Privacy policy

 Date of the last revision: 24 April 2018

Commitment to privacy

Singapore Digital Exchange is committed to protecting the privacy of its visitors and users. When you use and/or register for our service, we collect, use, share and store information on or related to you (‘your information’) in the manner described in this Privacy Policy. Below, we wish to inform you on how your information, and in particular any personally identifiable information we may hold about you, is collected, used, stored, disclosed, and removed (each and all referred to as ‘processing’).

Please note that this Privacy Policy may be revised and reissued without notice at any time. You should visit this page regularly to review the current version. However, we will strive to inform our users of any major changes to this Privacy Policy by communications posted on our website at Singapore Digital Exchange.

Applicable laws

In Australia, Singapore Digital Exchange is subject to the following laws which require or authorize us to collect personal information, such as the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (AML/CTF Act), Taxation Administration Act 1953, and Income Tax Assessment Act 1936.

Businesses providing digital currency exchange (DCE) services in Australia are regulated under the AML/CTF Act.

As Singapore Digital Exchange provides exchange services to convert money (for example, Australian or US dollars) into digital currency and vice versa, it is required to meet AML/CTF obligations. They include that we: 

• have to enroll and register our business with the Australian Transaction Reports and Analysis Centre (AUSTRAC);
• adopt and maintain an AML/CTF program that reflects Singapore Digital Exchange’s operations
• report suspicious matters and threshold transactions to AUSTRAC;
• keep records relating to customer identification, transactions, and the AML/CTF program.

Cross-border movements

Individuals and businesses, including reporting entities, must report cross-border movements of physical currency of AUD10,000 or more (or the foreign currency equivalent). If required by an Australian Customs and Border Protection or police officer, persons who are entering or leaving Australia must complete a report detailing any bearer negotiable instruments (such as traveler’s cheques, cheques, or money orders) they are carrying, of any value.

Threshold transaction reports

If a reporting entity provides a designated service that involves the transfer of physical currency or e-currency of SGD$ 10,000 or more (or foreign currency equivalent), the reporting entity must submit a report to AUSTRAC.

Suspicious matter reports

If a reporting entity forms a suspicion at any time while dealing with a customer (from inquiry to providing a designated service or later) on a matter that may be related to an offense, tax evasion, or proceeds of crime, the reporting entity must submit a suspicious matter report to AUSTRAC.

Offenses include money laundering, terrorism financing, operating under a false identity, or any other offense under a Commonwealth, state, or territory law.

Cookie policy for Singapore Digital Exchange

What Are Cookies

As is common practice with almost all professional websites, this site uses cookies, which are tiny files that are downloaded to your computer, to improve your experience. This page describes what information they gather, how we use it, and why we sometimes need to store these cookies. We will also share how you can prevent these cookies from being stored however this may downgrade or ‘break’ certain elements of the site’s functionality.

For more general information on cookies see the Wikipedia article on HTTP Cookies.

How We Use Cookies

We use cookies for a variety of reasons detailed below. Unfortunately, in most cases, there are no industry standard options for disabling cookies without completely disabling the functionality and features they add to this site. It is recommended that you leave on all cookies if you are not sure whether you need them or not in case they are used to provide a service that you use.

Disabling Cookies

You can prevent the setting of cookies by adjusting the settings on your browser (see your browser Help for how to do this). Be aware that disabling cookies will affect the functionality of this and many other websites that you visit. Disabling cookies will usually result in also disabling certain functionality and features of this site. Therefore, it is recommended that you do not disable cookies.

The Cookies We Set

If you create an account with us then we will use cookies for the management of the signup process, for general administration, and for preventing abuse and misuse of our services. The cookies will usually be deleted when you log out, however, in some cases, they may remain afterward too, for example, remember your site preferences when logged out. We use cookies when you are logged in so that we can remember this fact. This prevents you from having to log in every single time you visit a new page. These cookies are typically removed or cleared when you log out to ensure that you can only access restricted features and areas when logged in. When you submit data through a form such as those found on contact pages or comment forms, cookies may be set to remember your user details for future correspondence. To provide you with a great experience on this site, we provide the functionality to set your preferences for how this site runs when you use it. To remember your preferences, we need to set cookies so that this information can be called whenever you interact with a page that is affected by your preferences.

