Privacy Policy

PRIVACY POLICY

 

Six Capital Wealth Pte Ltd (the “Company”); and Six Capital Pte Ltd, Six Capital FX Trading Pte Ltd, Biopay Pte Ltd, Ricebowl Technologies and Six Capital Investment Holdings Ltd (the “Affiliates”) are related companies (“ Six Capital Group” or as appropriate in the context, “we”; “us”; or “our”). Six Capital Group is also the author and publisher of the internet resource www.sixcapital.com,www.tradewithchief.com, www.biopay.sg, www.playtagg.com and www.playtagg.com/academy (subject to other additions) (each, a “Website”; together, the “Websites”) on the world wide web as well as the following: (i) software and applications provided by Six Capital Group, including but not limited to the mobile application ‘TAGG 2.0’, and the software and applications of the brand names ‘TAGG Academy’, ‘TAGG 1.0’, ‘TAGG 2.0’, ‘TAGG’, ‘RicebowlTM’, and ‘TAGG Account’; and (ii) the online Forex Foundation Course and Trainee Dealer Programme (together with the Websites, referred to as the “Services”).

Six Capital Group respect the protection of the Personal Data of individuals and value the relationship we have with you. This Personal Data Policy (“ Privacy Policy”) is applicable to any data processing implemented by the Company, any Six Capital Group company and any Six Capital websites.

This Privacy Policy describes the types of Personal Data we may collect from you, how we may use that information, and with whom we may share it. Our Privacy Policy also describes the measures we take to protect the security of the information you provide to us, including without limitation through this Website. We also tell you how you can reach us to update your Personal Data, ask questions you may have about our personal data protection practices and provide feedback on our personal data protection practices.

BY SUBMITTING YOUR INFORMATION, SIGNING UP ON THE WEBSITES AND/OR OTHER CONFIRMATION, YOU ARE CONFIRMING THAT YOU ARE BOUND BY THIS PRIVACY POLICY. BY USING THE SERVICES OR BY OTHERWISE GIVING US YOUR INFORMATION, YOU WILL BE DEEMED TO HAVE READ, UNDERSTOOD AND AGREED TO THE PRACTICES AND POLICIES OUTLINED IN THIS PRIVACY POLICY AND YOU HEREBY CONSENT TO OUR COLLECTION, USE AND DISCLOSURE OF YOUR INFORMATION AS DESCRIBED IN THIS PRIVACY POLICY. WE RESERVE THE RIGHT TO CHANGE, MODIFY, ADD OR DELETE PORTIONS OF THE TERMS OF THIS PRIVACY POLICY, AT OUR SOLE DISCRETION, AT ANY TIME. IF YOU DO NOT AGREE WITH THIS PRIVACY POLICY AT ANY TIME, DO NOT USE ANY OF THE SERVICES OR GIVE US ANY OF YOUR INFORMATION. IF YOU USE THE SERVICES ON BEHALF OF SOMEONE ELSE (SUCH AS YOUR CHILD) OR AN ENTITY (SUCH AS YOUR EMPLOYER), YOU REPRESENT THAT YOU ARE AUTHORISED BY SUCH INDIVIDUAL OR ENTITY TO (I) ACCEPT THIS PRIVACY POLICY ON SUCH INDIVIDUAL’S OR ENTITY’S BEHALF, AND (II) CONSENT ON BEHALF OF SUCH INDIVIDUAL OR ENTITY TO OUR COLLECTION, USE AND DISCLOSURE OF SUCH INDIVIDUAL’S OR ENTITY’S INFORMATION AS DESCRIBED IN THIS PRIVACY POLICY.

 

SECTION 1: WHY THIS PRIVACY POLICY

 

This Privacy Policy is published in compliance with the Personal Data Protection Act (2012) of Singapore (the “PDPA”).

The objectives of this Policy are to:

• Provide a set of privacy and personal data protection standards that govern our procedures and protect the privacy of your personal data.

• Demonstrate our on-going commitment to protecting your privacy and addressing any privacy concerns that you might have.

• Describe the ways in which we collect, use, disclose and retain your personal data.

• Ensure that we comply with the PDPA.

• Facilitate our compliance with any further developments in the protection of personal data.

 

SECTION 2: TYPE OF PERSONAL DATA

 

Generally, some of the Services require us to know who you are so that we can best meet your needs. When you sign-up on the Website, access the Services, complete a transaction, verify your credit card, place an order, or through any interaction with us via employment contracts, application or registration forms, emails, telephone calls, short messaging services (“SMS”), texts or other correspondence, we may ask you to voluntarily provide us with certain information that personally identifies you or could be used to personally identify you.

Without prejudice to the generality of the above, information collected by us from you may include (but is not limited to) the following:

(a) contact data (name, NRIC, passport or other identification number, telephone number(s), mailing address, email address, personal interests, and any other information provided us in any forms you may have submitted to us, interaction with Six Capital and its agents/employees, or through signing up on our Websites);

(b) other information that you voluntarily choose to provide to us (such as information shared by you with us through emails);

(c) financial information such as bank accounts, credit and debit card details or other payment instrument details;

(d) information received by body corporate under lawful contract or otherwise;

(e) employment record; employment history; education background or income levels;

(f) your use of our Services, including data of trading history, volume, patterns, predictions, trends;

(g) email and telephone call data records;

(h) photographs, video and CCTV footage;

(i) your use of Websites and Services, including cookies, IP address, policy and usage history information; and

(j) your usage of and interaction with our website and/or services including computer and connection information, device capability, bandwidth, statistics on page views, and traffic to and from our website

The information collected from you by Six Capital Group may constitute Personal Data under the PDPA.

