APEX Website and Mobile Application Privacy Policy (“Privacy Policy”)
This Website (www.asiapacificex.com) / Mobile Application (APEX Mobile) is owned and operated by Asia Pacific Exchange Pte. Ltd. (“APEX“), a company incorporated in Singapore and licensed by the Monetary Authority of Singapore. APEX and Asia Pacific Clear Pte. Ltd. shall collectively be referred to as APEX Group.
Your privacy is important to us. PLEASE READ THIS PRIVACY POLICY CAREFULLY BEFORE USING THIS WEBSITE / MOBILE APPLICATION. It contains important information about what to expect when we collect personal data about you and how we will use your personal data.
This Privacy Policy applies only to the information collected on our Website / Mobile Application. For purposes of this Privacy Policy, “Website” means the Website of APEX Group available to the general public and located at www.asiapacificex.com, or any software application made available by the APEX Group for use on a computer, tablet, mobile phone or other mobile device. “Mobile Application” means the APEX Mobile application available to the general public by the APEX Group for use on a tablet, mobile phone or other mobile device.
This Privacy Policy does not apply to access to APEX’s electronic trading platforms, whether through the internet or by other means. Access to APEX’s electronic trading platforms is limited to members and participants of the relevant market who have entered into electronic user agreements (or any other relevant agreements) with APEX for such access, and is governed by the terms of those agreements.
Your use of this Website / Mobile Application and our services, and any dispute over privacy, is subject to this Privacy Policy and our Website / Mobile Application Terms and Conditions respectively.
The APEX Group is subject to the Personal Data Protection Act 2012 of Singapore (“PDPA“) (as amended from time to time) and other applicable data protection laws to the extent the APEX Group is subject to them, which shall prevail over this Privacy Policy in the event of any inconsistency.
1. Collection of Information
We collect personal data from you when you use our Website / Mobile Application; the type of information that we collect from you depends on your particular interaction with our Website / Mobile Application.
We may collect the following personal data from you: your name, NRIC, passport or other identification number, country of residence, address, phone number, job title, company, email address, your employment history, education background and income levels and any other information relating to you which you have provided to the APEX Group.
In addition, we and our third party service providers use cookies, web beacons, and other tracking technologies to collect information about you automatically as you use our Website.
Examples of this type of information include, but are not limited to, the dates and times of your use of this Website / Mobile Application and the route by which you choose to access it, including your IP (Internet Protocol) address, your browser type, your operating system, or domain name, and your use of any hyperlinks or downloadable content available on this Website / Mobile Application. We may combine this information with other information that we collect about you. For additional information about our use of these technologies, please refer to our Cookies Policy.
2. How we will use the information about you
You agree that the APEX Group may collect, store, process, disclose, access, review and/or use personal data (including sensitive personal data) about you, whether obtained from you or from other sources, for the purposes set out below and/or any other administrative or operational purposes and/or for the purposes of managing your relationship as a customer with APEX or any other company within the APEX Group or with our clearing and/or trading members:
(i) to help us identify you and any accounts you hold with us;
(ii) research, statistical analysis and behavioural analysis;
(iii) marketing;
(iv) fraud prevention and detection;
(v) providing services to you in relation to your transactions with APEX;
(vi) enabling your use of the services which APEX provides, including, where necessary, contacting you (whether by SMS, email or otherwise);
(vii) dealing with enquiries made by you;
(viii) maintenance and updating of the data;
(ix) administrative or operational purposes;
(x) for the APEX Group to comply with legal and/or regulatory requirements;
(xi) tax filing preparation;
(xii) processing credit notes and processing refunds;
(xiii) collection of fees, charges and expenses for services provided;
(xiv) verification and identification purposes;
(xv) facilitating the making and payment of claims, including payments by cheque, bank transfers or other means;
(xvi) carrying out billing, accounting, auditing and the maintenance of proper book-keeping to explain the APEX Group’s operations and business; and/or
(xvii) the disclosure of the relevant books, documents, records and information (in hard or soft copy) to the auditors for the preparation of financial reports.
3. Marketing
The APEX Group may wish to provide you with information about special features of our Website / Mobile Application or any other service or products we think may be of interest to you. If you would rather not receive this information, you may send an email to opt out from such marketing features to enquiries@asiapacificex.com. If you have consented to us providing you with marketing information, you may choose to opt out at any time.
4. Our use of cookies and other information-gathering technologies
Cookies are text files placed on your computer and/or mobile devices to collect standard internet log information and visitor behaviour information. Please refer to our Cookies Policy for further information about cookies.
5. How we protect your information and retention of information
All your personal data is kept confidential and the APEX Group takes all reasonable measures to protect it from unauthorized or accidental access, processing or loss, by implementing appropriate physical, electronic and supervisory controls.
