FXChange Private Limited (M No. 005886)(“FXChange”) is committed to protecting and respecting your privacy.
1.1 This Policy statement provides information on the obligation and policies of FXChange in respect of an individual user’s Personal Data. FXChange undertakes to use reasonable efforts in applying, where practicable, those principles and the processes set out herein to its operations.
1.2 FXChange officers, management, and members of staff shall use reasonable endeavours to respect the confidentiality of and keep safe any and all Personal Data collected and/or stored and/or disclosed and/or used for, or on behalf of, FXChange. FXChange shall use reasonable endeavours to ensure that all collection and/or storage and/or disclosure and/or usage of Personal Data by FXChange shall be done in an appropriate manner and in accordance with the Act and this Policy.
1.3 By interacting with us, submitting information to us, you agree and consent to FXChange as well as to its respective representatives and/or agents (“Representatives”) collecting, using, disclosing and sharing amongst themselves your Personal Data, and disclosing such Personal Data to FXChange’s authorized service providers and relevant third parties in the manner set forth in this Privacy Statement.
1.4 This Policy supplements but does not supersede nor replace any other consents you may have previously provided to us in respect of your Personal Data, and your consents herein are additional to any rights which we may have at law to collect, use or disclose your Personal Data.
1.5 For the purposes of this Policy, in line with the provisions under the Singapore Personal Data Protection Act 2012 (No.26 of 2012)(the “Act”). “Personal Data” shall mean data, whether true or not, about an individual customer who can be identified – from that data; or from that data and other information which an organization has or is likely to have access. Such Personal Data shall also refer to that which is already in the possession of FXChange or that which shall be collected by FXChange in the future.
2. Contacting the Data Protection Officer
2.1 Where you legitimately request access to and/or correction of Personal Data relating to you, such Personal Data which is in the possession and control of FXChange, FXChange shall provide and/or correct that data in a reasonable time and manner in accordance with its standard procedures as stated hereinafter.
2.2 In accordance with the Act, FXChange has established a process for receiving and responding to any query or complaint that may arise with respect to the application of this Act. To ensure that FXChange receives your complaints and enquiries regarding Personal Data, please send the name via email to any of our Data Protection Officer at firstname.lastname@example.org.
2.3 Should you not wish FXChange to use your Personal Data for any of the purposes listed in Clauses 3.2, you may opt out by sending a clearly worded email to the DPO via the email address provided in Clause 2.2. Your request shall be processed within a reasonable time.
3. Statement of Practices
Types of Personal Data Collected:
FXChange may collect from you, through various means, including viaour websites, enquiry forms, smart phone applications, marketing events such as exhibitions and any forms used by FXChange from time to time, some or all of the following Personal Data (as and when if required):
Purpose of Collection of Personal Data
(1) Information related to the status of use: FXChange will collect information related to the devices you use for accessing the Site as well as information from such devices. This includes IP address, type of browser and device, web pages that you visited prior to accessing FXChange's site, and personal identification information related to the devices being used. Furthermore, there may be cases where the devices being used (depending on the setting) may transmit position information to the Site.
Disclosure of Personal Data:
FXChange may disclose your Personal Data to the following third parties:
FXChange may in certain cases share personal information with others as described below.
(2) FXChangeSurvey: Generally, these surveys provide specific feedback using aggregated, de-identified data to third parties used to analyze trends and statistics for marketing, research, and development purposes, and neither your identity nor your specific feedback is shared with third parties. However, under the following circumstances, your identity may be shared with third parties and/or associated with specific feedback: (i) when we have your permission, (ii) when we match user information with such third party’s data, and (iii) when we believe in good faith that the law requires it. In all circumstances, the privacy of our User is protected, and if such sharing is permitted or required, your answers and identity will remain confidential.
3.1 Possibility of disclosure of information
Optional Provision of Personal Data:
3.2 In some instances, you may also be requested to provide certain Personal Data that may be used to further improve FXChange services and/or better tailor the type of information presented to you. In most cases, this type of data is optional although, where the requested service is a personalised service, or provision of a product or dependent on your providing all requested data, failure to provide the requested data may prevent FXChange from providing the service to you.
