Privacy and Policy

TREASURY PRIVACY POLICY

A. BACKGROUND

Effective [•]

This Privacy Policy describes how GLOBAL DIGITAL TREASURY PTE LTD (hereinafter referred to as, “Treasury”, “We”, “Us”, or “Our”) may collect, use, process, retain, transfer, disclose and protect your personal information in the course of our business, including our digital services and products such as our websites and mobile applications.

We are a commodity trading platform which includes but is not limited to physical gold trading. We are also the first digital Gold trading platform that has obtained a license from Ministry of Law of Singapore (Singapore’s Precious Stones and Precious Metals Act: PS20220002641. 

We are required to conduct our business in compliance with the Personal Data Protection Act 2012 of Singapore (the “PDPA”).

We are required to ensure that in collecting and using the information provided to us or information about visitors of our Treasury website (as described below), we do so in accordance with the PDPA in Singapore. This Privacy Policy explains our method of collecting, using, processing, retaining, transferring, disclosing and protecting the Personal Information that we have acquired from you. For further information, please contact our Data Protection Officer at: jason@treasury.

B. SCOPE OF PRIVACY POLICY

This Privacy Policy is applicable for the use of every transaction that you make through the Treasury website and mobile application which includes buying, selling, printing and transferring, including when you request information from us or use other services from us, or as a result of your relationship with one or more of our official partners, or as a result of a working relationship with us, or against any information collected by third parties. This Privacy Policy also applies to all of our websites, mobile applications and online services, including the following:

• “Treasury Web”, being websites of Treasury with the address at www.treasury.sg (including the content based on the sub-domain of this website),
• “Treasury App”, being mobile applications of Treasury which you can download or have downloaded from the App Store or Playstore; and
• other online services created or maintained by us from time to time where this Privacy Policy appears.

We may need to obtain certain details from you through our online services if, for example, you intend to transact through the Treasury Web, register to use our mobile application, or join and participate in various programs that we do or will do in the future. Our online services make use of cookies and similar technologies.

C. COLLECTING PERSONAL INFORMATION

General

We generally do not collect personal information directly from you unless it is provided to us voluntarily for identification purposes. 

We may also collect personal information from third parties who have been authorised by you to disclose your personal information to us (your “authorised representative”), after (i) you (or your authorised representative) have been notified of the purposes for which data is collected, and (ii) you (or your authorised representative) have provided written consent to the collection, processing, disclosure and usage of your personal data for those purposes. If we collect information from your authorised representative, we will verify that information based on different sources of information that are legally known in Singapore in accordance with PDPA.

We may also collect your personal information if the collection, processing, disclosure and use of personal information is permitted or required by the PDPA.

We will handle any unwanted information in accordance with the PDPA, including destroying or de-identifying (anonymity) when it is mandatory for us to do so pursuant to the PDPA.

We may collect recent personal information and history which includes but is not limited to your name, your mobile phone number, identification, organisation, employment relationship, position held, IP address, location information, device data (such as IMEI number and the names of the applications that you have installed on your device), and details of our communications and contracts with you. We may also collect personal information about your other relationships with us, including any contact we have with you by telephone, email or online. It is necessary for you to know that any sharing of your personal information with us is carried out by taking into account all the Terms and Conditions of all the features contained in the Treasury App. 

Where it is not necessary for the personal information to be associated with you as an individual before disclosing or sharing such information, we will use reasonable endeavours as permitted or required by the PDPA to remove the means by which the personal information can be associated with you as an individual before disclosing or sharing such information.

Other than as provided for in this Privacy Policy, we may disclose or share your Personal Information if we have obtained your consent for the disclosure or sharing.

Online Service

If you use our Online Services, we may collect information in the following ways:

• Information that you provide by completing forms (this includes information that you provide to us when registering for our online services, subscribing to our services, participating in further programs and services);
• Information that you provide to us if you contact us, for example reporting a problem with our online service or asking a question or feedback; and
• Details of visits made to our services, including but not limited to the amount of network traffic received, connection activity records (logs) (including, where available, IP addresses and locations of devices connected to online and online services as well as information and pointers and identification other technical details about the device and nature of the visit) and from where the data was accessed.