We will retain your personal data for as long as it is necessary to fulfil the purpose(s) for which it was collected, the legal and business purposes of our business, or as required by relevant laws.
We will cease to retain the personal data or remove the means by which the personal data can be associated with individuals when it is no longer necessary for legal or business purposes.
6. Overseas transfers
The personal data you provide may be transferred to countries or territories outside of Singapore that do have similar protections in place regarding your data and restrictions on its use as set out in this Privacy Policy. Such personal data may be transmitted to data storage facilities where we keep our central records. Personal data may also be transferred to our offices and appointed agents in Singapore or other countries or territories in connection with our performance of the contract with you. We will ensure that the recipients thereof provide a standard of protection to your personal data so transferred that is comparable to that which is provided herein. By submitting your personal data, you consent to these transfers for the purposes specified above.
7. Access to your information and accuracy of your information
You are entitled to have access to the personal data about you that is in the possession or under the control of the organization and information about the ways in which the personal data has been or may have been used or disclosed within a year before the date of the request. You may do so by sending an email to the Data Protection Officer at dpo@asiapacificex.com or a letter to 1 Phillip Street, Royal One Phillip, #06-00, Singapore 048692. The APEX Group reserves the right to charge an administrative fee of S$25 for each request for information, and reserves the right to increase the administration fee if the requested information is voluminous. The APEX Group reserves the right to not respond to a request in relation to which the administration fee has not been paid or to refuse requests which, in its opinion, occur with unreasonable frequency.
The APEX Group will also, where you have requested that it corrects an error or omission in your personal kept with the APEX Group, within 30 days of receipt of the correction request either:
(i) correct such data and send the corrected personal data to every organization to which the personal data was sent within a year before the date the correction was made, if applicable, unless that organization does not need the corrected personal data for any legal or business purpose or
(ii) if the APEX Group determines that it is unable to meet the timeline at (i) above, inform you in writing of the time by which it will be able to correct the personal data.
The APEX Group may however choose not to provide you with access to or correct such information, in accordance with the exceptions under the PDPA.
We may also request that you update your personal data. We want to ensure that your personal data is accurate and up to date and seek your assistance to ensure that such information is current, complete and accurate. If any of the information that you have provided to the APEX Group changes, for example, if you changed your email address, or name, or if you wish to withdraw your consent for which you have provided us your personal data, please let us know by either sending an email to the Data Protection Officer at dpo@asiapacificex.com or by sending a letter to the Data Protection Officer at 1 Phillip Street, Royal One Phillip, #06-00, Singapore 048692.
8. Data Quality
The APEX Group will take reasonable steps to make sure that the personal data it collects, uses or discloses is accurate, complete and up to date.
9. Data Security
The APEX Group will take reasonable steps to protect the personal data it holds from misuse, loss and from unauthorized access, modification or disclosure.
The APEX Group will not keep personal data for longer than is necessary and will take reasonable steps to destroy or permanently anonymise personal data if it is no longer needed.
10. Sale of business
If our business is sold or integrated with another business, your personal data may be disclosed to our advisers and any prospective purchasers and their advisers, and will be passed on to the new owners of the business.
11. Your consent
By submitting your personal data through the Website / Mobile Application, you consent to the collection, use, disclosure and processing of your personal data in accordance with this Privacy Policy.
You may withdraw your consent at any time by submitting a request to us at the contact details below.
12. Changes to the Privacy Policy
We keep our Privacy Policy under regular review and reserve the right to change this Privacy Policy from time to time. Changes and modifications to this Privacy Policy will be effective immediately upon posting of the changes and modifications on the Website / Mobile Application, except where prohibited by law. We may amend this Privacy Policy by posting amendments on this Website / Mobile Application. You should therefore periodically visit this page to review the current Privacy Policy. If you choose not to accept the terms of this Privacy Policy at any time, you should not use this Website / Mobile Application.
This Privacy Policy was last updated on 22 June 2023.
13. How to contact us
We welcome your views about our Website / Mobile Application and our Privacy Policy. If you would like to contact us with any queries or comments, please send an email to the Data Protection Officer at dpo@asiapacificex.com or send a letter to the Data Protection Officer at 1 Phillip Street, Royal One Phillip, #06-00, Singapore 048692.
14. Links to other websites
Our Website / Mobile Application may contain links to other websites / applications which are run by third parties that are not affiliated with us and that have their own separate and independent privacy policies. We do not verify nor endorse, make no representation or warranty relating to, have no control over and are therefore not responsible nor liable for the content of such third party websites / applications and activities of such third parties (including third party materials, products, services or reputation).
15. Governing Law
This Privacy Policy and your use of this Website / the Mobile Application shall be governed in all respects by the laws of Singapore. You agree to submit any disputes arising out of or in connection with this Privacy Policy to the exclusive jurisdiction of the Singapore courts.