4. Transfer of Personal Data Overseas
Your Personal data may be processed by FXChange, its affiliates, agents and third parties providing services to FXChange, in jurisdictions outside of Singapore. In this event, FXChange will comply with the terms of the Act and will, with all reasonable endeavours, ensure that such affiliates, agents and third parties do the same.
5. Accuracy of Personal Data
Where possible, FXChange will validate data provided using generally accepted practices and guidelines. In some instances, FXChange is able to validate the data provided against pre-existing data held by FXChange. In some cases, FXChange is required to see original documentation before we may use the Personal Data. To assist in ensuring the accuracy of your Personal Data in the possession of FXChange, please inform us of any updates of any parts of your Personal Data by sending a clearly worded email to the DPO at the email address provided at Section 2.2.
6. Protection of Personal Data
FXChange uses commercially reasonable physical, managerial, and technical safeguards to preserve the integrity and security of your Personal Data and will not knowingly allow access to this data to anyone outside of FXChange, other to you or as described in this Policy. However, FXChange cannot ensure or warrant that such information may not be accessed, altered, collected, copied, destroyed, disposed of, disclosed or modified by breach of any FXChange’s physical, technical, or managerial safeguards.
7. Access and Correction of Personal Data
7.1 In accordance with Clause 2.1 of this Policy, you have the right to:
(1) Check whether FXChange holds any Personal Data relating to you and, if so, obtain copies of such data; and
(2) require FXChange to correct any Personal Data relating to you which is inaccurate for the purpose for which it is being used.
7.2 If you wish to verify the details you have submitted to FXChange or if you wish to check on the manner in which FXChange uses and processes your Personal Data, FXChange’s security procedures mean that FXChange may request proof of identity before we reveal information. This proof of identity will take the form of full details of name and NRIC or Passport of FIN number. You must therefore keep this information safe as you will be responsible for any action which FXChange takes in response to a request from someone using your details.
8. Storage and Retention of Personal Data
8.2 However, in the foregoing case, please take note of the following points:
(1) it may take some time to delete the information of User from the FXChange server and its backup storage;
(2) FXChange may in certain cases retain the information of User due to legal obligations, for dispute resolution, or upon enforcement of the written consent regarding FXChange; and
(3) FXChange may anonymize personal information and permanently retain the same for the purpose of research, and the like.
9.2 Cookies may transmit information about you and your use of our service, including but not limited to:
9.3 Cookies may be stored persistently or stored only during an individual user session.
9.4 Cookies enable FXChange to provide and develop a more personalized browsing and usage experience on our website and mobile application, and improve the experience of displaying targeted advertising to you.
9.6 FXChange may share non-personally identifiable information about you with third parties, such as advertising identifies, location data, or encrypted account identifier to improve the experience of displaying targeted advertising on platforms including but not limited to search engine and social media channels.
9.7 You may deactivate cookies by adjusting your internet browser settings to disable, block or deactivate cookies, by deleting your browsing history and clearing the cache from your internet browser, if you do not wish your Cookies to be collected. You may also be able to limit our sharing of some of this information through your mobile device settings..
10. Do Not Call Registry (the “DNC”)
12. Governing Law
This Policy is governed by and shall be construed in accordance with the laws of Singapore. You hereby submit to the non-exclusive jurisdiction of the Singapore courts.
13.1 This Policy only applies to the collection and use of Personal Data by FXChange. It does not cover third party sites to which we provide links, even if such sites are co-branded with our logo. FXChange does not share your Personal data with third party websites. FXChange is not responsible for the privacy and conduct practices of these third-party websites, so you should read their own privacy policies before disclosure of any Personal Data to these websites.
13.2 FXChange will not sell your personal information to any third party without your permission, but we cannot be responsible or held liable for the actions of third party sites which you may have linked or been directed to FXChange website.