The objectives of this Policy are to:
- Provide a set of privacy and personal data protection standards that govern our procedures and protect the privacy of your personal data.
- Demonstrate our on-going commitment to protecting your privacy and addressing any privacy concerns that you might have.
- Describe the ways in which we collect, use, disclose and retain your personal data.
- Ensure that we comply with the PDPA.
- Facilitate our compliance with any further developments in the protection of personal data.
Type of Personal Data
Generally, some of the Services require us to know who you are so that we can best meet your needs. When you sign-up on the Website, access the Services, submit information, or through any interaction with us via application or registration forms, emails, telephone calls, short messaging services, texts or other correspondence, we may ask you to voluntarily provide us with certain information that personally identifies you or could be used to personally identify you.
Without prejudice to the generality of the above, information collected by us from you may include (but is not limited to) the following:
- contact data (name, NRIC, passport or other identification number, telephone number(s), mailing address, email address, personal interests, and any other information provided us in any forms you may have submitted to us, interaction with HGX and its agents/employees, or through opening an account with HGX);
- other information that you voluntarily choose to provide to us (such as information shared by you with us through emails);
- financial information;
- information received by body corporate under lawful contract or otherwise;
- your use of our Services, including data of investment history, volume, patterns, predictions, trends;
- email and telephone call data records;
- your use of the Website and Services, including cookies, IP address, policy and usage history information; and
- your usage of and interaction with our Website and/or services including computer and connection information, device capability, bandwidth, statistics on page views, and traffic to and from our Website.
The information collected from you by HGX may constitute Personal Data under the PDPA.
“Personal Data” is defined under the PDPA to mean any data, whether true or not, about an individual who can be identified from that data or from that data and other information to which an organisation has or is likely to have access. This would include, without limitation, information such as name, address, telephone number, e-mail address, credit card details and any other personal information.
HGX will be free to use, collect and disclose information that is freely available in the public domain without your consent.
Information that is business contact information such as your name, position name or title, business telephone number, business address, business electronic mail address or business fax number and any other similar information about you, which are not provided by you for personal purposes, will not be regarded as Personal Data under the PDPA. Your consent to us collecting, using and disclosing any business contact information will not be required.
Control of Personal Data
HGX is the controller of your personal data.
Collection of Personal Data
Personal Data may be collected by us through processes including, but not limited to the following:
- when you subscribe or register on our Website with us for an account;
- when you access our Website or submit information;
- when you interact with any of our employees;
- when you sign up to be included in an email or other mailing list;
- when you request that we contact you; and
- when individual submits his/her Personal Data to HGX for any other reason.
Information that you submit via any of our Website shall be deemed to be collected by us with your permission. Such information may include but is not limited to your name, contact and fax numbers, home, work and email addresses, date of birth, and other information necessary to the provision of Services.
Purposes for which we collect and use Personal Data
HGX may collect, use or disclose your personal data only for purposes:
- that a reasonable person would consider appropriate in the circumstances; and
HGX collects and uses the Personal Data that you provide to us depending on your relationship with us (e.g. as a customer, or other person relating to HGX).
Consent to Collection of Personal Data
HGX shall not collect, use or disclose your personal data unless:
- you consent to the collection, use or disclosure of your personal data;
- the collection, use or disclosure of your personal data is necessary for us to perform our contractual obligations owed to you and providing services to you;
- the collection, use or disclosure of your personal data is required or authorised under the PDPA or other written law; or
- the collection, use or disclosure of your personal data is in accordance with the protection of our legitimate interests.
HGX shall not, as a condition of providing a product or service to you, require you to consent to the collection, use or disclosure of your personal data beyond what is reasonable to provide the product or Service to you.
HGX shall not obtain or attempt to obtain your consent for collecting, using or disclosing personal data by providing false or misleading information with respect to the collection, use or disclosure of your personal data, or use deceptive or misleading practices.
As part of our continuous effort to keep you informed on our new product and services, we may mail, email, telephone and contact you by any other means. Information sent to you may also include upcoming special events, seminars or other relevant information that may be of interest to you.
