Personal Data Protection Policy

INTRODUCTION TO THE PDPA

1.1

"Personal Data" is defined under the PDPA to mean 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. Common examples of personal data could include names, identification numbers, contact information, medical records, photographs and video images.

PURPOSES FOR COLLECTION, USE, DISCLOSURE AND PROCESSING OF PERSONAL DATA

2.1

The personal data which we collect from you may be collected, used, disclosed and/or processed for various purposes, depending on the circumstances for which we may/will need to process your personal data, including :

providing or administering any products, services or information that have been requested;
managing and responding to your requests and/or enquiries;
internal and external audit and/or investigations within the Company;
complying with internal policies and procedures and managing the administrative and business operations of the Company;
record keeping purposes;
statutory/regulatory reporting purposes;
carrying out due diligence or other screening activities in accordance with legal or regulatory obligations or risk management procedures that may be required by law or put in place by the Company;
investigating your complaints, detecting and preventing fraud, misconduct; any unlawful action or omission and/or improper activities;
conducting research and statistical analysis;
managing the safety and security of our premises (including but not limited to carrying out CCTV surveillance and conducting security clearances);
complying with applicable rules, law, regulations or guidelines;
any other purposes reasonably related to the above;
any other purposes which we notify you of at the time of obtaining your consent,

(collectively, the "Purposes").

As the purposes for which we may/will collect, use, disclose or process your personal data depend on the circumstances at hand, such purpose(s) may not appear above. However, we will notify you of such other purpose(s) at the time of obtaining your consent, unless processing of your personal data without your consent is permitted by the PDPA or by law.

2.2

In order to conduct our business operations more smoothly, we may also be disclosing the personal data you have provided to us to our third party service providers, agents and/or our affiliates or related corporations, and/or other third parties whether sited in Singapore or outside of Singapore, for one or more of the above-stated Purposes. Such third party service providers, agents and/or affiliates or related corporations and/or other third parties would be processing your personal data either on our behalf or otherwise, for one or more of the above-stated Purposes.

REQUEST FOR ACCESS AND/OR CORRECTION OF PERSONAL DATA

3.1

You may request to access and/or correct the personal data currently in our possession by submitting your request to the DPO.

3.2

For a request to access personal data, we will provide you with the relevant personal data within a reasonable time from such a request being made.

3.3

We will also be charging you a reasonable fee for the handling and processing of your requests to access your personal data. We will provide you with a written estimate of the fee we will be charging. Please note that we are not required to respond to or deal with your access request unless you have agreed to pay the fee.

REQUEST TO WITHDRAW CONSENT

4.1

You may withdraw your consent for the collection, use and/or disclosure of your personal data in our possession or under our control by submitting your request to the DPO.

4.2

We will process your request within a reasonable time from such a request for withdrawal of consent being made, and will thereafter not collect, use and/or disclose your personal data in the manner stated in your request.

4.3

However, your withdrawal of consent could result in certain legal consequences arising from such withdrawal, which will depend on the extent of your withdrawal of consent for us to process your personal data.

ADMINISTRATION AND MANAGEMENT OF PERSONAL DATA

5.1

You must update us of any changes in your personal data that you had initially provided us with. We will not be responsible for relying on inaccurate or incomplete personal data arising from your not updating us of any changes in your personal data that you had initially provided us with.

5.2

We will also put in place reasonable security arrangements to ensure that your personal data is adequately protected and secured. However, we cannot assume responsibility for any unauthorized use of your personal data by third parties which are wholly attributable to factors beyond our control.

5.3

We will also put in place measures such that your personal data in our possession or under our control is destroyed and/or anonymized as soon as it is reasonable to assume that (i) the purpose for which that personal data was collected is no longer being served by the retention of such personal data; and (ii) retention is no longer necessary for any other legal or business purposes.

COMPLAINT PROCESS

6.1

If you have any complaint or grievance regarding about how we are handling your personal data or about how we are complying with the PDPA, we welcome you to contact us with your complaint or grievance.

6.2

Please contact us through one of the following methods with your complaint or grievance:

Global Digital Exchange :

Data Protection Officer
1 Wallich Street
#15-01 Guoco Tower
Singapore 078881
Email: contact@globaldigitalexchanges.com

Global Digital Exchange :

Data Protection Office Bowen Building Tower
the at 875 15th St. Mcpherson street, Washington DC
Email: contact@globaldigitalexchanges.com

6.3

Where it is an email or a letter through which you are submitting a complaint, your indication at the subject header that it is a PDPA complaint would assist us in attending to your complaint speedily by passing it on to the relevant staff in our organisation to handle. For example, you could insert the subject header as "PDPA Complaint"

6.4

We will certainly strive to deal with any complaint or grievance that you may have speedily and fairly.

UPDATES ON PERSONAL DATA PROTECTION POLICY

We reserve the right to amend the terms of this Personal Data Protection Policy at our absolute discretion. Any amended Personal Data Protection Policy will be posted on our website.

Last Updated on 2 July 2014