“Personal Data” is defined under the PDPA to mean any data, whether true or not, about an individual who can be identified from that data or from that data and other information to which an organisation has or is likely to have access. This would include, without limitation, information such as name, address, telephone number, e-mail address, credit card details and any other personal information.

Six Capital Group will be free to use, collect and disclose information that is freely available in the public domain without your consent.

Information that is business contact information such as your name, position name or title, business telephone number, business address, business electronic mail address or business fax number and any other similar information about you, which are not provided by you for personal purposes, will not be regarded as Personal Data under the PDPA. Your consent to us collecting, using and disclosing any business contact information will not be required.

 

SECTION 3: COLLECTION OF PERSONAL DATA

 

Personal Data may be collected by us through processes including, but not limited to the following:

(a) when a user signs-up or registers on our Websites with us for an account;

(b) when you access our Website or perform an online transaction;

(c) when you interact with any of our employees (including our wealth managers, customer service officers);

(d) when customer submits an application to us to purchase our products or use our Services;

(e) when a customer asks to be included in an email or other mailing list;

(f) when an individual requests that we contact him/her;

(g) when an individual responds to our marketing initiatives, events, seminars, promotions or surveys;

(h) when an individual submits his/her application form for our Forex Foundation Course; Trainee Dealer Programmes and seminars; and

(i) when an individual applies for employment in Six Capital Group.

Information that you submit via any of our websites shall be deemed to be collected by us with your permission. Such information may include but is not limited to your name, contact and fax numbers, home, work and email addresses, credit card details, including the three-digit code that appears on the back of your credit card, date of birth, gender and lifestyle information and other information necessary to the provision of Services.

 

SECTION 4: CONSENT TO COLLECTION OF PERSONAL DATA

 

Six Capital Group shall not collect, use or disclose your personal data unless:

(a) you give, or are deemed to give, consent to the collection, use or disclosure of your personal data; or

(b) the collection, use or disclosure of your personal data without your consent is required or authorised under the PDPA or other written law.

Six Capital Group shall not, as a condition of providing a product or service to you, require you to consent to the collection, use or disclosure of your personal data beyond what is reasonable to provide the product or Service to you.

Six Capital Group shall not obtain or attempt to obtain your consent for collecting, using or disclosing personal data by providing false or misleading information with respect to the collection, use or disclosure of your personal data, or use deceptive or misleading practices.

As part of our continuous effort to keep you informed on our new product and services, we may mail, email, telephone and contact you by any other means. Information sent to you may also include upcoming special events, seminars or other relevant information that may be of interest to you.

You may also receive mailings or other communications materials from our strategic marketing partners and/or carefully selected third parties. You will always have the option to decline any or all of these communications by following the directions included in our emails or other communications, or by contacting the Data Protection Officer of Six Capital Group directly (see Section 18 below).

Six Capital Group may collect and use personally identifiable information that you volunteer, or other behavioural data and big data generated. In addition to that, permission will be deemed given for communication from us that are necessary to fulfil transactions and services requested by you.

Photographs, videos and CCTV footage may constitute personal data if an identifiable individual is captured. Six Capital will either seek your written consent for the collection, use and disclosure of photographs, videos and/or CCTV footage of you, or state in the invitation to you of an event/seminar, that photographs/videos/CCTV footage will be taken at the event/seminar for publicity on Six Capital’s print and electronic media. Appropriate and obvious notices shall also be put up at the reception or entrance of our event/seminar to inform attendees on the event/seminar day.

 

SECTION 5: PURPOSES FOR WHICH WE COLLECT AND USE PERSONAL DATA

 

Six Capital Group may collect, use or disclose your personal data only for purposes:

(a) that a reasonable person would consider appropriate in the circumstances; and

(b) where you have been informed in accordance with this Section 5 of this Privacy Policy, to the extent applicable.

Six Capital Group collects and uses the Personal Data that you provide to us depending on your relationship with us (e.g. as an applicant, student, trainee dealer, trader, wealth manager, TAGGer, service provider, or other person relating to Six Capital Group).

In General

In general, Six Capital Group may collect, use and/or disclose your Personal Data for the following purposes:

(a) maintaining records of Six Capital Group’s interactions with you, through telephone recordings, documentation (hard copy and electronic), and

(b) internal reporting and analysis related to Six Capital Group’s business operations;

(c) responding to your queries and requests and handling complaints;

(d) updating you on developments in our services and special happenings;

(e) managing commercial and financial risks, including preventing, detecting and investigating crime, including fraud and any form of financial crime;

(f) assessing and processing any applications, requests and instructions for products and services offered by Six Capital Group;

(g) analysing your financial situation and determining financial strategies and products suitable for you as our client;

(h) evaluating your standing, resources and capabilities to enter or maintain a relationship with you as a client, employee, business partner or other;

(i) establishment and maintenance of relationship with Six Capital Group and/or within Six Capital Group’s related companies;

(j) marketing and promotion activities of Six Capital Group;

(k) taking of photographs and/or videos (whether by our staff or third party photographers and/or videographers) during events or seminars organised by Six Capital Group or its affiliates for publicity purposes;

(l) if consented to in the registration form and/or other methods of consent notification, providing marketing, advertising and promotional information via postal mail, electronic mail, SMS or MMS, fax and/or voice calls;

(m) any other purposes which Six Capital Group may inform you of in writing from time to time, but for which Six Capital Group will seek your separate consent; and

(n) any other purposes related to the above purposes.

