Personal Data Protection Statement

1. CLTX Commitment
The Cleartrade Exchange Pte. Ltd. (“CLTX”) is committed to protecting our stakeholders’ and clients’ personal data in accordance with the Singapore Personal Data Protection Act (“PDPA”) and the General Data Protection Regulation (GDPR, EU). For more information on PDPA or GDPR, kindly visit https://www.pdpc.gov.sg/Legislation-and-Guidelines/Personal-Data-Protection-Act-Overview
https://www.eugdpr.org/eugdpr.org.html

2. CLTX Privacy Policy
This Personal Data Protection Policy Statement explains what types of personal data are collected and why, how long CLTX keeps the data, CLTX’s security measures and how CLTX addresses access and correction requests. “Personal data” means any personal information about an individual which can be identified from that data, as more specifically defined under the PDPA.

3. What types of information does CLTX collect?
CLTX collects information about how to contact you and your interest and relationship with CLTX, including the products and services which are relevant to you. This information is collected when you communicate with CLTX in writing* or orally.

*Writing can be in the form of email, SMS, letters, paper or electronic forms, business cards or other forms of written or electronic correspondence.

4. What does CLTX do with the information?
CLTX collects information to provide products and services and communicate with you on matters relevant to your relationship with or interest in CLTX. The information helps CLTX to assess and improve the products and services that you use or may use, and selectively send you information about our products, services, activities or events that may interest you.

CLTX also fundamentally uses the personal/individual data for:

-Facilitating the setting up of membership and trading accounts for corporate clients whereby Know-Your-Customer (KYC) and due diligence are to be performed on all, but not limited to, company directors, shareholders, owners and key personnel of the member company or associated companies as required by Anti-money laundering and Countering Financing of terrorism regulations and measures.

-Facilitating the provision of services from CLTX to market participants and members, not limited to, execution of contracts, trade registration and usage of our electronic platform

-In such circumstances where CLTX group, its shareholders, affiliates, partners and such third parties service providers are compelled to disclose information pursuant to a court order, regulatory
requirements, request from relevant authorities, police investigations and criminal prosecutions for tax evasion or other offences.

We will not provide your personal data to any third parties without your approval, except as permitted under the PDPA, such as in response to law enforcement agencies, and to facilitate the provision of services.

By providing personal data to CLTX, you hereby consent CLTX to collect and use the information provided, and to share such information within the CLTX group and such third parties with which CLTX may have relevant service arrangements, for the purpose for which the information was collected or to be used, and any other reasonable additional purposes. This includes the purpose of facilitating CLTX’s provision of the products and services which you use, marketing CLTX products and services which are relevant to you, and your consent to receive notifications from CLTX on such products and services.

5. How long does CLTX store the information?
We shall retain your personal data for as long as is necessary for the above-mentioned purposes and take reasonable measures to remove any personal data that is no longer necessary to meet those purposes.

6. CLTX security measures
All your personal data is kept confidential in a secure environment and CLTX puts in place reasonable steps to safeguard it from unauthorized or accidental access, processing or loss, by implementing appropriate physical, electronic and supervisory controls. We protect personal data in our possession or under our control by making reasonable physical, technical, administrative and procedural security arrangements to prevent unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks.

7. How you can manage your information
If you wish to be removed from CLTX’s contacts database at any point of time, or if you believe CLTX has outdated information about you, please contact us at membership@cltx.com. By contacting us, you may update your personal information, unsubscribe from any CLTX communications you may be receiving, or choose to be removed from our contacts database altogether.

It is important to note that CLTX uses your personal information to provide you with the products and services you wish to use. CLTX also complies with various regulatory requirements in doing so, including the requirements for client due diligence. Withdrawal of consent for CLTX to collect, use or disclose personal information means that CLTX will stop these activities. The absence of certain key personal information, including but not limited to your name, address, email and/or telephone contacts, personal identification numbers or banking information, may cause CLTX to be unable to continue providing the relevant products and services to you.

8. Rights of Individuals
CLTX acknowledges and supports the below rights of individuals to their respective data:
-Individuals has the right to be informed of how their personal data are being processed
-Individuals has the right of access to their respective data
-Individuals has the right to rectification of their respective data where it is inaccurate or incomplete
-Individuals has right to erasure of personal data concerning the individual in certain circumstances
-Individuals has right to restrict processing of personal data where accuracy is contested, processing is unlawful and other relevant reasons
-Individuals has right to data portability
-Individuals has right to object to the use of their personal data
-Individual has right not to be subjected to automated decision-making and profiling

9. Timely update in breach of data
In the unfortunate and unlikely event of a data breach, CLTX will inform and update the respective affected individuals without undue delay. and not later than 72 hours where feasible, after awareness of the breach.

10. Opt out cookie option in relation to CLTX website
Website visitors are entitled to object to the storage of their visitor data, so that this data will no longer be recorded on this website in the future. If you object to the data storage, the CLTX website will allow it’s users the option to do an opt out of the cookies collecting the data of the users’ visit.

Contact us
If you have any questions about this Statement, or CLTX’s handling of your personal data, please contact our Head of Compliance/DPO (Mr. Lim Poh Leong) at pllim@cltx.com. For matters regarding updating of personal data, kindly get in touch with us via membership@cltx.com.

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