This Policy applies to ECG Pte Ltd (201622990Z ) and any holding companies, other subsidiaries or related entities of Tradinginsider.com, all of which are referred to as “Tradinginsider”, “we”, “our”, or “us”. The Policy extends to and covers all operations and functions of ECG Pte Ltd.
At TradingInsider, we are committed to ensuring the confidentiality and security of the personal information supplied by individuals. TradingInsider is bound by the Singapore Privacy Principles (‘SPPs’). Trading In has appointed a Privacy Officer, who oversees the Privacy Policy, and ensures that TradingInsider’s management of personal information is in accordance with this Policy and with the Privacy Act.
TradingInsider Privacy Policy Statement will be reviewed from time to time to take account of new laws and technology, changes to our operations and practices and to make sure it remains appropriate to the changing environment.
The word “individual” refers to a customer, client, trustee or any other person with whom we come into contact. All contractors, sub-contractors, vendors, service providers, customers, agents or any other third parties that have access to and/or utilise personal information collected and/or held by TradingInsider must abide by this Privacy Policy.
“Personal information” is information or an opinion relating to an individual, which can be used to identify that individual. Some personal information, which we collect, is “sensitive information”. “Sensitive information” includes information relating to a person’s racial or ethnic origin, political opinions, religion, trade union or other professional or trade association membership, sexual preferences and criminal record, which is also personal information, and also includes health information about an individual.
As the provider of financial services, including trading education, we may collect sensitive information about an individual’s personal circumstances and financial details, which may potentially identify the individual and/or contains an opinion about the individual.
Our ability to provide individuals with our products and services is sometimes dependent on us obtaining certain personal information about the individual. Typically, the type of personal information we collect about the individual includes his or her name, age, date of birth, occupation, mailing address, phone numbers, email address and other information that is relevant to the products and services we provide.
The personal information may also include information about the form of identification used in relation to an individual to send or receive a transaction (required by law in some instances), and information about a transaction in relation to an individual, including details of the amounts paid in or out of an individual’s account as well as delivery instructions.
We generally collect personal and/or sensitive information from individuals by the following methods:
1.1 directly from applications, questionnaires and/or forms completed by individuals (via our websites), which include surveys or special offers, when individuals wish to use our services, purchase our products or apply for a position in our organisation;
1.2 from information disclosed to us by an individual on the phone, or by sending us correspondence (by letter, fax or email) or contact us in person; and
1.3 from a variety of third party sources, including our business contacts credit reference and credit checking agencies, and financial institutions.
The above list is not exhaustive.
In some circumstances we may be provided with personal information about an individual from somebody else, for example a referral from another person. We will take reasonable steps to inform the individual that it holds the personal information and the purpose for which it holds the personal information.
The Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) and Anti-Money Laundering and Counter-Terrorism Financing Rules Instrument 2007 (No. 1) require us to collect certain identification information about you. We will collect personal information from third parties in respect of AML/CTF checks which are required to be carried out, under AML/CTF Legislation.
We must not collect sensitive information unless the individual has consented, or it is required by law, or in other special specified circumstances.
Having provided consent, you are able to withdraw it at any time. To withdraw consent, please contact our office. Please note that withdrawing your consent may lead to us no longer being able to provide you with the product or service you enjoy given that, as mentioned above, it is impracticable for us to treat some customers differently.
If the personal information we request is not provided, we may not be able to provide individuals with the benefit of our services, or meet an individual’s needs appropriately.
We may not be able to provide you with the products or services you are seeking if you provide incomplete or inaccurate information.
We collect personal information for the following purposes:
The personal and sensitive information we collect generally consists of name, address, date of birth, gender, marital status, occupation, account details, contact details (including telephone, facsimile and e-mail) and financial information.
We are required by law to identify you if you are opening a new account or adding a new signatory to an existing account. Anti-money laundering laws require us to sight and record details of certain documents (i.e. photographic and non photographic documents) in order to meet the standards set under those laws.