If you are an employee

If you are an employee, Six Capital may collect, use and/or disclose his/her Personal Data for the following purposes:

(a) recruitment;

(b) administration of benefits entitlement (such as medical, leave entitlement, pension and other benefits);

(c) salary administration and payment of expenses;

(d) employee surveys;

(e) pre-employment screening;

(f) training course management;

(g) contacting employee’s nominee in connection with emergencies;

(h) photographs and other indications of employee’s likeness for identification cards, management reports, internal documents and company collaterals;

(i) monitoring registrations with any regulatory bodies to ensure any compliance, training, examination and other requirements are met;

(j) absence, leave and sickness monitoring;

(k) assessing medical suitability for particular jobs or task;

(l) handling and administration of employee claims;

(m) payroll processing;

(n) administration of international assignments;

(o) career planning, performance appraisals, job moves, promotions, skills monitoring, and staff restructuring;

(p) disciplinary, capability, grievance and code of conduct processes and other investigations;

(q) equal opportunities monitoring;

(r) providing references if requested by the employee;

(s) administering bonus payments and other forms of remuneration;

(t) maintenance the security; and/or

(u) general Business operations, including (a) record keeping; (b) compliance with applicable rules, laws, regulations, code of practice or guidelines which are binding on Six Capital Group; and/or (c) any other purposes that is necessary or incidental to the above and business of Six Capital Group.

If you are a trainee dealer or prospective trainee dealer

If you are a trainee dealer, or prospective trainee dealer, Six Capital may collect, use and/or disclose your Personal Data for the following purposes:

(a) evaluating suitability for admission or employment as a trader, enrolling or employing, providing educational courses and training, including sending materials on course / study / assignment / lecture materials, information on time tables and examination details via postal mail, electronic mail, SMS or MMS, fax and/or voice calls; and

(b) processing application(s) for scholarships and/or financial aid, and research support, and administering and managing scholarship/financial aid/grant and other support programmes, which may include use of personal data for development and fund raising activities and disclosure of personal data to donors, grantors, external evaluators and/or external organisations for purposes of periodic reports, event invitations, surveys and/or publicity of Six Capital Group’s related programmes.

If you are a wealth manager or lead of wealth manager

If you are a wealth manager or lead of wealth manager, Six Capital Group may collect, use and/or disclose your Personal Data for the following purposes:

(a) evaluating your performance as our employee or business partner;

(b) carrying out market-related, evaluative or similar research and analysis for Six Capital Group’s operational strategy and business planning purposes and evaluation; and

(c) administering and/or managing relationships with the wealth managers and the leads generated by them (including responding to enquiries, the mailing of marketing correspondence).

If you are a trader

If you are a trader, Six Capital Group may collect, use and/or disclose your Personal Data for the following purposes:

(a) Carrying out trade-related, evaluative or similar research and analysis for Six Capital Group’s operational strategy and business planning purposes.
Marketing Purposes

Where you have specifically provided Six Capital with additional consents, Six Capital Group may also collect, use and/or disclose your Personal Data for the following purposes:

(a) providing you benefit, including without limitation promotions, loyalty and reward programmes and sending you details of products, services, special offers and rewards, either to our customers generally, or which may be of interest to you;

(b) matching your Personal Data with other data collected for other purposes and from other sources (including third parties) in connection with the provision or offering of products and services, whether by any Six Capital Group company, or other third parties;

(c) fulfilling your referral requests;

(d) administering contests and competitions;

(e) developing special offers and marketing programmes.

If you have provided your Singapore telephone number(s) and have indicated that your consent to receiving marketing or promotional information via your Singapore telephone number(s), then from time to time, Six Capital Group may contact you using such Singapore telephone number(s) (including via voice calls, SMS, fax or other means) with information about Six Capital Group’s products and services.

 

SECTION 6: DISCLOSURE OF PERSONAL DATA

 

Six Capital Group will only disclose Personal Data:

(a) for the primary purpose for which it was collected as outlined in Section 5 above;

(b) for purposes that a reasonable person will consider appropriate in the circumstances;

(c) where you have consented; or

(d) where permitted under the PDPA or other applicable law or if required by law.

Subject to applicable laws, Six Capital Group may disclose the Data Subject’s personal data for the purposes set out above to parties such as those described below:

(a) Six Capital Group’s related companies being [Six Capital Pte Ltd, Six Capital FX Trading Pte Ltd, BioPay Pte Ltd, Six Capital Wealth Pte Ltd, Ricebowl Technologies, Six Capital Investments Ltd, Jinguo Six Capital (Shanghai) Ltd and PT Six Capital and any of their affiliates, associated entities and any of their branches and offices which may also include entities and activities overseas;

(b) banks, financial institutions, credit card companies, payment gateways and their respective service providers;

(c) companies providing services relating to insurance and/or reinsurance to us, and associations of insurance companies;

(d) agents, contractors or third party service providers who provide services to us such as telecommunications, information technology, payment, data processing, storage and archival; and

(e) our professional advisers such as our auditors and lawyers.