You will always have the option to decline any or all of these communications by following the directions included in our emails or other communications, or by contacting HGX directly at [email protected].
HGX may collect and use personally identifiable information that you volunteer, or other behavioural data and big data generated.
In general, HGX may use collect, use and/or disclose your Personal Data for the following purposes
- for the specific purpose for which the information was provided;
- to confirm your identity and ensure that you are eligible to access and use the services provided on the Website;
- to process and, where necessary, respond to your application(s), enquiry(s), or request(s);
- to conduct due diligence checks on you in accordance with all applicable laws and HGX's internal 'know your client' and Anti-Money Laundering/Countering the Financing of Terrorism policies;
- to verify and approve the disclosures entrepreneurs seeking capital for their business through HGX's platform make to potential investors;
- to enable HGX to comply with all of its legal and regulatory obligations;
- to inform or update you about products, or services that you request from HGX or that may interest you, where you have consented to be contacted for such purposes;
- to update you about changes to the Website or HGX's operations;
- to monitor, improve, and administer the Website and the services provided through it, and conduct statistical or other forms of analysis for purposes of maintaining or improving the Website and HGX's services in general; or
- to comply with all proceedings or inquiries from any state, regulatory, or enforcement agency.
Disclosure of Information
HGX will not sell or rent your personal information to any third party. Information you provide to HGX will be disclosed to third parties where:
- you have expressly consented to such disclosure;
- such disclosure is a necessary part of the process of seeking funding, investors, or backers;
- necessary to provide you with the products and/or services you have requested for, or to respond to your queries;
- necessary for the operation of the Website or HGX's internal processes;
- required by any government, statutory, or regulatory authority, or to comply with any applicable law, court order, directive, or proceeding of such authority;
- HGX believes, in good faith, that doing so will be appropriate or necessary for it to investigate and defend against any third party claims or allegations, or prevent or stop any illegal activity, security breaches, or harm to the Website, HGX's interests, or any HGX employee;
- HGX is the subject of a takeover and your personal information forms part of HGX's assets to be transferred to the acquiring entity; or
- you disclose such information to third parties in the course of participating in any competitions or promotional programmes on the Website.
Additional Privacy Statements for Website and Service Users
Persons who have subscribed for our updates on the Website (“Subscribers”) Note:
This section applies to all Subscribers.
- As part of the signing-up process that is available to Subscribers on the Website, certain information, including Personal Data or sensitive personal information is collected from the Subscribers.
- If you have inadvertently submitted any such information to HGX prior to reading the privacy statements set out herein, and you do not agree with the manner in which such information is collected, processed, stored, used or disclosed, then you may access, modify and delete such information by using options provided on the Website. In addition, you can, by sending an email to [email protected], inquire whether HGX is in possession of your Personal Data, and you may also require HGX to delete and destroy all such information.
- HGX will communicate with the Subscribers through email. The Subscribers can change their e-mail address by resubscribing and sending an email to [email protected] for the deletion of previous email.
- All HGX employees and data processors, who have access to, and are associated with the processing of sensitive personal data or information, are obliged to respect the confidentiality of every Subscribers’ Personal Data or sensitive personal information.
- To the extent necessary to provide Subscribers with the Services, HGX may provide their Personal Data to third party contractors who work on behalf of or with HGX to provide Subscribers with such Services, to help HGX communicate with Subscribers or to maintain the Website. Generally, these contractors do not have any independent right to share this information, however certain contractors who provide services on the Website, including the providers of online communications services, may use and disclose the personal information collected in connection with the provision of these Services in accordance with their own privacy policies. In such circumstances, you consent to us disclosing your personal information to contractors, solely for the intended purposes only.
- Subscribers may choose to unsubscribe from marketing communications that they receive from HGX or manage their preferences via the links provided at the end of every such email and/or promotional communication.
Persons who register and have accounts to use the Website (“Members”) Note:
This section applies to all Members.
