privacy policy

Last updated 18 August 2022

1. Introduction and application
1.1. This policy ("Privacy Policy") describes how Market Makers (Company No.202228834C) ("Company") manages Personal Data which is in our possession or under our control. "Personal Data", is defined in the Personal Data Protection Act 2012 of Singapore ("PDPA"), and currently refers to data, whether true or not, about an individual who can be identified from that data; or from that data and other information to which we have or are likely to have access to.
1.2. By using our services pursuant to your agreement(s) with us ("Services"), operating any account maintained with us, accessing the online platform operated by us (which is accessible through our website at https://www.marketmakers.com/) ("Platform"), websites or mobile applications, or otherwise providing information to or communicating with us, you are taken to have agreed to our collection, use, processing and disclosure of your Personal Data in accordance with this Privacy Policy.
1.3. Capitalized terms not otherwise defined in this Privacy Policy shall have the meaning as ascribed in the Terms and Conditions, its Schedules and application form(s) submitted by you (including any terms and conditions or disclaimers thereto) (the "Agreement")between you and us.
1.4. This Privacy Policy does not supersede or replace any other consents you may have previously or separately provided to us in respect of your Personal Data, and your consent to this Privacy Policy is in addition to any other rights which we may have to collect, use, process or disclose your Personal Data.
1.5. The words "we", "us", "our" or any of their derivatives refer to Company and its successors and any novate, assignee, transferee or purchaser of Company' rights and/or obligations hereunder and any reference to Company includes a reference to such successor, novate, assignee, transferee or purchaser. The words "you", "your", "yours" or any of their derivatives refer to the person using our Services, operating any account maintained with us, accessing our Platform, website or mobile applications, or otherwise providing information to or communicating with us and shall include, as the context may require, personal representatives (as the case may be).
1.6. This Privacy Policy shall be governed by, and construed in accordance with, the laws of Singapore. Without prejudice to your rights under any applicable laws, any dispute arising out of or in connection with this Privacy Policy and/or the documents referred to herein, including any question regarding their existence, validity or termination, shall be referred to and finally resolved by the courts of Singapore and both you and we hereby unconditionally and irrevocably submit to the exclusive jurisdiction of the courts of Singapore.

2. Personal data that we collect
2.1. We collect, use, disclose, transfer and otherwise process Personal Data about you or individuals who are connected or associated with you including but not limited to your legal representatives ("Associated Persons") in accordance with this Privacy Policy.
2.2. The Personal Data that we collect or may collect include:
2.2.1. personal contact data including name, telephone number, email address, residential address and correspondence address;
2.2.2. specimen signature(s);
2.2.3. occupation, education, employment status and income levels, including whether you have any professional qualifications relating to finance;
2.2.4. identification card or passport number, nationality, date of birth, place of birth and other information for the verification of identity;
2.2.5. financial and banking information (e.g. information on source and amount of regular income, your financial situation, net assets, income, expenses, cash flow, financial commitments, credit history, bank account and banking transactions);
2.2.6. images, voice recordings of our conversations with you and/or your biometric information;
2.2.7. tax and insurance information;
2.2.8. information about your financial or investment objectives, risk profile and risk tolerance, investments, investment objectives, knowledge and experience and/or business interests and assets, including current investment portfolio, including any life policies, your current securities trading account, whether the amount to be invested with is a substantial portion of your assets and prior investment experiencing relation to specific investment products;
2.2.9. personal opinions made known to us (e.g. your feedback or responses to any surveys);
2.2.10. browsing history, patterns or other unique information;
2.2.11. your internet protocol address and information associated with such address;
2.2.12. any other personal data reasonably required in order for us to provide the Services requested by you; and
2.2.13. any other personal data permitted by or required to comply with any applicable local or foreign laws, rules, acts, regulations, subsidiary legislation notices, notifications, circulars, license conditions, directions, requests, requirements, guidelines, directives, codes, information papers, practice notes, demands, guidance and/or decisions of any national, state or local government, any agency, exchange, regulatory or self-regulatory body, law enforcement body, court, central bank or tax revenue authority or any other authority whether in Singapore or elsewhere, whether having the force of law or not (including any intergovernmental agreement between the governments or regulatory authorities of two or more jurisdictions or otherwise),as may be amended from time to time ("Applicable Laws") and our internal control and compliance policies.