In order to make purchases, sales, storage, printing and various transactions available through our online services, you must provide a number of personal information, which includes but not limited to:

• • Full Name
  • Email Address
  • Mobile Number
  • Bank Account
  • NRIC
  • Selfie with ID Card Photo
  • Complete Address for Shipping

D. ACCURACY OF PERSONAL INFORMATION

We generally rely on personal information provided by you (or your authorised representative). In order to ensure that your personal data is current, complete and accurate, we advise you to provide factual information and to update us if there are changes to your personal information by informing our Data Protection Officer in writing or via email at the contact details provided above. We do not hold any responsibilities or any liabilities for any loss that arises from the incorrect information provided.

E. USE OF PERSONAL INFORMATION

We use and process your personal information to provide and improve our services to you, for example:

• Facilitate the transactions that you make with us through our online services, including for the purposes of payments that you make in connection with the implementation of the gold transaction;
• Manage and carry out our obligations in connection with the legal engagement that exists between you and us through our online services;
• Carry out monitoring activities on transactions that exist or have been carried out by you through our online services; 
• Ensure that content from our online services is presented in the most effective and secure manner for you and your device and settings;
• Regularly provide you with information and services, including those related to transactions that you will or have done, that you have requested from us or which we feel may interest you as permitted by the applicable laws and regulations of the Republic of Singapore, and measure the success and effectiveness of services to improve the services we offer to you and other recipients;
• Maintain and develop our relationship with you;
• For developing, enhancing, and providing services and features in Treasury;
• For research, planning, service development, security or risk management purposes;
• For the maintenance and updating of our records;
• Carry out obligations arising from any agreement made and agreed between you and us in connection with gold transactions; 
• Facilitate the operation of our internal business activities, including meeting the requirements stipulated in the laws and regulations of the Republic of Singapore, and our legal and professional obligations;
• Provide flexibility for you to use or access interactive features or secure areas on our website, if you choose to do so; 
• Managing risk, performing creditworthiness and solvency checks, or assessing, detecting, investigating, preventing and/or remediating fraud or other potentially prohibited or illegal activities and otherwise protecting the integrity of our information technology platform;
• Detecting, investigating, preventing or remediating violations of our Terms and Conditions, any applicable internal Treasury services policies, relevant industry standards, guidelines, laws or regulations;
• Making such disclosures may be required by any law or regulation of any country applicable to us or our affiliate, government official or other third party, including any card association or other payment network.  Disclosures may also be made pursuant to any subpoena, court order or other legal process or requirement in any country applicable to us or our affiliate (including anti-money laundering and counter-terrorist financing reporting requirements);
• Making any disclosure to prevent any harm or financial loss, to report any suspected illegal activity or to deal with any claim or potential claim brought against us or our affiliates;
• Enabling any due diligence and other appraisals or evaluations for actual or proposed merger, acquisition, financing transactions or joint ventures;
• Any other legitimate business purposes, such as protecting you and other users of Treasury App from losses, protecting lives, maintaining the security of our systems and products, and protecting any of our other rights and/or properties.

F. DISCLOSURE OF YOUR INFORMATION

We have database rights in the information collected. As a company that officially cooperates with our partners who support us to provide the best service to you, we may allow our partners/partners to access your information in accordance with the PDPA in providing our services or conducting our business activities. In addition, subject to the PDPA, we may disclose your personal information to third parties when:

• You have previously acknowledged and given written consent or have been deemed to have provided consent to us to us to share your personal information by agreeing to every pop-up notification that appears when your consent to accessing your personal data is required as stated in section C above (COLLECTING PERSONAL INFORMATION);
• We have an obligation under the laws and regulations of the Republic of Singapore to do so (for example, to comply with provisions regarding anti-money laundering, terrorism financing, fraud prevention, etc.) or to protect our rights and interests, property or safety of Treasury, our users or others;
• Every, or substantially all, Treasury assets are combined with or acquired by a third party, or we expand or reorganise our business activities, in which case your personal information may become part of the assets transferred or combined, or we may need to transfer your information to a newly established entity or third parties with which our business activities will be carried out;
• We provide anonymous statistical information about Treasury Web users and related usage information to reputable third parties, including search engine and analytical site operators; or
• We use third party service providers to provide services that involve data processing, for example archival services, audits, reference checking, professional advisors (including legal, accounting, financial and business consultants), mailing houses, delivery, technology, websites, research, banking, payments, data processing, insurance, forensics, litigation assistance, marketing and security.

G. TRANSFERS OF PERSONAL INFORMATION OUTSIDE OF SINGAPORE

In accordance with the PDPA, we may transfer your personal information to recipients outside of Singapore that are bound by legally enforceable obligations to provide a standard of protection to personal data that is comparable to the protection under the PDPA. By using our services and accepting our Terms and Conditions and Privacy Policy, you are deemed to have provided your consent to such transfers of your personal information. These transfers will be done in accordance with the legal requirements under the PDPA.

