Privacy Policy

1. This policy will more specifically address the personal data we collect,use, and disclose, which generally includes your name, address, telephone number, email address and other information that specifically relates to you, which we collect in the course of providing our services to you. However, business contact information which is defined under the Personal Data Protection Act 2012 as an individual’s name, position name or title, business telephone number, business address, business electronic mail address or business fax number and any other similar information about the individual, not provided by the individual solely for his personal purposes is not considered as personal data.

2. Please read this Privacy Policy and understand the ways in which your Personal Data is collected, used, disclosed and otherwise processed. By visiting or using Globalore’s website, microsites or mobile sites including Globalore’s online trading platform (collectively our ” Site“) and any mobile applications which Globalore provides for download to your mobile device (“Apps“) you are accepting and consenting to the practices described in this Privacy Policy. You may withdraw your consent to any of the purposes and uses at any time. However, Globalore may in certain circumstances be unable to provide you with continued access to the Site/App or to any of the services provided to you or the Market Members as a result of your withdrawal of consent to such collection, use, disclosure, transfer and/or processing of your personal data where such consent is necessary for the continued provision of such access or services.

3. If you wish to withdraw consent to any of the purposes and uses at any time, you should:

(i) put your request in writing,

(ii) provide us with your name, email address, phone number and other information that will assist us to identify you (e.g. name, email address, user name, account number);

(iii) specify what you wish to withdraw consent from; and

(iv) send the request to the email address or postal address provided under “Questions about Privacy” below.

(a) Online forms

4. You may give us personal data about you when you fill in forms on our Site. This includes but is not limited to information you provide when you subscribe to our services, register your account on our Site, update your account information online, and when you report a problem on our Site.

(b) Correspondence with us

5. You may give us personal data about you when you correspond with us by phone, email or otherwise communicate with us.

6. We may collect technical information such as the internet protocol (IP) address used to connect your computer to the internet, browser type and version, time zone setting, browser plug-in types and versions. We may also collect other general information about your visit on our Site including the Uniform Resource Locators (URL) clickstream to, through and from our Site, items you searched for, length of visits to certain pages, page response time and download errors.

7. This information helps us monitor customer traffic patterns, site usage and related site information. In order to optimise the services we provide, we may give aggregated statistics to a reputable third-party. However, these statistics will include no personally identifying information.

8. Cookies is a small data file which is stored on the hard drive of your computer. Cookies contain information that is transferred to your computer’s hard drive. They help us to improve our site and to deliver a better and more personalized service. They enable us:

(i) To estimate our audience size and usage pattern;

(ii) To store information about your preferences, and so allow us to customize our site according to your individual interests;

(iii) To speed up your searches;

(iv) To recognize you when you return to our Site; and

(v) To monitor your usage of our Site, including without limitation, the duration each user login session remains connected to our Site.

9. You may refuse to accept cookies by activating the setting on your browser which allows you to refuse the setting of cookies. However, if you select this setting you may be unable to access certain parts of our Site. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you log on to our Site.

10. We may also receive personal data about you through our Market Members pursuant to activities related to their membership including their application for membership. For example, they may name you as an authorised user, administrator, account holder or signatory.

11. We use personal data collected through our Site and communications in the following ways (“Purposes“):

(i) To carry out our obligations arising from any agreements entered into between you and us and to provide you with the information, product or services that you request from us;

(ii) To send you newsletters/aggregated reports or provide other services you have subscribed to or requested for;

(iii) To improve or modify our Site including to ensure that content from our Site is presented in the most effective manner for you and for your computer;

(iv) To diagnose and resolve technical issues associated with connection to and usage of our Site;

(v) To identify you and any accounts you hold with us;

(vi) As part of our efforts to keep our Site safe and secure;

(vii) To allow you to participate in interactive features of our Site, when you choose to do so;

(viii) To conduct research, statistical analysis and behavioral analysis;

(ix) To provide you with information about products or services which we feel may interest you, where you have consented to be contacted for such purposes;

(x) To carry out our obligations arising from any agreements entered into between the Market Member who provided us with your personal data and us and to provide the Market Member with the information, product or services that you request from us; and

(xi) To notify you about changes to our services and our Site.

12. Your provision of personal data is voluntary. However, please note that if you do not provide us with the required personal data, we may not be able to provide the information, products or services you need or process your request.

13. We may disclose your personal data to third parties :

(i) In order to carry out our obligations arising from any agreements entered into between you and us or between a Market Member who provided us with your personal data and us;

(ii) In order to provide you with the information, product or services that you request from us;

(iii) To assist us in improvement, optimization and modification of our Site;

(iv) To facilitate the support of our product and services by a third party, including any third party that hosts or maintains any underlying IT system or database that we use to provide our Site or other products and services;

(v) If we are required, or we reasonably believe that we are required, to do so by law or if we reasonably consider that it is necessary to protect the users of our Site;

(vi) To protect and/or enforce our legal rights and interests; and

(vii) In the event that we are acquired by a new owner, or if following a reorganization of our corporate group we become part of one of our affiliate companies, your personal data may be transferred to a new owner, or another of our affiliate companies, as part of our assets. If this occurs, we will take all reasonable steps to ensure that our new owner or the affiliate which we become part of will use your personal data only in accordance with the terms of this Privacy Policy.