3. Sources of information
3.1. The Personal Data has/or will be obtained from the following sources, where applicable, or such other sources which we may see fit from time to time:
3.1.1. information provided or submitted by you through among others, your dealings and agreements with us, which includes information provided when registering as a user, providing information regarding any account which you may open with us, providing answers to security questions, completing any confirmations, declarations or forms, or through your utilization of any of our Services, accessing or viewing our Platform;
3.1.2. as applicable, publicly available or publicly accessible information; and
3.1.3. such other written, electronic or verbal communications or documents delivered to us prior to and during the course of our contractual or pre-contractual dealings with you.
3.2. As the accuracy of your Personal Data depends largely on the information you provide to us, you should inform us as soon as practicable if there are any errors in the Personal Data or if there have been any changes to the Personal Data by informing our Data Protection Officer via email at dataprotection@marketmakers.com.

4. Purpose of collecting, using and disclosing your personal data
4.1. We may collect, use or disclose your Personal Data for our business purposes, including the provision and continuing operation of the Platform and the Services provided to you. This includes, the following purposes ("Purposes"):
4.1.1. performing obligations in the course of or in connection with our provision of the Services as requested by you;
4.1.2. assessing and processing applications, instructions or requests from you;
4.1.3. managing your relationship with us;
4.1.4. communicating with you, including providing you with updates on changes to our Services;
4.1.5. to verify your identity for the purposes of providing the Services to you;
4.1.6. conducting due diligence checks, screenings or credit checks as may be required by any Applicable Laws or our internal policies and procedures;
4.1.7. for the specific purpose for which it was volunteered or provided to us;
4.1.8. to detect and protect us or any third parties against negligence, fraud, theft and other illegal activities;
4.1.9. to understand your needs and preferences;
4.1.10. improving the content, appearance and utility of the Platform;
4.1.11. to manage and develop infrastructure and business operations;
4.1.12. to administer any account which you may open with us;
4.1.13. to process payments or credit transactions;
4.1.14. to comply with our internal policies and procedures;
4.1.15. to respond to queries or feedback;
4.1.16. to address or investigate any complaints, claims or disputes;
4.1.17. as permitted by any Applicable Laws;
4.1.18. to comply with any Applicable Laws or to assist with any request from or law enforcement and investigations conducted by any relevant governmental or regulatory authority;
4.1.19. financial reporting, regulatory reporting, management reporting, risk management, audit and record keeping purposes;
4.1.20. enforcing obligations owed to us;
4.1.21. seeking professional advice, including legal advice;
4.1.22. any other reasonable purposes in connection with the provision of our Services;
4.1.23. providing you with information, materials and/or documents for marketing, business development, advertising and/or promotional purposes in connection with the Services we may provide. We may use your personal data to recommend you products or services, including special offers, promotions, contests or entitlements that may be of interest to you. Such marketing messages may be sent to you in various modes including but not limited to electronic mail, direct mailers, short message service, telephone calls, facsimile and other mobile messaging services;
4.1.24. transmitting to any unaffiliated third parties including our third party service providers and agents, and relevant governmental and/or regulatory authorities, whether in Singapore or abroad, for the aforementioned purposes; or
4.1.25. fulfilling any purpose directly related to the above Purposes or other incidental business purposes related to or in connection with the above.
4.2. The Purposes listed above may continue to apply even in situations where your relationship with us (for example, pursuant to a contract) has been terminated or altered in any way, for a reasonable period thereafter (including, where applicable, a period to enable us to enforce our rights under a contract with you).
4.3. You shall acquire consent from Associated Persons before providing their Personal Data to us. Where you have provided Personal Data to us relating to any other individual, wish all assume that you have obtained the relevant consent in order to do so.
4.4. You may, at any time, withdraw your consent to receive marketing information from us. If you wish to do so, please contact our data protection officer at EMAIL or PHONENUMBER OF DATA PROTECTION OFFICER.