- All the information provided to HGX by a Member, including Personal Data or any sensitive personal information, is voluntary. You understand that HGX may use certain information of yours, which has been designated as Personal Data under the PDPA, (a) for the purpose of providing you the Services, (b) for commercial purposes and in an aggregated or non-personally identifiable form for research, statistical analysis and business intelligence purposes, (c) for the transfer of such research, statistical or intelligence data in an aggregated or non-personally identifiable form to third parties and affiliates. HGX also reserves the right to use information provided by or about the Member for the following purposes:
- Publishing such information on the Website.
- Contacting Members for offering new products or services
- Contacting Members for taking product and Service feedback.
- Analysing software usage patterns, trends, history, big data for our business operations, improving product design and utility.
- Analysing anonymised practice information for our commercial use.
If you have voluntarily provided your Personal Data to HGX for any of the purposes stated above, you hereby consent to such collection and use of such information by HGX.
- You are responsible for maintaining the accuracy of the information you submit to us, such as your contact information provided as part of account registration. If your personal information changes, you may correct, delete inaccuracies, or amend information by making the change on your account page or by contacting us through [email protected]. We will make good faith efforts to make requested changes in our then active databases as soon as reasonably practicable. If you provide any information that is untrue, inaccurate, out of date or incomplete (or becomes untrue, inaccurate, out of date or incomplete), or HGX has reasonable grounds to suspect that the information provided by you is untrue, inaccurate, out of date or incomplete, HGX may, at its sole discretion, discontinue the provision of the Services to you. There may be circumstances where HGX will not correct, delete or update your Personal Data, including (a) where the Personal Data is opinion data that is kept solely for evaluative purpose; and (b) the Personal Data is in documents related to a prosecution if all proceedings relating to the prosecution have not been completed.
- If you wish to cancel your account or request that we no longer use your information to provide you Services, contact us through [email protected]. We will retain your information for as long as your account with the Services is active and as needed to provide you the Services. We shall not retain such information for longer than is required for the purposes for which the information may lawfully be used or is otherwise required under any other law for the time being in force. After a period of time, your data may be anonymised and aggregated, and then may be held by us as long as necessary for us to provide our Services effectively, but our use of the anonymised data will be solely for analytic purposes. Please note that your withdrawal of consent, or cancellation of account may result in HGX being unable to provide you with its Services or to terminate any existing relationship HGX may have with you.
- If you wish to opt-out of receiving non-essential communications such as promotional and marketing-related information regarding the Services, you may do so via your email and/or account.
- HGX does not collect information about the visitors of the Website from other sources, such as public records or bodies, or private organisations, save and except for the purposes of registration of the Members (the collection, use, storage and disclosure of which each User must agree to in order for HGX to effectively render the Services).
- HGX maintains a strict "No-Spam" policy, which means that HGX does not intend to sell, rent or otherwise give your e-mail address to a third party without your consent.
- HGX has implemented best international market practices and security policies, rules and technical measures to protect the Personal Data that it has under its control from unauthorised access, improper use or disclosure, unauthorised modification and unlawful destruction or accidental loss. However, for any data loss or theft due to unauthorised access to the Member’s electronic devices through which the Member avails the Services, HGX shall not be held liable for any loss whatsoever incurred by the Member.
- HGX implements reasonable security practices and procedures and has a comprehensive documented information security programme and information security policies that contain managerial, technical, operational and physical security control measures that are commensurate with respect to the information being collected and the nature of HGX’s business. The reasonable security practices and procedures implemented by HGX include, but not limited to: ensuring that any Personal Data is protected by password.
- HGX takes all reasonable steps to ensure that all unsolicited information is destroyed immediately.
Casual Visitors Note:
- No sensitive personal data or information is automatically collected by HGX from any casual visitors of this Website, who are merely perusing the Website.
- If you, as a casual visitor, have inadvertently browsed any other page of this Website prior to reading the privacy statements set out herein, and you do not agree with the manner in which such information is collected, processed, stored, used, disclosed or retained, merely quitting this browser application should ordinarily clear all temporary cookies installed by HGX. All visitors, however, are encouraged to use the “clear cookies” functionality of their browsers to ensure such clearing / deletion, as HGX cannot guarantee, predict or provide for the behaviour of the equipment of all the visitors of the Website.
Confidentiality and Security
Your Personal Data is maintained by HGX in electronic form on its equipment, and on the equipment of its employees. Such information may also be converted to physical form from time to time. HGX has implemented and will continue to maintain security measures adequate to prevent the unauthorised collection, use, disclosure, copying, modification, and disposal of your information. Nevertheless, you acknowledge and agree that communications through the Internet are not entirely secure and that any information transferred to HGX is done so at your own risk. HGX does not warrant or guarantee that the information you provide will not be accessed, copied, used, or disposed of in breach of HGX's security measures, and you agree not to hold HGX liable or responsible for any loss or damage resulting therefrom. In the event of such a breach, HGX will, as far as reasonably possible, promptly notify all affected persons.
No administrator at HGX will have knowledge of your password. You accept that you are responsible for keeping confidential your username and password to your account with HGX. Be sure to log off from the Website when finished. HGX does not undertake any liability for any unauthorised use of your account and password. If you suspect any unauthorised use of your account, you must immediately notify HGX by sending an email to [email protected]. You shall be liable to indemnify HGX due to any loss suffered by it due to such unauthorised use of your account and password.
Age of Consent
By using the Website, you represent that you are at least the age of 18 years old, or you have given us your consent to allow any of your minor dependents to use this Website as the case may be.
HGX strongly encourages parents and guardians to supervise the online activities of their minor children and consider using parental control tools available from online services and software manufacturers to help provide a child-friendly online environment. These tools also can prevent minors from disclosing their name, address, and other personally identifiable information online without parental permission. Although the Website and Services are not intended for use by minors, HGX respects the privacy of minors who may inadvertently use the internet or the mobile application.
HGX may collect certain information from you without you actively providing the information when you navigate the Website via cookies. Cookies are small data text files stored in your local browser cache that send information about your previous visits to and activities on the Website. These cookies will not give HGX any personal information about you. HGX reserves the right to use the cookies to recognise your browser and thereby customise and optimise the Website to your preferences.
You can accept or delete cookies. For security reasons, you may wish to deactivate the storing of cookies or adjust your browser to inform you before the cookies are stored on your computer. However, please note that if you do erase or block the cookies, you may not be able to utilise some features on the Website. In such situations, HGX shall not be held liable for any loss or damage resulting from your inability to use those features.
HGX may also collect your Internet Protocol (IP) address. Your Internet Service Provider allocates an IP address to your computer in order for it to access the Internet. The IP address is considered to be non-personal information and it may be dynamic (changing every time you connect to the Internet) or it may be static (unique to your computer). HGX collects your IP address in order to facilitate its administration and improvement of the Website. The information derived from your IP address can help HGX diagnose server problems, report aggregate information, and determine the fastest route from your computer to the Website.
We use the following cookies:
- Strictly necessary cookies. These are cookies that are required for the operation of the Website. They include, for example, cookies that enable you to log into secure areas of the Website, using HGX's online payment services.
- Analytical/performance cookies. They allow HGX to recognise and count the number of visitors and to see how visitors move around the Website when they are using it. This helps HGX to improve the way the Website works, for example, by ensuring that users are able to use custom features.
- Functionality cookies. These are used to recognise you when you return to our Website. This enables HGX to personalise its content for you, greet you by name and remember your preferences (for example, your choice of language or region).
- Targeting cookies. These cookies record your visit to the Website, the pages you have visited and the links you have followed. HGX will use this information to make the Website and the advertisements targeted more relevant to your interests. HGX may also share this information with third parties for this purpose.
Transfer, Storage, & Retention of Information
You may at any time inform HGX that you wish to withdraw your consent to such transfer, storage, or processing of your personal data.
HGX will retain all information collected for as long as you continue to use the Website or HGX's services. If you are a Member and terminate your HGX account, HGX will retain the information, including personal data, collected during your membership for as long as reasonably necessary for any business or legal purpose. Generally, we do not retain Personal Data for a period of longer than six (6) years after the original purposes for which the Personal Data was collected have ceased to be applicable, unless otherwise required by law or other mandatory directions by court or government authorities or for purposes of legal proceedings or other similar proceedings or investigations.