In addition, Six Capital Group would disclose Personal Data in the following circumstances:

(a) in response to a request from law enforcement authorities or other government officials;

(b) to comply with a court order or direction from a government agency or regulatory authority ordering the disclosure of the Personal Data; and

(c) where the disclosure is necessary for investigations or legal proceedings.

 

SECTION 7: ADDITIONAL PRIVACY STATEMENTS FOR WEBSITE AND SERVICE USERS

 

7.1 Persons who have visited and signed up on our Websites (“Users”) Note:

This section applies to all Users.

i. As part of the signing-up process that is available to Users on this Website, certain information, including Personal Data or sensitive personal information is collected from the Users.

ii. All the statements in this Privacy Policy apply to all Users, and all Users are therefore required to read and understand the privacy statements set out herein prior to submitting any Personal Data or sensitive personal information to Six Capital Group, failing which they are required to leave the Website immediately.

iii. If you have inadvertently submitted any such information to Six Capital Group prior to reading the privacy statements set out herein, and you do not agree with the manner in which such information is collected, processed, stored, used or disclosed, then you may access, modify and delete such information by using options provided on the Website. In addition, you can, by sending an email to dataprivacy@sixcapital.sg, inquire whether Six Capital Group is in possession of your Personal Data, and you may also require Six Capital Group to delete and destroy all such information.

iv. Users’ personally identifiable information, which they choose to provide on the Website when they sign up, is used to help the Users describe/identify themselves; request for more information from Six Capital Group; register an Account if User so decides; and if User consents, for Six Capital Group to inform User about portal content updates, any of Six Capital Group’s new products and other updates. Other information that does not personally identify the Users as an individual, is collected by Six Capital Group from Users (such as, your computer’s internet protocol (IP) address which provides us with information that helps us learn about your browser and operating system) and is exclusively owned by Six Capital Group. Six Capital Group may also use such information in an aggregated or non-personally identifiable form for research, statistical analysis and business intelligence purposes, and may sell or otherwise transfer such research, statistical or intelligence data in an aggregated or non-personally identifiable form to third parties and affiliates. In particular, Six Capital Group reserves with it the right to use anonymized User demographics information for the following purposes:

(a) Analyzing software usage patterns for improving product design and utility.

(b) Analyzing such information for research and development of new technologies.

(c) Using analysis of such information in other commercial product offerings of Six Capital Group.

(d) Sharing analysis of such information with third parties for commercial use.

v. The Website uses temporary cookies to store certain data (that is not sensitive personal data or information) that is used by Six Capital Group and its service providers for the technical administration of the Website, research and development, and for User administration. In the course of serving advertisements or optimizing services to Users, Six Capital Group may allow authorized third parties to place or recognize a unique cookie on the User’s browser. The cookies however, do not store any Personal Data of the User. You may adjust your internet browser to disable cookies. If cookies are disabled you may still use the Website, but may be limited in the use of some of the features.

vi. Six Capital Group will communicate with the Users through email, telephone and notices posted on the Website or through other means available through the service, including SMSs, text and other forms of messaging]. The Users can change their e-mail and contact preferences at any time by sending an email to dataprivacy@sixcapital.sg.

vii. At times, Six Capital Group conducts a User survey to collect information about Users’ preferences. These surveys are optional and if Users choose to respond, their responses will be kept anonymous. The demographic information that Six Capital Group collects in the registration process and through surveys is used to help Six Capital Group improve its Services to meet the needs and preferences of Users. This may include targeting advertising through marketing newsletters to Users about our Services.

viii. Six Capital Group may keep records of electronic communications and telephone calls received and made for making appointments or other purposes for the purpose of administration of Services, customer support, research and development.

ix. All Six Capital Group employees and data processors, who have access to, and are associated with the processing of sensitive personal data or information, are obliged to respect the confidentiality of every Users’ Personal Data or sensitive personal information.

ix. To the extent necessary to provide Users with the Services, Six Capital Group may provide their Personal Data to third party contractors who work on behalf of or with Six Capital Group to provide Users with such Services, to help Six Capital Group communicate with Users or to maintain the Website. Generally, these contractors do not have any independent right to share this information, however certain contractors who provide services on the Website, including the providers of online communications services, may use and disclose the personal information collected in connection with the provision of these Services in accordance with their own privacy policies. In such circumstances, you consent to us disclosing your personal information to contractors, solely for the intended purposes only.

x. Users may choose to unsubscribe from marketing communications that they receive from Six Capital Group by clicking the ‘unsubscribe’ link provided at the end of every such promotional communication.

7.2 Persons who register and have accounts to use the Services, including TAGGers, traders (“Subscribers”) Note:

This section applies to all Subscribers.

i. Accordingly, a condition of each Subscriber’s use of and access to the Services is their acceptance of the terms of this Privacy Policy. Any Subscriber that does not agree with any provisions of the same has the option to discontinue the Services provided by Six Capital Group immediately.

ii. All the information provided to Six Capital Group by a Subscriber, including Personal Data or any sensitive personal information, is voluntary. You understand that Six Capital Group may use certain information of yours, which has been designated as Personal Data under the PDPA, (a) for the purpose of providing you the Services, (b) for commercial purposes and in an aggregated or non-personally identifiable form for research, statistical analysis and business intelligence purposes, (c) for sale or transfer of such research, statistical or intelligence data in an aggregated or non-personally identifiable form to third parties and affiliates. Six Capital Group also reserves the right to use information provided by or about the Subscriber for the following purposes:

(a) Publishing such information on the Website.