Third-Party Cookies

In some special cases, we also use cookies provided by trusted third parties. This section details which third-party cookies you might encounter through this site. This site uses Google Analytics which is one of the most widespread and trusted analytics solutions on the web for helping us to understand how you use the site and the ways that we can improve your experience. These cookies may track things such as how long you spend on the site and the pages that you visit, so we can continue to produce engaging content. For more information on Google Analytics cookies, see the official Google Analytics page. As we provide a service platform, it’s important for us to understand statistics about how our users use the site and the services, and this is the kind of data that these cookies will track. Several partners advertise on our behalf and affiliate tracking cookies allow us to see if our customers have come to the site through one of our partner sites so that we can credit them appropriately, and where applicable, allow our affiliate partners to provide any bonus that they may provide you for making a purchase.

More Information

If you are looking for more information, please contact customer support.

Your Information

We collect and process two types of information about users of our services:

Non-Personal Data

For purposes of this Privacy Policy, ‘Non-Personal Data’ means information that does not identify you and is therefore not deemed as personal data under laws applicable to data controllers. Additionally, Non-Personal Data means to aggregate and anonymized information, which is data collected from the use of the services but from which any personally identifiable data has been removed. Non-Personal Data may include general user base profiling information and other non-identifying information.

We may use tools or third-party analytical software to automatically collect and use certain Non-Personal Data. The types of Non-Personal Data we may collect and use include but are not limited to: (i) end-user software and hardware profile information, including, for example, information on the browser and operating system settings and version; (iii) general data on service usage trends and patterns; (iv) other Non-Personal Data as deemed necessary by us to enhance and further develop the services.

Personal Data

For purposes of this Privacy Policy, ‘Personal Data’ means any information relating to you as an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an online identifier or to one or more factors specific to your identity.

Situations where you make or may make, Personal Data available to us including without limitation:

• Registration and/or verification for the services, such as by disclosing your information on the registration form, or if requested by us, as part of additional identity verification measures
• Using the service, such as by creating advertisements, taking part in trades, or posting on the forums
• Creating a support request on our website, sending us email messages, or through other means of communications directed at us
• Otherwise through the use of the services where Personal Data is required for use and/or participation
• The Personal Data we collect, and process may include:
  • Your name, email address, and other contact details, as well as other personal details we may ask, and you may provide us in the context of the services for purposes of identification, directing communications, and use of the services – please note that if you do not provide this information where requested, parts of the service may be unavailable to you
  • Details on your communications with us, including without limitation any messages, notifications, requests, and similar sent to us by email, by using the service features or otherwise
  • Your account, transaction, and service activity information, including without limitation your account settings as well as information on the advertisements and forum posts you have submitted and the trades you have engaged in, your payment details, and any information on fees or charges related to your service activity along with any information necessary for their determination and review, and site usage information, such as how long you spend on the site and the pages that you visit, IP addresses, browser type, operating system, referring and exit pages, the dates and times of visits, and other site usage behavior

How We Use Your Information

We may use and process your information to:

• Provide our services to you and enable other users of our services to engage with you in trades, communications, and other activities enabled by our services
• Manage your account and your participation in the above-mentioned activities
• Charge you for the use of the services, where applicable, and for debt recovery purposes
• Respond to any issues or inquiries you may have regarding our services and provide you with information relevant to your use of the services, such as updates on scheduled downtime, new features, or issues related to your use of or activity within the services
• Contact you with offers or promotions based on how you use the services or inform you about products and services we think may interest you – provided that we have obtained your consent for this where necessary
• Protect and maintain our network and the services, and prevent, identify and repair any technical problems or security issues
• Verify your identity and prevent, detect and investigate fraud, money laundering, criminal activity, or other misuses of the services
• Meet our legal obligations and protect important interests of ours or those of third parties such as other users of the services
• Perform research and statistical analysis on the services, including observing how our customers use the services
• Better allocate our resources and enhance and improve the services provided to you and other users