We may take steps to verify the information we collect; for example, a birth certificate provided as identification may be verified with records held by the Registry of Births, Deaths and Marriages to protect against impersonation.
The type of information we may collect and hold includes (but is not limited to) personal information about:
If we receive personal information that is not solicited by us, we will only retain it, if we determine that it is reasonably necessary for one or more of our functions or activities and that you have consented to the information being collected or given the absence of your consent that it was impracticable or unreasonable for us to obtain it under the circumstances.
If these conditions are not met, we will destroy or de-identify the information.
If such unsolicited information is sensitive information we will obtain your consent to retain it regardless of what the circumstances are.
When we refer to “use “of personal information, we mean use within our organisation for the purposes outlined above. When we use the word “disclose” we mean providing the information to persons outside of our organisation.
We may use and disclose personal information for the primary purposes for which it is collected, and also for reasonably expected secondary purposes which are related to the primary purpose and in other circumstances authorised by the Privacy Act. Sensitive information will be used and disclosed only for the purpose for which it was provided or a directly related secondary purpose, unless the individual agrees otherwise, or where certain other limited circumstances apply (e.g., where required by law).
We may use and disclose personal information for the following purposes:
When you enter provide your contact details as part of a survey or market research questionnaire, we may ask for your name, address, and e-mail address so we can conduct the survey and thereby enhance our services. We may ask for other information to enable us to improve our websites or to send you special offers. In these instances we will usually provide you with an opportunity to opt out from receiving any information after providing your details.
Unless a client agrees and consents, we do not disclose personal information we collect to others for the purpose of allowing them to direct market their products and services. We do not use or disclose sensitive personal or contact information for direct marketing purposes without the consent of clients or users.
We may engage other people to perform services for us, this may involve those people handling personal information that we possess. In these situations, we prohibit that person from using personal information about you except for the specific purpose for which we supply it. We may disclose personal and/or sensitive information to:
We may also collect personal and/or sensitive information from these organisations and individuals, and deal with that information in accordance with this Policy. TradingInsider trains its employees and advisers who handle personal information to respect the confidentiality of customer information and the privacy of individuals. TradingInsider regards breaches of your privacy very seriously and will impose appropriate penalties for breach of this Policy, which may, in certain circumstances, include dismissal.
We may be required to disclose customer information by law e.g. under Court Orders or Statutory Notices pursuant to taxation or social security laws or under laws relating to sanctions, anti-money laundering or counter terrorism financing.
We will only use or disclose the personal information we hold about you for the purpose of direct marketing if we have received the information from you and you have not requested not to receive such information.
We will only disclose your personal information to a recipient who is not in Singapore and who is not our entity after we ensure that:
The Privacy Act requires us to take all reasonable steps to protect the security of personal information. Safeguarding the privacy of your information is important to us, whether you interact with us personally, by phone, mail, over the internet or other electronic medium.
We hold personal information in a combination of secure computer storage facilities and paper based files and other records, and take steps to protect the personal information we hold from misuse, loss, unauthorized access, modification or disclosure.
We may need to maintain records for a significant period of time. However, when we consider information is no longer needed, we will remove any details that will identify you or we will securely destroy the records.
We will not use identifiers assigned by the Government, such as a tax file number, Medicare number or provider number, for our own file recording purposes unless required or authorized to do so by or under Singapore law, regulation or court/tribunal order.
Before using or disclosing a government related identifier of an individual, we will ensure that such use or disclosure is:
We take reasonable steps to ensure that the personal information it holds is accurate, complete and up-to-date. We encourage individuals to contact us in order to update any personal information we hold about them. Our contact details are set out at the end of this document.
Under the Privacy Act, you have the right to obtain a copy of any personal information which TradingInsider holds about you and to advise TradingInsider of any perceived inaccuracy.
To make a request, you will need to complete an application form verifying your identity and specifying what information you require. We will acknowledge your request within 14 days and respond promptly to it or if that deadline cannot be met owing to exceptional circumstances, your request will be dealt with within 30 days.