HGX may record, and/or monitor any communication(s) (including telephone calls or other electronic communications) between you and HGX. HGX may do so in order to resolve queries in the future and/or for the purpose of ensuring security, staff training and complying with its legal and/or regulatory responsibilities.
Right to Access
You have the right to obtain confirmation from HGX as to whether or not HGX processes your personal data and, where HGX does so, access to the personal data and information including, the details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. HGX will, at your request, endeavour to provide you with copy of your personal data in HGX’s possession or control within a reasonable period of time.
The first copy of your personal data will be provided to you free of charge, and for any subsequent copies HGX may charge you a reasonable fee for administrative costs. However, please note that your right to obtain a copy of your personal data is subject to the rights and freedoms of others, and HGX may have to deny your request should your request adversely affect the rights and freedoms of others.
Right to Rectification
You have the right to have any inaccurate personal data about you rectified. In addition, when there are any changes to your personal data, HGX highly encourages you to inform HGX of any such changes so that HGX may have an accurate record of your personal data.
Right to Erasure
You have the right to request HGX to delete or remove your personal data where your personal data is no longer relevant to the original purposes for processing, where HGX may have processed your information unlawfully, where you have withdrawn your consent to HGX processing your personal data or where HGX is required to delete or remove your personal data pursuant to relevant legislation and regulations. However, please note that HGX may have deny your request where HGX is legally required to retain your personal data for, inter alia, reasons of public interest or for the establishment, exercise or defence of legal claims.
Right to Restriction of Processing
You have the right to request HGX to suspend the processing your personal data where you want to establish the accuracy of your personal data, where the processing of your personal data is unlawful but you do not want HGX to erase your personal data, where HGX no longer requires your personal data for the purposes of processing but you require HGX to retain your personal data for the establishment, exercise or defence of legal claims or where you have objected to HGX’s processing of your personal data but HGX needs to verify whether HGX has an overriding legitimate grounds to use your personal data.
Right to Object
You have the right at any time to object to HGX processing your personal data on the grounds that there is something about your particular situation that makes you want to object. In addition, you also have the right to object the processing of your personal data for direct marketing purposes. However, in some instances, HGX may demonstrate that HGX has compelling legitimate grounds to processing your personal data which may override your objection.
Right to Data Portability
You have the right to request HGX to transfer your personal data to you or to a third party of your choosing, in a structured, commonly used, machine-readable format. This right shall only be applicable where the processing of your personal data is carried out by automated means, and provided that the request does not affect the rights and freedom of others.
Right to Lodge a Complaint
You have the right to lodge a complaint at any time to the relevant supervisory authority. The relevant authority in Singapore is the Personal Data Protection Commission. However, HGX endeavors to provide you with the best user experience and therefore would appreciate the opportunity to deal with any concerns you may have before you seek the assistance of the Personal Data Protection Commission.
Right to Withdraw Consent
You have the right to withdraw your consent at any time to HGX processing your personal data. However, the withdrawal of your consent shall not affect the lawfulness of HGX’s processing of your personal data that was based on your consent prior to your withdrawal. You may also withdraw your consent for specific forms of communication and on specific communications via the unsubscribe options as stated on HGX’s email or other marketing messages.
Please note that in withdrawing your consent, you acknowledge that HGX may not be able to provide or continue providing certain goods and/or services to you and that HGX may cease such provision accordingly without any liability.
To exercise any of your rights as explained above, kindly send your requests to our Data Protection Officer HGX, at [email protected]
We hope that we can fulfill your requests within 30 days. In cases where we may take longer than 30 days, we will notify you and keep you updated. Notwithstanding the foregoing, you agree and acknowledge that there may be circumstances where we may be unable to accede to your request due to legal or contractual obligations.
If a Subscriber or Member uses the Services; or accesses the Website after a notice of changes has been sent to such Prospect or Member, or published on the Website, such Prospect or Member hereby provides his/her/its consent to the changed terms.
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