Legal Bases of Processing

For us to be able to process your Personal Data, we may rely on different legal bases, including:

• Your separate consent (only when legally required or permitted). To the extent we rely on your consent as a legal basis for processing your Personal Data, you have the right to withdraw your consent at any time;
• The necessity to establish a contractual relationship with you and to perform our obligations under a contract, including without limitation the Terms of Service;
• The necessity for us to comply with legal obligations;
• The necessity to pursue our legitimate interests, including:
• Ensuring the security of our networks, information, and other assets
• Protecting important interests of ours or those of third parties such as other users of the services
• Contacting you to inform you about our products and services we think may interest you
• Administering and generally conducting our business
• Preventing, detecting, and investigating fraud, money laundering, criminal activity, or other misuses of the services
• The necessity to protect the vital interests of any person

Retention of Your Information

We retain your information only for as long as is necessary for the purposes for which we process the information.

Please note that we may continue to process certain Personal Data even after you have stopped using the services, in particular where required by law, regulation, or an order issued by a competent authority, or if the retention of particular data is necessary for us in order to protect important interests of ours or those of third parties such as other users of the services, including without limitation to be able to reactivate your account without loss of data in case you decide to resume using the services, collect any charges or receivables, troubleshoot technical problems and prevent security issues, prevent, detect and investigate fraud, criminal activity or other misuses of the services, enforce our agreements or present or defend against existing or potential claims or complaints, or to defend our rights or property or those of users of the services. In such cases, we will retain and process your Personal Data only to the extent and only for as long as necessary for such purposes.

Any communications and file attachments related to individual trades are retained by us for 180 days after the trade closes unless we decide to further retain any information in a particular case for any of the purposes mentioned above. In case you have a problem with a trade, you must inform us within 150 days of the initiation of the trade. If you have not informed us within that time frame, information on the trade may be removed.

How We Share Your Information

We may disclose your information to:

• Companies in our company group
• Partners or agents involved in delivering the products and services you have ordered or used
• Companies who are involved in performing services and functions for or on behalf of us in connection with our services, such as data storage or hosting
• Professional advisors, such as auditors, lawyers, accountants, and other professional advisors
• Other users of the services if and to the extent disclosure of your information is necessary for the purpose of fund recovery, dispute resolution between the trading parties, or the prevention, detection, or investigation of fraudulent or criminal activity or other misuses of the services
• Fraud prevention agencies and debt recovery organizations engaged in connection to your use of the services
• Law enforcement agencies, courts, regulatory organizations, or other public authorities, if we are so required or authorized to by law

In any case, your Personal Data will be disclosed only for the purposes specified above in this Privacy Policy and only to the extent the disclosures are necessary for relation to these purposes.

We may also transfer your information to other third parties if we need to counter or prevent any malicious or fraudulent actions, invoke any available legal remedies to limit potential damage incurred to us, or if we sell, merge, de-merge, or otherwise restructure our business operations and a new party becomes the controller of the information.

Some of the organizations referred to above are located outside Australia. By submitting your personal information you expressly consent to us disclosing this information to those organizations and to its storage outside of Australia.

We will take reasonable steps to ensure that each organization it discloses your personal information to is committed to protecting your privacy. By allowing us to disclose your personal information to other organizations, you also consent to the terms and conditions and privacy policies of these entities, which are available upon request. Please be aware that your personal information may continue to be used by third-party organizations following the termination of our agreement with them.

How We Secure Your Information

Any collected Personal Data is stored in accordance with this Privacy Policy and any applicable laws in secure locations and servers as follows:

• Our premises are physically protected with mechanical and electrical locks and other break-in prevention methods;
• Our data connections utilize firewalls and protection from malicious programs, as well as other protection mechanisms and software which improve the security of our telecommunications and data connections; and
• Only designated persons and a limited amount of our personnel have access to the information. Our personnel has been trained to observe data security in their work.