14. We do not sell, or grant rights to external third parties, to use your email address for their own marketing purposes.

15. We may need to transfer your personal data outside of Singapore for the purpose of storing or processing your personal data as part of our business continuity processes. We will take steps to ensure that the recipient organisation is legally bound to provide to the transferred personal data a standard of protection that is at least comparable to the Personal Data Protection Act 2012 (“PDPA “). By submitting your personal data, you agree to this transfer, storing or processing.

16. Our third party service providers who offer services to us from time to time may also store and process your personal data outside of Singapore. We, and our third party service providers mentioned above, may need to disclose your personal data that we store if required to do so under any applicable laws, rules or regulations.

17. If you give us information on behalf of someone else, you confirm that the other person has appointed you to act on his/her behalf and has agreed that you can:

(i) Give consent on his/her behalf to the collection, use, disclosure, transfer and processing of his/her personal data;

(ii) Receive on his/her behalf any data protection notices; and

(iii) Give consent to the transfer of his/her personal data outside of Singapore.

18. You have a right to ask us to stop processing your personal data for direct marketing purposes. If you no longer wish to receive emails and other marketing communications such as newsletters, aggregated reports, or otherwise have us process your personal data for marketing purposes, you should :

(i) put your request in writing,

(ii) provide us with your name, email address, phone number and other information that will assist us to identify you (e.g. name, email address, user name, account number); and

(iii) send the request to the email address or postal address provided under “Questions about Privacy” below.

19. Please note, even if you request not to receive marketing emails, you may still receive email communications from us regarding operational matters.

20. You have the right to ask us whether we hold any of your personal data, what is being held and how it has been used or disclosed by us during the period of one year before the date of your request subject to any existing regulatory exceptions. You may request us to supply to you within a reasonable time a copy of such information about your personal data. If you wish to exercise this right, you should:

(i) put your request in writing,

(ii) provide us with your name, email address, phone number and other information that will assist us to identify you (e.g. name, email address, user name, account number); and

(iii) send the request to the email address or postal address provided under “Questions about Privacy” below.

Upon your written request, to the extent that the information is still within our possession or control, we will inform you of the personal data relating to you that we hold and the use and general disclosure of your personal data. We will also give you a copy of the personal data we have retained. There may be a minimal charge for accessing your personal data.

21. You also have the right to require us to correct any inaccuracies in your personal data that we hold subject to any existing regulatory exceptions. If you wish to exercise this right, you should:

(i) put your request in writing,

(ii) provide us with your name, email address, phone number and other information that will assist us to identify you (e.g. name, email address, user name, account number);

(iii) specify the information that is incorrect and what it should be replaced with; and

(iv) send the request to the email address or postal address provided under “Questions about Privacy” below.

22. Globalore will retain your personal data for as long as it is necessary to fulfil the purposes for which they were collected. If you or the Market Member who supplied your personal data have de-registered your/their account or withdrawn consent for any collection and processing of your personal data, Globalore will delete your personal data as soon as reasonably possible unless there is a valid legal or business purpose for the continued retention of such data whereupon the personal data shall be retained only for the duration of such valid legal or business purpose.

23. Our Site may, from time to time contain links to other Site operated by third parties (“Third Party Sites“). If you follow a link to any of these Third Party Sites, please note that their privacy policies may differ from ours and we do not monitor nor accept any responsibility or liability for these policies. Please review the privacy policies of each Third Party Site to ensure that you are comfortable them.

24. Globalore will implement reasonable security arrangements to prevent unauthorised access, collection, use, disclosure, modification to and processing of your personal data. Nevertheless, whilst we implement the above security measures, you should be aware that 100% security is not always possible. Further, while we will use all reasonable efforts to safeguard your personal data, you acknowledge that the use of the internet is not entirely secure and for this reason we cannot guarantee the security or integrity of any personal data that are transferred from you or to you via the internet.

25. This Privacy Policy shall be governed by and construed in accordance with the laws of Singapore. The parties irrevocably agree to submit to the non-exclusive jurisdiction of the courts of Singapore as regards any claim or matter arising in relation to this Privacy Policy. The Contracts (Rights of Third Parties) Act (Cap. 53B) shall not apply to this Privacy Policy. Those who choose to access our Site/App from outside the Singapore are responsible for compliance with local laws if and to the extent local laws are applicable.

26. We reserve the right to change this Privacy Policy from time to time. Any changes we may make to this Privacy Policy in the future shall be posted on this page and, where appropriate notified to you by e-mail. Please check back frequently to ensure that you are aware of changes to this Privacy Policy.

27. By submitting personal data to us after the changes coming into effect, you are agreeing that we may collect, use, disclose, and transfer your personal data in accordance with the purposes and uses identified and to the transferees specified in the updated Privacy Policy.

28. If you have any questions, comments or concerns regarding our privacy practices, please write to us at the address set out below: