Privacy Policy

1. Parties

1.1 ECXX Global Private Limited. (hereinafter referred to as ‘the Company’) is a company incorporated in the Republic of Singapore under the laws of Singapore, and operates the Website https://www.ecxx.co (hereinafter referred to as ‘this Website’ or ‘the Website’), which is a platform dedicated to the transaction of digital assets and the provision of related services (hereinafter referred to as ‘the Service’). For the convenience of wording in this Agreement, the Company and the Website are referred to collectively as ‘we’ or other applicable forms of first person pronouns in this Agreement.

1.2 All natural persons or other subjects who log onto this Website shall be users of this Website. For the convenience of wording in this Agreement, the users are referred to as ‘you’ or any other applicable forms of the second-person pronouns.

1.3 For the convenience of wording in this Agreement, you and we are collectively referred to as “both parties”, and individually as “one party”.

2. Privacy Policy

This Privacy Policy sets out the basis we may collect, use, disclose or otherwise process personal data of our customers in accordance with the Personal Data Protection Act (“PDPA”). This Privacy Policy applies to personal data in our possession or under our control, including personal data in the possession of organisations which we have engaged to collect, use, disclose or process personal data for our purposes.

3. Consent Obligation

To ensure that you have full confidence in our handling of personal data, you are advised to read and understand the terms of this Privacy Policy in detail. In particular, upon your log into our Website, regardless of whether you register with this Website, you shall be deemed to accept, agree, undertake and consent that:

3.1 You, on the basis of your own free will and your requisite consent, agree to disclose your personal information to us;

3.2 You will comply with all the terms and limitations of this Privacy Policy;

3.3 You agree that we may collect your information through your log into this Website, your registration with this Website, and/or your using the Services offered by us; you agree to any changes and modifications that we may make to our Privacy Policy in the future;

3.4 You agree that our branches, affiliates and employees may contact you in connection with the products and services that you may be interested in (unless you have indicated that you do not want to receive such information).

3.5 The consent that you provide for the collection, use and disclosure of your personal data shall remain valid until such time it is being withdrawn by you in writing a request to us. You may withdraw consent and request us to stop using and/or disclosing your personal data for any or all of the purposes listed by submitting your request in writing or via email to our Data Protection Officer at DPO@ecxx.com

3.6 Upon receipt of your request to withdraw your consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us. In general, we shall seek to process your request within fifteen (15) business days upon receiving the request.

3.7 Whilst we respect your decision to withdraw your consent, please note that depending on the nature and scope of your request, we may not be in a position to continue providing our services and/or products to you and we shall, in such circumstances, notify you before completing the processing of your request. Should you decide to cancel your withdrawal of consent, please inform us in writing in the manner described in clause 3.5 above.

3.8 Withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclose without consent is permitted or required under applicable laws.

4. Types of Information Collected

4.1 When you use this Website, you agree to permit us to use cookies to track each of your actions and collect and keep all the information that you leave on this Website, including but not limited to your IP address and geographical location.

4.2 If you are willing to use the services offered by this Website, you will be required to fill in and provide the following two categories of information:

4.2.1 Identity Information. Such information can help us verify whether you are eligible to be registered as a member of this Website. It includes but is not limited to your full name, identification number issued by your government that certified your identity information (e.g. NRIC number, FIN number, Passport number), residence address, gender, photo(a selfie), other information that can help us to verify your identity (hereinafter referred to as ‘identity information’).

4.2.2 Service information. Such information helps us to contact you and provide you with the services, including but not limited to your phone number, valid email address, mailing address, and information concerning your account (hereinafter collectively referred to as ‘service information’).

4.3 When you use this Website or the services this Website offers, we may collect more information necessary from our exclusive mailboxes or in other manners that we consider as in compliance with relevant requirements, for the purpose of improving the functions of this Website, enhancing your experience of using this Website and its services as well as the security thereof, or as is required by any court order, any applicable law, administrative regulation or any order of any other competent government agency.

4.4 If you visit any of links to third-party websites as are listed on this Website or any link of any of our third-party partners, you shall agree to and comply with the separate and independent Privacy Policy of such third party website. We will not bear any liability for the contents and activities of such websites or the partners.

5. Cookies

5.1 When you visit our Website, we use Google stats via cookies to record our performance and check the effect of online advertising. Cookies are a small amount of data that is sent to your browser and stored on your computer hard drive. Only when you use your computer to access our Website can the cookies be sent to your computer hard drive.

5.2 Cookies are usually used to record the habits and preferences of visitors in browsing the items on our Website. The information collected by cookies is non-registered and collective statistical data and does not involve personal data.

5.3 Cookies, which enable the Website or service provider system to recognize your browser and capture and recall information, cannot be used to obtain data on your hard drive, your email address, or your personal data. Most browsers are designed to accept cookies. You can opt to set your browser to reject cookies, or to notify you as soon as possible if you are loaded on cookies. However, if you set your browser to disable cookies, it is possible that you may not be able to launch or use some functions of our Website.

6. Ways of Information Collected

6.1 We may obtain your information in the following ways:

6.1.1 when you submit any form, including but not limited to application, declaration, referral forms or other forms relating to any of our services;

6.1.2 when you use our services (including but not limited to websites, mobile applications and any online accounts established with us);

6.1.3 when you request that we contact you, be included in an email or other mailing list; or when you respond to our request for additional Personal Data, our promotions and other initiatives;

6.1.4 when you sign up for or use one of the many services we provide or when you register an account at our Website, including mobile applications;

6.1.5 when you sign up for our seminars, events or webinars;

6.1.6 when you contact us through various methods such as application forms, emails and letters, telephone calls and conversations you have with our employee.

6.1.7 from our analysis of your transactions (including but not limited to transaction history);

6.1.8 when you participate in customer surveys or when you sign up for any of our events or promotions; and

6.1.9 when you submit your information to us for any other reason(s).

7. Purposes for the Collection, Use and Disclosure of Information

7.1 For legal and business purposes, we shall use your information that we collect for the following purposes or in the following ways:

7.1.1 to provide you with our Services and/or Products through our Website;

7.1.2 to identify and verify your identity when you use our Website;

7.1.3 to improve and upgrade the services of the Website (your information and feedback received by us can help us improve the service of the Website, so that we can more effectively respond to your service requests and support needs);

7.1.4 to keep statistics relating to the use of our Website and to be used for data analysis carried out in cooperation with government agencies, public affairs institutions;

7.1.5 to personalize your experience (your information will help us to better respond to your personalized needs);

7.1.6 to facilitate transactions (your information, whether public or private, will not be sold, exchanged, transferred, or otherwise provided to any other company on any grounds without your consent, except for where doing so is expressly for the purpose of completing the transaction you require);

7.1.7 to send e-mail regularly (the email address that you provide for the purpose of processing orders may be used to receive information on and updates to your orders, in addition to newsletters, updates, related products or services information, etc., that we may send to you from time to time); and

7.1.8 to meet other purposes as specified in the User Agreement of this Website and all legal means adopted for satisfying such purposes.

8. Protection of Personal Data

8.1 We do not sell, trade, or otherwise transfer information or allow others to collect, use information; however, such information does not involve the following parties and does not include the following information: our affiliates, trusted third parties who help us operate our websites, manage our business, or provide services to you, provided that such parties agree to keep such information confidential; When we believe that information disclosure is appropriate, or it is required by any of the applicable laws, regulations, rules or by any order of courts or other competent authorities, and is necessary for executing the strategy of our Website and ensuring the proper functioning of the Website, or as may be necessary for the related parties to provide services, or for the protection of the rights, property or safety of us or other persons. However, your information will not be provided to other parties for marketing, advertising or other purposes.

8.2 We adopt appropriate physical, electronic, management and technical measures so as to protect and safeguard the security of your personal data. We will, to the greatest extent possible, ensure that any personal data collected through our Website shall be free from being subject to nuisance by any third party unrelated to us. The security measures that we may take include but are not limited to:

8.2.1 Physical measures: records of your personal data will be stored in a properly locked place.

8.2.2 Electronic measures: The computer data that contain your personal information will be stored in computer systems and storage medias that are subject to strict login restrictions.

8.2.3 Management measures: only staff members duly authorized by us can access your personal data, and these staff members shall comply with our internal code concerning personal data confidentiality.

8.2.4 Technical measures: such encryption techniques as Secure Socket Layer Encryption may be used to convey your personal data.

8.2.5 Other measures: our network servers are protected by proper ‘firewall ‘.

8.3 If you are aware of any security flaws in our Website, please contact our Data Protection Officer immediately at DPO@ecxx.com so that we can take appropriate action.

8.4 Despite of the above-mentioned technical and security measures, we cannot guarantee that the information transmitted via the Internet is absolutely safe, so we cannot absolutely guarantee that the personal data that you provide to us through our Website will be safe at any time. We will not be held liable for any loss or damage arising from or caused by any event that may occur in connection with unauthorized access to your personal data, and we shall not be held liable for compensation for such loss or damage.

9. Rights to Access and Correction to Provide Accuracy of Personal Data

9.1 You have the right to access your Personal Data we hold about you and the right to know how we process, use and share.

9.2 We reserves the right to charge a reasonable administrative fees for the access request. We shall inform you of the fees before processing your request.

9.3 We reserves the right to deny your request to access your Personal Data and shall provide an explanation as required by applicable laws.

9.4 You have the right to correct any Personal Data provided about you that is inaccurate. We generally rely on the personal data and information provided by you. In order to ensure that your personal data is current, complete and accurate, please update us if there are changes to your personal data.

9.5 To exercise any of the rights, please contact our Data Protection Officer at DPO@ecxx.com

10. Retention of Personal Data

10.1 We may retain your personal data for as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws.

10.2 We will cease to retain your personal data, or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purpose for which the personal data was collected, and is no longer necessary for legal or business purposes.

11. Transfers of Personal Data Outside of Singapore

We generally do not transfer your personal data to countries outside of Singapore. However, if we do so, we will obtain your consent for the transfer to be made and we will take steps to ensure that your personal data continues to receive a standard of protection that is at least comparable to that provided under the PDPA.

12. Amendments to Privacy Policy

We reserve the right to amend the Privacy Policy from time to time and at any time. We will inform you of the amendments made to the Privacy Policy by updating and publishing the effective date of the release of new version. We may issue a notice to inform you of the amendments made in the Privacy Policy, which, however, is not an obligation for us. You shall regularly review the Privacy Policy and if you do not agree to such amendments, you shall immediately stop accessing this Website. When an updated version of this Privacy Policy is published, your continued visit to this Website shall indicate and show that you agree to the amendments and agree to comply with the updated Privacy Policy.

13. Communicate with us

13.1 If you have any requests and comments, you can send an email to our Data Protection Officer at DPO@ecxx.com, which is the only valid and official email through which we communicate with you for this privacy policy, so we will not bear any liability for your failure to using effective contact information, any act or omission.

13.2 We only publish announcements and information on the basis of the valid and effective contact information on this Website or post announcements on this Website; therefore, we shall not be held liable for any loss arising from your trust in the information that has not been obtained through the above-mentioned means.

13.3 If you have any questions regarding our Privacy Policy, you are welcome to contact our Data Protection Officer at DPO@ecxx.com.

14. General Data Protection Regulation (GDPR)

14.1 This Privacy Policy has also incorporated elements from the General Data Protection Regulation (GDPR) as we act in accordance to its personal information processing rules within the European Economic Area (EEA). GDPR applies to any organisation established within and outside of the EU, so long as: the organisation offers goods or services to individuals in the EU, or monitors their behaviour within the EU processes and holds personal data of individuals residing in the EU, regardless of the organisation’s location.

14.2 For EEA Residents only, you may exercise your rights in relation to the Personal Data as set out below:

14.2.1 Right to Access. You have the right to know whether we process Personal Data about you, and if we do, to access Personal Data we hold about you, in a copy of electronic format, and certain information about how we use and who we share with.

14.2.2 Right to Data Portability. You have the right to receive a subset of the Personal Data we collect from you in a structured, commonly used and machine readable format and a right to request that we transfer such Personal Data to another party. The relevant subset of Personal Data is data that you provide us with your consent or for the purposes of performing our contact with you. If you would like to request the transfer of Personal Data to another party, please ensure you detail that party and note that we can only do so where it is technically feasible. We are not responsible for the security of the Personal Data or its processing once received by the third party. We also may not provide you with certain Personal Data if providing it would interfere with another’s rights (e.g. where providing the Personal Data we hold about you would reveal information about another person)

14.2.3 Right to Rectification. You have the right to correct any Personal Data held about you that is inaccurate or incomplete.

14.2.4 Right to Erasure or Deletion. You have the right to request that we delete the Personal Data that we process about you, except we are not obliged to do so if we need to retain such data in order to comply with a legal obligation or to establish, exercise or defend legal claims.

14.2.5 Right to Restrict Processing. You have the right to restrict our processing of your Personal Data where you believe such data to be inaccurate; our processing is unlawful; or that we no longer need to process such data for a particular purpose unless we are not able to delete the data due to a legal or other obligation or because you do not wish for us to delete it.

14.2.6 Right to Object. Where the legal justification for our processing of your personal information is our legitimate interest, you have the right to object to such processing on grounds relating to your particular situation. We will abide by your request unless we have compelling legitimate grounds for the processing which override your interests and rights, or if we need to continue to process the data for the establishment, exercise or defence of a legal claim.

14.2.7 Withdrawing Consent. If you have consented to our processing of your personal information, you have the right to withdraw your consent at any time, free of charge. This includes cases where you wish to opt out from marketing messages that you receive from us. You also have the right to lodge a complaint with the local data protection authority if you believe that we have not complied with applicable data protection laws.

14.3 You are required to provide us with your proof of identity before we respond to any requests to exercise your rights. We shall respond to a request by you to exercise those rights without undue delay and respond within one month. Dealing with requests of individuals shall be carried out free of charge. Where requests are manifestly unfounded or excessive, in particular because of your repetitive character, we may charge a reasonable fee or refuse to act. To exercise any of the rights, please contact our Data Protection Officer at DPO@ecxx.com.