Privacy Policy

PRIVACY POLICY

BuoyTrade Private Limited (“BuoyTrade”, “us”, “we” and “our”) is committed to safeguarding your privacy online or otherwise and the success of our business depends upon our ability to maintain the trust of our customers. This Privacy Policy aims to provide a summary of the type of Personal Data that we collect of our customers, how such information is used, transferred/disclosed and stored. The policy does not cover any external third-party websites that may be accessed through links provided on our website.

“Personal Data” has the meaning set out in the Personal Data Protection Act 2012 (“PDPA”).

Any reference to “BuoyTrade”, “us”, “we” and “our“ in this privacy policy is a reference to BuoyTrade Private Limited as the context requires unless otherwise stated.

Similarly, any reference to ”you”, “your”, “yours”, “yourself” or “Customer” in this privacy policy is a reference to any of our customers and potential customers as the context requires, unless otherwise stated.

1. COLLECTION OF PERSONAL DATA

Generally, we collect personal data that is linked to an individual. We obtain and collect the data about you directly from you in connection with your use of our services. This includes, in particular:

i. Data that you provide to us yourself, especially when you register on the website, enter information into your user account, order services, participate in our events or projects, or when you communicate with us through customer support or social networks. For example, your name, identification number, residential address, date of birth, gender, nationality, phone number,

email address, location data etc. If you are an entrepreneur, payment data, such as bank details and other data, such as records of communication between you and our company or details of any warranty claims. This is not an exhaustive list and we may collect other types of personal data from you.

ii. Apart from Personal data, we may collect other types of information which is not linked to an individual and which is anonymous. These are data that we automatically collect when you use our services. These are data about your device (such as IP address, device type, operating system, browser used, connection provider); website usage data (such as date, time and duration of visit, country from which you visit the website, website browsing history), and data on the use of services (such as the login and logout information, your account settings, value of your fictitious capital, your account currency, business strategy).

Some data about you is provided to us by third parties, such as providers of trading platforms that you choose for use of our services, and social network operators if you decide to link you social networking accounts to an account on the website. This includes:

iii. Data about the simulated transactions you have completed (such as the type of financial instrument, time of opening and closing the position, amount of investment, profit and loss) and data from social networks (user name, profile picture, e-mail address associated with the account on the social network). For information on how your personal data are processed by trading

platform, providers and social network operators for their own purposes, please refer to the privacy of those parties.

2. USE, DISCLOSURE AND/OR PROCESSING OF PERSONAL DATA

We may hold and retain information about you for various purposes based on different reasons.

· Registration and user account

In order to use the services, you must register on the website and create your account, and for this purpose we process your personal data.

Personal data: identification and contact data; we may also process your data related to the settings of your user account.

Legal ground for the processing: Processing is necessary for the performance of the contract, and the provision of these personal data is required, as we cannot register your user account without them.

· Provision of services and exercise of rights and obligations under the contract between us and the customer

In order to be able to provide you with our services, i.e. in particular to provide you with the relevant access, tools and support, and to carry out trades, we need to process your personal data.

For this purpose, the following shall apply:

Personal data: identification and contact data and, in the case of paid services, also payment data, data on the use of the services, data on the simulated trades and, if you decide to link your social networks accounts with the account on the website, also data from social networks.

Legal ground for the processing: Processing is necessary for the performance of the contract on the basis of which we provide our services, or on the basis of our legitimate interest. After we stop providing you with services, we process personal information for a limited period of time. Such processing is necessary for the purposes of exercising and protecting our rights based on our

legitimate interest.

· Marketing communication about our services and products or about events in which we take part

If you are our current or past customer, we may from time to time send you marketing communications to the extent to which you give us your consent. Each of the e-mails sent will be marked as a business communication and each of them will contain a link with the help of which you can easily unsubscribe from the business communications. For this purpose, the following shall

apply:

Personal data: identification and contact data.

Legal ground for the processing: If we have provided you with our services, we may from time to time send you marketing communications based on our legitimate interest, namely keeping in touch with our customers. If you give us your consent to process your data for marketing purposes, then we process your data on the basis thereof.

· Customer support and communication

If you use our customer support services, we will process your personal data. For this purpose, the following shall apply:

Personal data: identification and contact data, other data and data from social networks, if you contact us through social networks.

Legal ground for the processing: Processing is based on our legitimate interest, namely in maintaining customer satisfaction and supporting the use of our services.

· Improving services

If you use some of our services, we will process your personal data in order to develop, test and enhance the services and improve their security. For this purpose, the following shall apply:

Personal data: identification and contact data, data about your device, website usage data, data on the use of the services, and data on the simulated trades.

Legal ground for the processing: Processing is based on our legitimate interest, namely in improving our services.

· Analytics

To obtain information about how our website and our services are used, we analyse customer behaviour. For this purpose, the following shall apply:

Personal data: identification and contact data, payment data, data about your device, website usage data, data on the use of the services, and data on the simulated trades.

Legal ground for the processing: Processing is based on our legitimate interest, namely in ascertaining customer behaviour and estimating customer preferences.

3. STORING AND SECURITY OF PERSONAL DATA

We process your personal data in an encrypted database on computers and other devices. In order to ensure protection against unauthorised access or unauthorised alteration, disclosure or destruction of the data that we collect and process, we have adopted organisational and technical measures to secure them, which we strictly adhere to.