Automated Decisions

We reserve the right to make automated decisions, including using machine learning algorithms, about our customers and website visitors in order to optimize the products and services offered and/or delivered. The use of automated fraud and risk modeling, in particular, may lead to the use of your account being temporarily limited pending our manual review and/or additional identity verification measures required from you.

Opting Out of Newsletters

Users who sign up for Singapore Digital Exchange will automatically receive Singapore Digital Exchange Newsletters. Should you later wish to opt-out of receiving this information, please contact us and you will be removed from the recipient list and no longer receive such communications.

Your Rights as a Data Subject

You have the right to obtain from us confirmation as to whether Personal Data concerning you is being processed by us, and where that is the case, access to that Personal Data as well as to have any inaccurate or incomplete Personal Data rectified or completed. In certain circumstances and/or with respect to specific data, processing purposes, or legal bases for processing, you may also have the right to request the erasure, or the restriction of processing, of your Personal Data or parts of it, to object to the processing and/or to receive the data in a structured, commonly used and machine-readable format.

Please contact our customer service for any inquiries related to exercising the above rights. We may charge you the reasonable costs of providing you access to this information where allowed by applicable law.

If you consider our processing activities of your personal data to be inconsistent with the applicable data protection laws, you may lodge a complaint with the responsible supervisory authority.

Public Forums/Chat Room

This website has a message board and chat rooms available to its users. Please bear in mind that any information that is disclosed in these areas becomes public information and you should exercise caution when deciding to disclose your personal information.

Linking and Framing

The Platform may contain links to other and third-party websites and Singapore Digital Exchange may display content or information from other websites within frames on the Website. By clicking links or accessing Third Party Websites through the Platform or Website, Singapore Digital Exchange may earn a payment because of that advertising or that referral.

Singapore Digital Exchange is not responsible or liable for the third-party website, any third-party content nor for any infringement of third-party intellectual property rights as a result of hosting links to third-party websites and third-party content on the Platform. 

Singapore Digital Exchange is not responsible or liable for the handling, use, or disclosure of any personal information collected by a third party (including information collected through a third-party website), and to the extent permitted by law, Singapore Digital Exchange disclaims any liability resulting from the third party’s failure to handle, use and disclose your personal information in accordance with the Privacy Act 1988 (Cth).

Singapore Digital Exchange does not warrant the accuracy, currency, or suitability for any purpose of the third-party websites or third-party content, nor does Singapore Digital Exchange endorse the offers, products, or services that they may promote.

All statements, representations, offers, products, or services provided through third-party websites and third-party content are the sole responsibility of the operator of the third-party website or the author of the third-party content and in so far as such links to third-party websites or third-party content are hosted on the Platform they are done so at the request of the operator or author for the purposes of promoting their offers, products, and services. Except where expressly stated otherwise, Singapore Digital Exchange does not act as an agent, representative, partner, or in any other capacity on behalf of such operator or author.

Competitions

Singapore Digital Exchange may occasionally run competitions with other websites and we will ask visitors for their contact information. Any information that you supply will be held in the strictest confidence and will only be used in conjunction with the competition. In order for visitors to take part in the competitions, you must be a member of the Singapore Digital Exchange Platform.

Data Breaches

While we will take all reasonable endeavors to secure your data, there is regrettably always the possibility of unauthorized access to, unauthorized disclosure of, or loss of your personal information that we hold (data breach).

Under the Australian Notifiable Data Breaches scheme (NBD scheme), where we have reasonable grounds to believe that there has been a data breach and that it is likely to cause serious harm to one or more individuals, we will notify the Office of the Australian Information Commissioner (OAIC) by way of the prescribed statement.

Additionally, we will either:

• (i) notify all individuals whose personal information is part of the eligible data breach; or

• (ii) notify only individuals at risk of serious harm from the eligible data breach; or

• (iii) if the above isn’t practicable, publish a copy of the statement on our site and take reasonable steps to publicize the contents of the statement.

Where we suspect a data breach has occurred, we will immediately conduct an investigation and if one is found will follow the above procedure.