H. PROTECTION OF PERSONAL INFORMATION

Transmission of information over the internet is not completely secure. We cannot guarantee the security of your data transmitted to our online services; any transmission is at your own risk. Once we receive your information, we will take reasonable steps in accordance to the PDPA to use security procedures and features to try to prevent unauthorized access, modification or disclosure. For example, electronic communications via insecure web platforms including WhatsApp, may not be secure, virus-free or delivered successfully. If you communicate with us using an insecure web platform, you run the risk that the communication between us may be intercepted, not received, delayed, corrupted or received by people other than the intended recipient

To safeguard your personal information from unauthorized access, collection, use, disclosure, copying, modification or disposal, or similar risks, we have introduced appropriate administrative, physical and technical measures to secure your information whether in electronic or physical form. These measures include the following:

• We store information in an access-controlled place or in an electronic database that requires good password practices (logins, passwords and pin numbers).
• We require third party data storage providers to meet appropriate information security industry standards. All staff and third party service providers who have access to confidential information are subject to confidentiality obligations.
• All staff who have access to confidential information are required to know about the protection of personal data under the PDPA for the purpose of preventing failure to protect personal data, and we ask third party service providers who have access to confidential information to do the same.
• Subject to the PDPA, the data we collect from you may be transferred to, and stored in, a destination outside the jurisdiction of origin, that has a standard of data protection that is comparable to the protection under the PDPA.

You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures. 

You understand and agree that we are not responsible for Malicious Software (MALWARE) that gains access to your device or any damage resulting therefrom.

You can help us to maintain information security; please remember that any username or password or PIN number associated with Treasury Web is personal to you and should not be shared with anyone. You should stop using your username, password and PIN number and notify us immediately if you suspect that someone else may be using it.

I. COOKIES

Our online services use cookies and other similar technologies, for example, to distinguish you from other users when you browse Web Treasury or use our online services and also to make us improve our online services.

J. THIRD PARTY SITES

In addition to our online services, which we control directly, we may also use and provide links to websites controlled by third parties.

If you use or follow a link to any of these third party websites, please be aware that these websites have their own privacy policies and we are not responsible for any of their use of information about you.

K. YOUR RIGHTS

Some of our online services may provide registered users with the facility to directly access and update certain profile information.

PDPA give individuals the right to access, correct and delete their personal information. If you wish to request a copy of your data and wish to change or delete the information about you that we store, please submit your request in writing or via email to our Data Protection Officer at the contact details provided below 

Upon receipt of your written request to withdraw your consent, we may require reasonable time (subject to the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us. In general, we shall seek to process your request within ten (10) business days of receiving it.

In accordance with the PDPA, upon determining that a data breach is notifiable, we will notify the Personal Data Protection Commission Singapore (“PDPC) as soon as practicable, but in any case, no later than 3 calendar days. Where required, we will notify affected individuals as soon as practicable, at the same time or after notifying the PDPC.

At any time if you choose to stop receiving promotions, programs and the latest information from us, please use the “unsubscribe” option contained in emails or other materials.

Please note that withdrawing consent does not affect our right to continue to collect, use, process, and disclose personal data where such collection, processing, usage and disclosure without consent is permitted or required under applicable laws.

L. STATUS OF PRIVACY POLICY

By using our online services, we assume we have received your agreement to the terms of this Privacy Policy.

The practice of managing technology and information continues to evolve. Therefore, we may amend this Privacy Policy from time to time and will make available the updated Privacy Policy in the Treasury Web and Treasury App. Accordingly, we recommend that you review this page regularly to ensure that you are aware of any changes to any of its terms.

The updated Privacy Policy will supersede earlier versions and will apply to personal information provided to us previously. Each time you use the Treasury Web or Treasury App or any other online services, or contact, interact or transact with us, you acknowledge and agree that the latest version of this Privacy Policy shall apply. This Privacy Policy shall be read in conjunction with the Treasury Terms and Conditions.

M. CONTACT AND MORE INFORMATION

To find out more about Treasury, please visit: www.treasury.sg.

If you have questions about this Privacy Policy, or would like to make a written complaint about how we handle your personal information, please contact our Data Protection Officer via: [email protected].

If you make a privacy complaint, we will respond so you know how your complaint is being handled. We may request additional details from you, consult with others and maintain records of your complaint.