monitoring your web site visit. You may also remove cookies stored from your computer or mobile device. However, if you do block cookies and pixel tags, you may not be able to use certain features and functions of our web sites or the Platform.
9.4 We also use analytics programs for web analytics purposes to manage and improve our websites, mobile applications, the Platform and/or our Services. Accordingly, your information may be collected for reports such as impression reporting, demographic reporting, interest reporting and to assist with tailoring our online advertising to provide you with a better experience.
9.5 We and our third-party vendors use first-party cookies and third-party cookies or other third-party identifiers together, to inform, analyse, optimise, and serve custom ads based on your interests, searches and prior usage patterns when visiting our websites, mobile applications and Platform, and for other market research analysis purposes such as impression reporting and how your interactions with these ads are related to visits to our websites, mobile applications and Platform, amongst others. As a consequence, third party vendors may show our ads on other websites or mobile applications. We neither support or endorse the goals, causes or statements of these websites or mobile applications which display our ads.
10. THIRD PARTY SITES
11. SCENARIOS WHERE CONSENT NEED NOT BE OBTAINED OR CONSENT IS DEEMED TO HAVE BEEN OBTAINED
Where your consent is not required:
(a) to improve, enhance or develop new services that can be provided to you;
(b) improve, enhance or develop new methods or processes for our business operations with respect to our services;
(c) learn or understand your behaviour and preference; or
(d) identify services that may be suitable for you, or personalising or customising any such services for you.
Where consent is deemed to have been obtained from you:
(a) if we have notified you of our intention to and the purpose for which we will collect, use or disclose your Personal Data, and you have not taken any action to opt out of such collection, use or disclosure within the period stated;
(b) where it is reasonably necessary for us to disclose your Personal Data to other third parties (including on a downstream basis) so that we can perform our obligations to you; or
(c) where you have voluntarily provided us with your Personal Data.
We may be able to collect, use, process and disclose your Personal Data in certain situations where your consent is not required, or where your consent is deemed to have been obtained from you, with respect to your use of our Services, your operation of any accounts maintained with us, access or use our Platform, websites, mobile applications or otherwise provide information to or communicate with us.
13. CONTACTING US
If you have any questions about any aspects of this policy or your Personal Data, please contact our Data Protection Officer at [email protected] or +65 8118 8840.