If we refuse to provide the information, we will provide reasons for the refusal and inform the individual of any exceptions relied upon under the Privacy Act.
If you want to make a general enquiry about ECG Pte Ltd ‘s privacy policy, change your personal information, lodge a complaint or obtain an application form for access to your personal information, please contact us using the details at the end of this document.
We will require identity verification and to specify what information is required. An administrative fee for search and photocopying costs may be charged for providing access. We will advise of the likely cost in advance.
If we refuse to give access to the personal information or to give access in the manner requested by you, we will give you a written notice setting out the reasons for the refusal, the mechanisms available to complain and any other relevant matter. Additionally, we will endeavour to give access in a way that meets both yours and our needs.
We will correct all personal information that we believe to be inaccurate, out of date, incomplete, irrelevant or misleading given the purpose for which that information is held or if you request us to correct the information.
If we correct your personal information that we previously disclosed to another SPP entity you can request us to notify the other SPP entity of the correction. Following such a request, we will give that notification unless it is impracticable or unlawful to do so.
If we refuse to correct the personal information as requested by you, we will give you a written notice setting out the reasons for the refusal, the mechanisms available to complain and any other relevant matter.
If we refuse to correct the personal information as requested by you, you can request us to associate with the information a statement that the information is inaccurate, out of date, incomplete, irrelevant or misleading. We will then associate the statement in such a way that will make the statement apparent to users of the information.
Updates to this Policy
TradingInsider’s Privacy Policy will be reviewed from time to time to take account of new laws and technology, changes to our operations and practices and to make sure it remains appropriate to the changing environment.
It is the responsibility of management to inform employees and other relevant parties that this Privacy Policy is maintained and enforced. Management must ensure that they periodically advise TradingInsider’s employees and other relevant parties of any changes to the Privacy Policy in a timely manner. It is the responsibility of all employees and other relevant parties to ensure that they understand and adhere to this Privacy Policy. Ignorance of the existence of the Privacy Policy will not be an acceptable excuse for non-compliance.
All new employees must be provided with timely and appropriate access to Asiaforexmentor’s Privacy Policy. All employees must be provided with opportunities to attend appropriate and periodic Privacy awareness training and must ensure that they understand the Privacy related issues that could adversely affect Asiaforexmentor’s position if not properly adhered to.
Any ECG Pte Ltd employee or relevant third party that identifies, knows about, or suspects a Privacy breach must immediately report the matter to the Privacy Officer. Employees or other relevant parties that contravene or do not comply with ECG Pte Ltd ‘s Privacy Policy may be subject to disciplinary action.
If an individual has a privacy complaint, he or she is required to send it in writing to the Privacy Officer. TradingInsider has an effective incidents/complaints handling process in place to manage privacy risks and issues. The incidents/complaints handling process involves:
We must ensure that all contractual arrangements with third parties adequately address privacy issues.
Each third party is aware of this Privacy Policy, and has informed us that they have implemented policies in relation to the management of personal information in accordance with the Privacy Act, including:
The third parties specifically agree only to use personal information for the purposes consented to by TradingInsider or by the individual concerned.
TradingInsider’s websites (www.tradinginsider.com) contain links to other websites whose operator may or may not adhere to a privacy policy or be governed by the SPPs. Asiaforexmentor has no control over the privacy practices of sites that are linked to its sites via hyperlinks or banner advertising. Please take care at all times to check whose site you are visiting.
When an individual accesses our websites, our websites uses cookies which allow us to identify the individual’s browser. Cookies do not identify the individual – they simply allow us to track usage patterns so that we can measure the level of interest in various areas of its site. All browsers allow individuals to be notified when they receive a cookie and elect whether to accept it.
We may also use third parties to analyse traffic at our web sites, which may involve the use of cookies. Information collected through such analysis is anonymous. Our websites’ privacy policy can be accessed by clicking on the privacy link located on the homepage of each of our websites.
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