4. RETENTION

Personal Data is held for as long as the purpose for which it was collected remains and until retention is no longer legally required nor necessary for business purposes. BuoyTrade shall cease to retain Personal Data or remove the means by which the Personal Data can be associated with particulars customers, as soon as it is reasonable to assume that the purpose for which that Personal Data was collected is no longer valid and retention is no longer necessary for legal or business purposes.

5. TRANSFER OF PERSONAL DATA OVERSEAS

In certain circumstances, we may need to transfer your personal data outside of Singapore (for example, data storage, data management and/or consolidation purposes), whether to our parent company, group companies, business partners or third-party service providers or simply to data storage facilities, we shall do so in accordance with the PDPA and ensure that the standard of protection applied to Personal Data so transferred is comparable to the protection required under the PDPA.

6. CONSENT

BuoyTrade (including its employees, directors and/or representatives) is required by law to keep Personal Data strictly private and confidential, save and except as set out in this Privacy Policy, we will not disclose any Personal Data without having obtained your prior consent to do so unless otherwise permitted by law.

Generally, when we request for Personal Data in the course of providing you a service and/or product and where you provide us with such Personal Data, there is implied consent that you agree to provide us your with Personal Information in order for us to provide you with the requested service and/or product.

In some circumstances and as required by applicable law, we will seek your express consent when collecting your Personal Information. This is particularly where fresh content is required for a new purpose in which your Personal Information will be used.

If you do not consent to provide the requisite personal data that we need at the point of application or in the course of maintaining your account(s)with us, we may not be able to open account or provide specific service or product that you require. You are entitled to withdraw your consent for the collection of personal data by sending a email to [email protected] with the subject titled “Withdrawal of Consent Form”. Upon receiving the email, we will send you the relevant form for the necessary action. However, do note that by doing this, it may affect our ability to maintain your account(s) with us.

7. ACCURACY AND CORRECTION

BuoyTrade endeavours to ensure that your Personal Data is as accurate and up-to-date as possible. To ensure that we hold accurate and current information, we ask you to promptly notify us of any changes to the personal data we hold about you. You may contact us at any time if you wish to correct, amend or update your Personal Data by emailing us at [email protected]

8. ACCESS RIGHTS

Under the Act, you have the right to obtain a copy of Personal Data which we hold about you and entitled to know how your Personal Data has been used or disclosed in the past one year. A request can be made emailing us at [email protected] with the subject titled “Request for Information”.

Your request will be acknowledged and acted upon generally within thirty (30) days of receipt of such request. If for any reason, we are unable to accede to your request, you will be notified accordingly. BuoyTrade is entitled to charge a reasonable administrative fee to cover the processing cost for the request. The actual fee will be provided to you after we have received your request as it will depend on the data requested.

9. SECURITY SAFEGUARDS

We have implemented stringent measures to secure and protect your information. However, you should be aware that the use of the Internet is not entirely secure and for this reason we cannot guarantee the security or integrity of any personal data which is transferred from you or to you via the Internet.

10. COOKIES

A cookie is a text file made up of letters and numbers that allow us to distinguish your browser/device from another user’s browser/device. This text file is stored on your computer’s hard disk for the purpose of keeping records when you visit a website.

We use cookies to collect information. When cookies are used by us, they collect statistical and factual information about how you use our services. Most internet browsers are set up to accept cookies. If you do not wish to receive cookies, you may be able to change the settings of your browser to refuse all cookies or to have your computer notify you each time a cookie is sent to it, and thereby give yourself the choice whether to accept it or not. However, this may impair the quality of the services that we provide to you in relation to your account.

11. GOVERNING LAW

BuoyTrade is a Singapore registered company, this Privacy Policy has been drafted solely in accordance with the laws of Singapore. We do not represent or warrant that this Privacy Policy complies with the privacy laws of any other jurisdiction and accordingly, you shall not construe this Privacy Policy as such.

12. EUROPEAN UNION GENERAL DATA PROTECTION REGULATION (EU GDPR)

In addition to obligations under the PDPA, we strive to comply with its obligations to individuals in the EU as set out in the EU GDRP. In the event that the EU GDRP requires a higher level of protection for the personal data of individuals in EU than the PDPA, such stricter requirements shall be complied with.

Please refer to the GDPR website for more information:https://eugdpr.org

13. CONTACT US

If you have any comments and/or questions about this Privacy Policy or if you wish to give specific feedback relating to our collection, use and/or disclosure of your Personal Data, please contact us as follows:

Subject: Privacy Policy

Attention: Data Protection Officer

Email: [email protected]

In applying for, using or continuing to use our services, you shall be deemed to have accepted and consented to the terms in this Privacy Policy. If you do not consent to the terms herein, kindly contact us at the abovementioned contact details.

14. AMENDMENTS TO THIS PRIVACY POLICY

This Privacy Policy will be reviewed from time to time take account of amendments to the Act, and other applicable new laws and technology, changes to our operations and practices and to make sure it remains appropriate to the changing environment. Amendments to this Privacy Policy will be effective from the time they are posted on our website and your continued use of this website will constitute acceptance to any amendments to this Privacy Policy. We advise you to check the website regularly for any amendments to this Privacy Policy.

15. DISCLAIMER

Our website may contain links to external third party websites. Please note that third-party websites are not covered by our Privacy Policy. You are advised to read the privacy statement of each website that you visit, which collects personal data.