Singapore Digital Exchange Anti Money Laundering (“AML”) and Counter Terrorist Financing (“CTF”) Policy.
Date of the last revision: 24 April 2018
Commitment to privacy
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:
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.
What Are Cookies
For more general information on cookies see the Wikipedia article on HTTP 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 are looking for more information, please contact customer support.
We collect and process two types of information about users of our services:
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.
Situations where you make or may make, Personal Data available to us including without limitation:
How We Use Your Information
We may use and process your information to:
Legal Bases of Processing
For us to be able to process your Personal Data, we may rely on different legal bases, including:
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:
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
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.
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.
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:
Where we suspect a data breach has occurred, we will immediately conduct an investigation and if one is found will follow the above procedure.