(b) Contacting Subscribers for offering new products or services

(c) Contacting Subscribers for taking product and Service feedback.

(d) Analyzing software usage patterns, trends, history, big data for our business operations, improving product design and utility.

(e) Analyzing anonymized practice information for our commercial use.

If you have voluntarily provided your Personal Data to Six Capital Group for any of the purposes stated above, you hereby consent to such collection and use of such information by Six Capital Group.

iv. Collection, use and disclosure of information which has been designated as Personal Data under the PDPA requires your express consent. By affirming your assent to this Privacy Policy, you provide your consent to such use, collection and disclosure as required under applicable law. Our Services may be unavailable to you in the event such consent through an email is not given.

v. Six Capital Group does not control or endorse the content, messages or information found in any Services and, therefore, Six Capital Group specifically disclaims any liability with regard to the Services and any actions resulting from your participation in any Services, and you agree that you waive any claims against Six Capital Group relating to same, and to the extent such waiver may be ineffective, you agree to release any claims against Six Capital Group relating to the same.

vi. You are responsible for maintaining the accuracy of the information you submit to us, such as your contact information provided as part of account registration. If your personal information changes, you may correct, delete inaccuracies, or amend information by making the change on our member information page or by contacting us through dataprivacy@sixcapital.sg. We will make good faith efforts to make requested changes in our then active databases as soon as reasonably practicable. If you provide any information that is untrue, inaccurate, out of date or incomplete (or becomes untrue, inaccurate, out of date or incomplete), or Six Capital Group has reasonable grounds to suspect that the information provided by you is untrue, inaccurate, out of date or incomplete, Six Capital Group may, at its sole discretion, discontinue the provision of the Services to you. There may be circumstances where Six Capital Group will not correct, delete or update your Personal Data, including (a) where the Personal Data is opinion data that is kept solely for evaluative purpose; and (b) the Personal Data is in documents related to a prosecution if all proceedings relating to the prosecution have not been completed.

vii. You may choose to unsubscribe from marketing communications that you receive from Six Capital Group by clicking the ‘unsubscribe’ link provided at the end of every such promotional communication.

viii. If you wish to cancel your account or request that we no longer use your information to provide you Services, contact us through dataprivacy@sixcapital.sg. We will retain your information for as long as your account with the Services is active and as needed to provide you the Services. We shall not retain such information for longer than is required for the purposes for which the information may lawfully be used or is otherwise required under any other law for the time being in force. After a period of time, your data may be anonymized and aggregated, and then may be held by us as long as necessary for us to provide our Services effectively, but our use of the anonymized data will be solely for analytic purposes. Please note that your withdrawal of consent, or cancellation of account may result in Six Capital Group being unable to provide you with its Services or to terminate any existing relationship Six Capital Group may have with you.

ix. If you wish to opt-out of receiving non-essential communications such as promotional and marketing-related information regarding the Services, please send us an email at dataprivacy@sixcapital.sg.

x. Six Capital Group may require the Subscriber to pay with a credit card, wire transfer, debit card or cheque for Services for which subscription amount(s) is/are payable. Six Capital Group will collect such Subscriber’s credit card number and/or other financial institution information such as bank account numbers and will use that information for the billing and payment processes, including but not limited to the use and disclosure of such credit card number and information to third parties as necessary to complete such billing operation. Verification of credit information, however, is accomplished solely by the Subscriber through the authentication process. Subscriber’s credit-card/debit card details are transacted upon secure sites of approved payment gateways which are digitally under encryption, thereby providing the highest possible degree of care as per current technology. However, Six Capital Group provides you an option not to save your payment details. Subscriber is advised, however, that internet technology is not full proof safe and Subscriber should exercise discretion on using the same.

xi. Due to the communications standards on the Internet, when a User or a Subscriber or anyone who visits the Website, Six Capital Group automatically receives the URL of the site from which anyone visits. Six Capital Group also receives the Internet Protocol (IP) address of each User’s computer (or the proxy server a User used to access the World Wide Web), Subscriber’s computer operating system and type of web browser the Subscriber is using, email patterns, as well as the name of Subscriber’s ISP. This information is used to analyse overall trends to help Six Capital Group improve its Service. The linkage between Subscriber’s IP address and Subscriber’s personally identifiable information is not disclosed to third parties. Notwithstanding the above, Six Capital Group may disclose some of the aggregate findings (not the specific data) in anonymized form (i.e., non-personally identifiable) with advertisers, sponsors, investors, strategic partners, and others in order to help grow its business.

xii. The Website uses temporary cookies to store certain data (that is not sensitive personal data or information) that is used by Six Capital Group and its service providers for the technical administration of the Website, research and development, and for Subscriber administration. In the course of serving advertisements or optimizing services to its Subscribers, Six Capital Group may allow authorized third parties to place or recognize a unique cookie on the Subscriber’s browser. The cookies however, do not store any Personal Data of the Subscriber. You may adjust your internet browser to disable cookies. If cookies are disabled you may still use the Website, but may be limited in the use of some of the features.

xiii A Subscriber may have limited access to the Website without creating an account on the Website. In order to have access to all the features and benefits on our Website, a Subscriber must first create an account on our Website. To create an account, a Subscriber is required to provide the following information, which such Subscriber recognizes and expressly acknowledges is Personal Data allowing others, including Six Capital Group, to identify the User: name, Subscriber ID, email address, country, ZIP/postal code, age, telephone number, password chosen by the Subscriber and valid financial account information. Other information requested on the registration page, including the ability to receive marketing communications from Six Capital Group, is optional. Six Capital Group may, in future, include other optional requests for information from the Subscriber to help Six Capital Group to customize the Website to deliver personalized information to the Subscriber.

xiv. This Privacy Policy applies to Services that are owned and operated by Six Capital Group. Six Capital Group does not exercise control over the sites displayed as search results or links from within its Services. These other sites may place their own cookies or other files on the Subscriber’s computer, collect data or solicit personal information from the Subscriber, for which Six Capital Group is not responsible or liable. Accordingly, Six Capital Group does not make any representations concerning the privacy practices or policies of such third parties or terms of use of such websites, nor does Six Capital Group guarantee the accuracy, integrity, or quality of the information, data, text, software, sound, photographs, graphics, videos, messages or other materials available on such websites. The inclusion or exclusion does not imply any endorsement by Six Capital Group of the website, the website’s provider, or the information on the website. If you decide to visit a third party website linked to the Website, you do this entirely at your own risk. Six Capital Group encourages the Subscriber to read the privacy policies of that website.

xv. The Website may enable a Subscriber to communicate with other Subscribers or to post information to be accessed by others, whereupon other Subscribers may collect such data. Such Subscribers, including any moderators or administrators, are not authorized Six Capital Group representatives or agents, and their opinions or statements do not necessarily reflect those of Six Capital Group, and they are not authorized to bind Six Capital Group to any contract. Six Capital Group hereby expressly disclaims any liability for any reliance or misuse of such information that is made available by Subscribers or visitors in such a manner.

xvi. Six Capital Group does not collect information about the visitors of the Website from other sources, such as public records or bodies, or private organisations, save and except for the purposes of registration of the Subscribers (the collection, use, storage and disclosure of which each User must agree to in order for Six Capital Group to effectively render the Services).

xvii. Six Capital Group maintains a strict “No-Spam” policy, which means that Six Capital Group does not intend to sell, rent or otherwise give your e-mail address to a third party without your consent.

xviii. Six Capital Group has implemented best international market practices and security policies, rules and technical measures to protect the Personal Data that it has under its control from unauthorised access, improper use or disclosure, unauthorised modification and unlawful destruction or accidental loss. However, for any data loss or theft due to unauthorized access to the Subscriber’s electronic devices through which the Subscriber avails the Services, Six Capital Group shall not be held liable for any loss whatsoever incurred by the Subscriber.

xix. Six Capital Group implements reasonable security practices and procedures and has a comprehensive documented information security programme and information security policies that contain managerial, technical, operational and physical security control measures that are commensurate with respect to the information being collected and the nature of Six Capital Group’s business. The reasonable security practices and procedures implemented by Six Capital Group include, but not limited to: ensuring that any Personal Data is protected by password.

xx. Six Capital Group takes your right to privacy very seriously and other than as specifically stated in this Privacy Policy, will only disclose your Personal Data in the event it is required to do so by law, rule, regulation, law enforcement agency, governmental official, legal authority or similar requirements or when Six Capital Group, in its sole discretion, deems it necessary in order to protect its rights or the rights of others, to prevent harm to persons or property, to fight fraud and credit risk, or to enforce or apply the terms under this Privacy Policy.

xxi. Six Capital Group takes all reasonable steps to ensure that all unsolicited information is destroyed immediately.

7.3 Casual Visitors Note:

i. No sensitive personal data or information is automatically collected by Six Capital Group from any casual visitors of this website, who are merely perusing the Website.

ii. Nevertheless, certain provisions of this Privacy Policy are applicable to even such casual visitors, and such casual visitors are also required to read and understand the privacy statements set out herein, failing which they are required to leave this Website immediately.

iii. If you, as a casual visitor, have inadvertently browsed any other page of this Website prior to reading the privacy statements set out herein, and you do not agree with the manner in which such information is collected, processed, stored, used, disclosed or retained, merely quitting this browser application should ordinarily clear all temporary cookies installed by Six Capital Group. All visitors, however, are encouraged to use the “clear cookies” functionality of their browsers to ensure such clearing / deletion, as Six Capital Group cannot guarantee, predict or provide for the behaviour of the equipment of all the visitors of the Website.

iv. You are not a casual visitor if you have willingly submitted any Personal Data or personal information to Six Capital Group through any means, including email, post or through the registration process on the Website. All such visitors will be deemed to be, and will be treated as, Users for the purposes of this Privacy Policy, and in which case, all the statements in this Privacy Policy apply to such persons.

 

SECTION 8: SHARING AND TRANSFER OF PERSONAL DATA

 

In general, the third-party providers used by us, such as data intermediaries and aggregators, will only collect, use and disclose your information to the extent necessary to allow them to perform the services they provide to us.

In the course of or in connection Six Capital Group’s business operations, which includes, providing products and services to customers, Six Capital Group may transfer Personal Data to the following parties for the following purposes:

(a) to our vendor data aggregators for the collection and storing of Personal Data from Data Subjects;

(b) to our data intermediaries for the processing of Personal Data, including financial data from users of our Websites, trade data from our traders, TAGGers and purchase history;

(c) To government and non-government authorities, agencies and/or regulators as required under law or under directions or orders from the government and non-government authorities, agencies and/or regulators for security, regulatory approvals or permits;

(d) To event organisers and service providers to facilitate the planning of seminars/ publicity events / functions that Six Capital organises or is involved in;

(e) Financial institutions or payment gateways for purposes of payment processing and transactions related to Six Capital’s provision of products and services, such as nodes for TAGGers;

(f) [Other service providers who provide IT and outsourcing services such as electronic mail services, deployment of management operations for information technology and HR outsourcing services]; and

(g) Professional, financial and legal advisors, tax advisors, auditors, insurers and insurance brokers.

However, certain third-party service providers, such as payment gateways and other payment transaction processors, have their own privacy policies in respect to the information we are required to provide to them for your purchase-related transactions.

For these providers, we recommend that you read their privacy policies so you can understand the manner in which your personal information will be handled by these providers.

In particular, remember that certain providers may be located in or have facilities that are located a different jurisdiction than either you or us. So if you elect to proceed with a transaction that involves the services of a third-party service provider, then your information may become subject to the laws of the jurisdiction(s) in which that service provider or its facilities are located.

As an example, if you are located in Canada and your transaction is processed by a payment gateway located in the United States, then your personal information used in completing that transaction may be subject to disclosure under United States legislation, including the Patriot Act.

Once you leave our Website(s) or are redirected to a third-party website or application, you are no longer governed by this Privacy Policy or our website’s Terms of Service.

Six Capital Group requires that the parties to whom we transfer Personal Data and our service providers implement adequate levels of protection in order to protect Personal Data. We also require that these parties only process Personal Data strictly for purposes for which we engage them for and consistent with the purposes that we have described in the Section 5 “Purposes for which we collect and use Personal Data” or with other purposes for which consent has been sought and obtained.

 

SECTION 9: CONFIDENTIALITY AND SECURITY

 

Your Personal Data is maintained by Six Capital Group in electronic form on its equipment, and on the equipment of its employees. Such information may also be converted to physical form from time to time. Six Capital Group takes all necessary precautions to protect your personal information both online and off-line, and implements reasonable security practices, precautions and follow industry best practices to make sure it is not inappropriately lost, misused, accessed, disclosed, altered or destroyed, including certain managerial, technical, operational and physical security control measures that are commensurate with respect to the information being collected and the nature of Six Capital Group’s business.

No administrator at Six Capital Group will have knowledge of your password. It is important for you to protect against unauthorized access to your password, your computer and your mobile phone. Be sure to log off from the Website when finished. Six Capital Group does not undertake any liability for any unauthorised use of your account and password. If you suspect any unauthorized use of your account, you must immediately notify Six Capital Group by sending an email to dataprivacy@sixcapital.sg. You shall be liable to indemnify Six Capital Group due to any loss suffered by it due to such unauthorized use of your account and password.

Six Capital Group makes all Personal Data accessible to its employees, agents or partners and third parties only on a need-to-know basis, and binds only its employees to strict confidentiality obligations.

Notwithstanding the above, Six Capital Group is not responsible for the confidentiality, security or distribution of your personal information by our partners and third parties outside the scope of our agreement with such partners and third parties. Further, Six Capital Group shall not be responsible for any breach of security or for any actions of any third parties or events that are beyond the reasonable control of Six Capital Group including but not limited to, acts of government, computer hacking, unauthorised access to computer data and storage device, computer crashes, breach of security and encryption, poor quality of Internet service or telephone service of the User and/or Subscriber etc.

 

SECTION 10: AGE OF CONSENT

 

By using the Websites, you represent that you are at least the age of majority in your state or province of residence, or that you are the age of majority in your state or province of residence and you have given us your consent to allow any of your minor dependents to use this site.

Six Capital Group strongly encourages parents and guardians to supervise the online activities of their minor children and consider using parental control tools available from online services and software manufacturers to help provide a child-friendly online environment. These tools also can prevent minors from disclosing their name, address, and other personally identifiable information online without parental permission. Although the Six Capital Group Websites and Services are not intended for use by minors, Six Capital Group respects the privacy of minors who may inadvertently use the internet or the mobile application.

 

SECTION 11: ACCURACY

 

Six Capital Group will take reasonable efforts to ensure that any Personal Data collected is accurate and up to date by updating its records whenever changes to information come to its attention. Six Capital Group will disregard information which seems, on a reasonable basis, to be inaccurate or out of date by reason of the time which has elapsed since it was collected or by reason of any other information in its possession.

 

SECTION 12: RETENTION OF PERSONAL DATA

 

Six Capital Group only retains Personal Data for as long as the retention is required for the purposes for which we collected the Personal Data, the purposes described in this Policy and for our business and legal purposes. Generally, we do not retain Personal Data for a period of longer than [6] years after the original purposes for which the Personal Data was collected have ceased to be applicable, unless otherwise required by law or other mandatory directions by court or government authorities or for purposes of legal proceedings or other similar proceedings or investigations.

For job applicants who were interviewed by the Company but were unsuccessful, Six Capital Group will retain your Personal Data for no longer than [1] year for the purposes of evaluating your suitability for future job openings within Six Capital Group, unless you inform us otherwise.

 

SECTION 13: ACCESS, CORRECTION OR UPDATE OF PERSONAL DATA

 

If you have any questions about the use of your Personal Data (including how your Personal Data has been used and to whom it has been disclosed), or if you wish to correct, delete or update any of your Personal Data held by Six Capital Group, you may submit a written request via email to dataprivacy@sixcapital.sg and request for our Request for Access of Personal Data form or Request for Update/Correction of Personal Data form.