5. Disclosure and sharing of your personal data
5.1. Without prejudice to any other provisions in any agreements between us, we may from time to time disclose and share your Personal Data with our directors, officers, employees, representatives, agents or delegates or any third parties including Intermediaries, whether located in Singapore or otherwise, to carry out the Purposes. This includes disclosing and sharing your Personal Data with the following:
5.1.1. any of our directors, officers, employees, representatives, agents or delegates;
5.1.2. any of our shareholders or related corporations, and any of their successors or assigns, and their directors, officers, employees, representatives, agents or delegates;
5.1.3. our professional advisers, consultants and auditors;
5.1.4. any Intermediaries, service providers, agents, contractors, delegates, suppliers or hard parties which we may appoint from time to time to provide us with services in connection with the Platform or the Services that we offer to you, and their directors, officers, employees, representatives, agents or delegates;
5.1.5. any sub-contractors which any of our Intermediaries, service providers, agents, suppliers, delegates or contractors may appoint from time to time to provide them with services in connection with the Platform or the Services that we offer to you, and their directors, officers, employees, representatives, agents or delegates;
5.1.6. anyone who takes over or may take over all or part of our rights or obligations under any agreement we have with you or anyone any agreement we have with you(or any part thereof) is transferred to or may be transferred to;
5.1.7. any person who we believe in good faith to be your legal advisers or other professionals;
5.1.8. any relevant governmental or regulatory authority, in so far as we need to do so to keep to any Applicable Laws, or which we in good faith believe that we should keep to;
5.1.9. pursuant to a request by any relevant governmental or regulatory authority(regardless of the reason for such request and whether such request is exercised under a court order or otherwise);
5.1.10. parties which assist us in carrying out the Purposes laid out above in this Privacy Policy; and
5.1.11. any person to whom we are, in our belief in good faith, under an obligation to make disclosure as required by any Applicable Laws, provided that in the case of disclosures under any of the circumstances in paragraphs 5.1.1 to 5.1.4, we shall procure that the recipient is subject to the same duty of confidence.

6. Transfer of your personal data outside Singapore
6.1. We may transfer, store, process and/or deal with your Personal Data outside Singapore. When doing so we will take appropriate steps to ensure that the transferred PersonalData is provided with a standard of protection that is at least comparable to the protection under the PDPA.

7. Retaining your personal data
7.1. We may retain your Personal Data for as long as it is necessary to fulfil the purpose(s)for which it was collected, or as required or permitted by Applicable Laws. We will cease to retain your Personal Data, or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purpose(s) for which the Personal Data was collected, and is no longer necessary for legal or business purposes.

8. Withdrawing your consent
8.1. The consent that you provide for the collection, use and disclosure of your Personal Data will remain valid until such time it is being withdrawn by you in writing. You may withdraw consent and request us to stop collecting, using and/or disclosing your Personal Data for any or all of the Purposes listed above by submitting your request via email to our Data Protection Officer at the contact details provided below.
8.2. Upon receipt of your written request to withdraw your consent, we may require reasonable time (depending on 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 will aim to process your request within ten (10) business days of receiving it.
8.3. Whilst we respect your decision to withdraw your consent, please note that depending on the nature and scope of your request, we may not be in a position to continue providing our services to you and we shall, in such circumstances, notify you before completing the processing of your request.
8.4. Please note that withdrawing consent does not affect our right to continue to collect, use and disclose Personal Data where such collection, use and disclose without consent is permitted or required under Applicable Laws.

9. Rights of access and rectification
9.1. You may request access to your Personal Data we hold about you or information about the ways in which we use or disclose your personal data, or request the rectification or correction of any of your Personal Data. If you would like to do so, please contact our data protection officer at dataprotection@marketmakers.com.
9.2. Please note that a reasonable fee may be charged for an access request. If so, we will inform you of the fee before processing your request.
9.3. We will respond to your request as soon as reasonably possible. In general, our response will be within thirty (30) business days. Should we not be able to respond to your request within thirty (30) days after receiving your request, we will inform you inwriting within thirty (30) days of the time by which we will be able to respond to your request. If we are unable to provide you with any personal data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the PDPA).

10. Use of cookies and related technologies
10.1. Our Platform, websites and mobile applications ("apps" or an "app") use cookies and other tracking technologies. By using our Platform, websites and apps, you agree to the use of cookies and other tracking technologies as set out in this Privacy Policy. If you do not agree to such use, please either refrain from using the relevant website or Platform or refer to the paragraphs below on how you can adjust your settings.
10.2. A cookie is a small text file placed on your computer, system or mobile device when you visit a website or use an app. Cookies collect information about users and their visit to the website or use of the app, such as their Internet protocol (IP) address, how they arrived at the website (for example, through a search engine or a link from another website) and how they navigate within the website or app. We use cookies and other technologies to facilitate your internet sessions and use of our apps, offer you products and/or Services according to your preferred settings, track use of our websites and apps and to compile statistics about activities carried out on our websites and/or through our apps.
10.3. A pixel tag, also known as a web beacon, is an invisible tag placed on certain pages of our website but not on your computer. Pixel tags are usually used in conjunction with cookies and are used to monitor the behavior of users visiting the website.
10.4. You may set up your web browser to block cookies which will in turn disable the pixel tags from monitoring your website visit. You may also remove cookies stored from your computer or mobile device. However, if you do block cookies and pixel tags, you may not be able to use certain features and functions of our websites or the Platform.
10.5. We may also use analytics programs similar to Google Analytics for web analytics purposes to manage and improve our websites, mobile applications, the Platform and/or our Services. Certain features may be used and as a result, your information may be collected for reports such as impression reporting, demographic reporting, interest reporting and to assist with tailoring our online advertising to provide you with a better experience.
10.6. We and our third-party vendors may use first-party cookies or other first-part identifiers, and third-party cookies or other third-party identifiers together, to inform, analyze, optimize, and serve custom ads based on your interests, searches and prior usage patterns when visiting our websites, mobile applications and Platform, and for other market research analysis purposes such as impression reporting and how your interactions with these ads are related to visits to our websites, mobile applications and Platform, amongst others. As a consequence, third party vendors may show our ads on other websites or mobile applications. We neither support or endorse the goals, causes or statements of these websites or mobile applications which display our ads. Where applicable, using the Google Ad Settings(https://www.google.com/settings/u/0/ads/authenticated), you may control the ads you view, block specific advertisers, learn how ads are selected for you, and opt-out of Google Analytics for Display Advertising. To opt out from any collection or use of information by Google Analytics, please download and install the Google Analytics Opt-Out Browser Add-on available at https://tools.google.com/dlpage/gaoptout. By opting out, you will not be subject to online advertising or marketing analysis by Google Analytics and you will no longer receive ads tailored to your browsing patterns and usage preferences. .

11. Protection of personal data
11.1. To safeguard your Personal Data from unauthorized access, collection, use, disclosure, copying, modification, disposal or similar risks, we have introduced appropriate administrative, physical and technical measures such as authentication and access controls, encryption of data, up-to-date antivirus protection, regular patching of operating system and other software, web security measures against risks, usage of onetime password(otp)/2 factor authentication (2fa)/multi-factor authentication (mfa) to secure access, and security review and testing performed regularly.
11.2. 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.
11.3 Data obtained through the short code program will not be shared with any third-parties for their marketing reasons/purposes.


12. Third party sites
12.1. Our web sites may contain links to other websites which are not maintained by us. This Privacy Policy only applies to our websites, mobile applications (as applicable), the Platform and/or our Services. When visiting these third party websites, you should read their privacy policies which will apply to your use of the web sites.

13. Complaints
13.1. If you think any collection, use, process or disclosure of your Personal Data violates this Privacy Policy or any Applicable Laws, please report to our data protection officer at dataprotection@marketmakers.com and we will process your complaint and respond to you.

14. Changes
14.1. We may revise this Privacy Policy from time to time without any prior notice. You may determine if any such revision has taken place by referring to the date on which this Privacy Policy was last updated. If you continue to use our Services, operate any account maintained with us, access our Platform, websites or mobile applications (as applicable),and/or otherwise provide information to or communicate with us, you are deemed to have agreed to such changes without reservation.

15. Contacting us
15.1. If you have any questions about any aspects of this Privacy Policy or your PersonalData, please contact our data protection officer at dataprotection@marketmakers.com.