We will endeavour to acknowledge the receipt of your request within 3 working days after the date of receipt of your request if it is sent by e- mail, or within 7 days after the date of receipt of your request if it is sent by post. As it is important to us that the Personal Data that we have about you is accurate and complete, it may be necessary for us to request for supporting documentation from you. We will contact you if we require supporting documentation from you.

There may be circumstances where Six Capital Group will not correct, delete or update your Personal Data, including: (a) where the Personal Data is opinion data that is kept solely for evaluative purpose; and (b) the Personal Data is in documents related to a prosecution if all proceedings relating to the prosecution have not been completed.

Six Capital Group shall have the right to request for information for the purposes of verification of your identity and for more information about your request. As allowed under the PDPA, Six Capital Group reserves a right to charge an administrative fee to respond to the request set out above.

 

SECTION 14: TRANSFER OF PERSONAL DATA OUTSIDE OF SINGAPORE

 

Certain Six Capital Group’s agents, vendors, or service providers may be operating outside Singapore. By providing information to us through our application forms, employment, use of our Websites or otherwise, you are consenting to the transfer of that information to be processed and used in accordance with the terms of this Privacy Policy. In such a situation, Six Capital Group will ensure that the Personal Data so transferred will be accorded a standard of protection comparable to the protection provided under the PDPA.

 

SECTION 15: YOUR REQUESTS AND FEEDBACK ON YOUR PERSONAL DATA WITH US

 

You may request for information from Six Capital Group on what Personal Data of yours we have and how we have used and shared your Personal Data during the last one year before the date of your request.

To learn more about how you can request for information from Six Capital Group, please see our Request for Access of Personal Data form.

You may also choose to withdraw your consent to Six Capital Group’s use, collection, sharing or processing of your Personal Data at any time. To learn more about how you can withdraw your consent, please see our Request for Withdrawal of Personal Data form. Please understand that your withdrawal of your consent to our use of your Personal Data may affect our provision of products and services to you or our business dealings with you, depending on the nature of your relationship with us.

If you have any concerns, feedback or complaints about the use and/or sharing of your Personal Data, you may contact us at dataprivacy@sixcapital.sg.

 

SECTION 16: DO NOT CALL PROVISIONS

 

Six Capital Group shall not, and shall ensure that its agents shall not, send a specified message to a Singapore telephone number without first checking with the Do Not Call Registry established by the Personal Data Protection Commission (“PDPC”) and receiving confirmation from the PDPC that such Singapore telephone number is not listed on the Do Not Call Register.

Six Capital Group shall not, and shall ensure that its agents shall not, send a specified message to a Singapore telephone number, unless the specified message includes clear and accurate information identifying the person sending the specified message and/or the specific Six Capital Group company, and such person’s and/or such Six Capital Group company’s contact information.

The prescribed duration within which Six Capital Group must check with the Do Not Call Registry before sending a specified message to a Singapore telephone number will be 30 days. You may continue to receive marketing messages and other product information from Six Capital Group within the prescribed validity period.

Six Capital Group shall not make, cause or authorise a voice call addressed to a Singapore telephone number that conceals or withholds, or that has the effect of concealing or withholding, the calling line identity from the recipient.

Six Capital Group will not require a subscriber or users of a Singapore telephone number to consent to the sending of a specified message beyond what is reasonable for Six Capital Group to provide its products, courses and services. Six Capital Group will not obtain or attempt to obtain such consent by:

(a) providing false or misleading information; or

(b) using deceptive or misleading practices.

If a subscriber or user of a Singapore telephone number gives notice withdrawing consent for the sending of a specified message to that number, then Six Capital Group shall cease (and cause its agents to cease) sending specified messages to that number.

 

SECTION 17: CHANGES TO THIS PRIVACY POLICY

 

Six Capital Group may update this Privacy Policy at any time, with or without advance notice. In the event there are significant changes in the way Six Capital Group treats your personally identifiable information, or in the Privacy Policy itself, Six Capital Group will display a notice on the Website or send you an email, as provided for above, so that you may review the changed terms prior to continuing to use the Services. As always, if you object to any of the changes to our terms, and you no longer wish to use the Services, you may contact dataprivacy@sixcapital.sg. Unless stated otherwise, Six Capital Group’s current Privacy Policy applies to all information that Six Capital Group has about you and/or your account.

If a User or Subscriber uses the Services; or accesses the Website after a notice of changes has been sent to such User or Subscriber, or published on the Website, such User or Subscriber hereby provides his/her/its consent to the changed terms.

 

SECTION 18: HOW TO CONTACT US

 

Should you have questions about this Privacy Policy or Six Capital Group’s information collection, use and disclosure practices , or if you would like to access, correct, amend or delete any personal information we have about you, register a complaint, or simply want more information contact us at dataprivacy@sixcapital.sg. We will use reasonable efforts to respond promptly to any requests, questions or concerns, which you may have regarding our use of your personal information. If you have any grievance with respect to our use of your information, you may communicate such grievance to:

[Six Capital Wealth Pte Ltd]
2 Shenton Way, #01-01 SGX Centre 1, Singapore 068804

Email: dataprivacy@sixcapital.sg

Effective date: 08 March 2016

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