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Privacy Statement

PRIVACY STATEMENT

    1. 1.1Co-Axis Marketplace Pte. Ltd. (“Co-Axis”) is a Singapore-incorporated company and we collect, use, disclose and process personal data (as defined below) in accordance with the Personal Data Protection Act 2012 of Singapore (“PDPA”).
    2. 1.2The purpose of this Privacy Statement is to inform you of how we handle or process personal data in accordance with the PDPA.
    3. 1.3This Privacy Statement sets out the basis on which we will collect, use, disclose, and process your personal data. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By visiting and using this website as well as the services, content and/or features offered thereon (“Platform”), you confirm that you accept and agree to be bound by the terms of this Privacy Statement, as may be amended from time to time, and consent to Co-Axis and its related corporations, subsidiaries and affiliates, as well as our representatives and/or agents (“us”, “we” or “our”) collecting, using, disclosing your personal data as described in this Privacy Statement. In addition, this Privacy Statement will also provide you with more information on the basis upon which we may collect, use and/or disclose your personal data without your consent, where permitted by applicable law.
    4. 1.4This Privacy Statement supplements but does not supersede nor replace any other consents which you may have previously provided to us, either directly or via a third-party data collector, and your consents herein are cumulative and additional to any rights which we may have at law to collect, use, disclose and/or process your personal data. This Privacy Statement does not affect any rights which we may have at law in connection with the collection, use, disclosure and/or processing of your personal data.

COLLECTION OF PERSONAL DATA

As used in this Privacy Statement, “personal data” means data, whether true or not, about an individual who can be identified: (a) from that data; or (b) from that data and other information to which we (and all our affiliated entities and relevant unaffiliated third parties) have or are likely to have access.


    1. 1.1Generally, we collect personal data when you or your authorized representatives provide it directly or indirectly to us or to our partners, vendors or service providers, including through the following:
      1. (a)submitting forms to us, including any registration forms, or when you update or add information to your user profile;
      2. (b)when you use our services, or interact with us via the Platform (including, without limitation, when you use services, content and/or features thereon);
      3. (c)when we seek information about you and receive your personal data in connection with your relationship with us, including for our services, for example, from business partners, public agencies, and the relevant authorities;
      4. (d)when you interact with us, for example, when you contact us via emails, telephone or by any other means, make enquiries, submit requests and/or respond to our communications;
      5. (e)when you link any of your account with us with third-party services and applications (examples include, without limitation, Google and LinkedIn);
      6. (f)when we receive your personal data from third parties, for example, when you submit your email address to us to show interest, we receive information from a third party that provides automated fraud detection services to us, or from parties that legally provide it to us, such as credit reference agencies or law enforcement agencies;
      7. (g)similar situations in which you have chosen to provide the information to us;
      8. (h)when you submit your personal data to us for any other reason; and
      9. (i)through the use of analytics code and other tools like cookies (please refer to the “IP Addresses/Cookies” section below in this Privacy Statement for further details).
    2. 1.3Where personal data submitted by you concerns another individual other than yourself, you represent and warrant to us that all the necessary consents (in accordance with all applicable data protection legislation, including without limitation, the PDPA) have been obtained from the relevant individuals and that you have retained proof of these consents, such proof to be provided to us upon our request.

PURPOSES OF COLLECTION, USE AND DISCLOSURE

3.1 Generally, we may collect, use and/or disclose your personal data and other information individually or collectively and may combine your personal data with other information for the following purposes:

(a) processing your registration with our Platform;

(b) administering our website(s) and providing you with services on our Platform;

(c) to respond to, handle and process your enquiries, requests, applications, complaints, and feedback pursuant to your emails, telephone calls, submission of form(s) and/or any other form of communication;

(d) responding to and taking follow-up actions on your feedback;

(e) administering your data such as by carrying out your instructions or responding to any enquiries by you;

(f) compiling statistics, whether for our own use or for industry exercises and studies, to design and improve our products and services for you;

(g) marketing and advocacy such as information about us and our related organisations’ products and services, or other information which may be of interest to you;

(h) complying with obligations under applicable laws and their related subsidiary legislation, regulations, guidelines, advisories, or other directions as may be issued by the relevant law enforcement or regulatory agencies from time to time;

(i) facilitating business asset transactions (which may extend to any mergers, acquisitions or asset sales) involving us;

(j) to detect, prevent and mitigate fraud and abuse of our services and to protect you against account compromise;

(k) to enhance security, monitor and verify identity or service access, combat spam or other malware or security risks;

(l) to send information including confirmations, technical notices, updates, security alerts, and support and administrative messages;

(m) for other purposes as reasonably required to provide services to you; and

(n) for any other purposes relating to the above.


3.2 In addition, where permitted under applicable law, we may also collect, use and disclose your personal data for the following purposes (which we may describe in our documents and agreements as “Additional Purposes” for the handling or processing of personal data):

(a) providing or marketing services, products and benefits to you, including promotions and loyalty and reward programmes, including joint marketing and/or cross promotions with third parties;

(b) matching personal data with other data collected for other purposes and from other sources (including third parties) in connection with the customisation, provision or offering of products, services, marketing or promotions, whether by us or other third parties;

(c) personalising your experience on our Platform;

(d) conducting market research, understanding and analysing customer behaviour, location, preferences and demographics for us to offer you products and services as well as special offers and marketing programmes which may be relevant to your preferences and profile;

(e) recommending, identifying and/or contacting you to inform you of products, services, special offers and rewards, either to our customers generally, or which we have identified may be of interest to you, or that are or may be relevant to you, in any case including on behalf of third parties, or sharing your personal data with such third parties or their service providers for them to collect, use, disclose or process your personal data for any of such purposes; and/or

(f) collection, use, disclosure and/or processing of customer data by us or our business partners for data monetisation purposes.


3.3 To the maximum extent permitted under applicable law, we may anonymise your personal data so that it no longer identifies you, in which case we shall be entitled to retain, use, disclose, and/or process such anonymised data without restriction.


3.4 These purposes may also apply even if you do not maintain any account(s) with us, or have terminated these account(s).


3.5 In order to comply with international sanctions and applicable regulations for securities and to fight money-laundering or the financing of terrorism, we (and/or our service providers) may need to check any personal data provided by you against information sources.


3.6 If you have provided us with your Singapore telephone number(s) and have consented to be contacted by telephone, we may contact you using your telephone number(s), subject to applicable laws.


DISCLOSURE OF PERSONAL DATA

4.1 We may also disclose your personal data for any of the purposes listed above to the following persons, whether located overseas or in Singapore:

(a) our service providers and contractors, including third party vendors that provide services to us, including, without limitation, IT-service providers, data processing or management services and for compliance with applicable laws and regulations;

(b) any business partner, investor, assignee or transferee (actual or prospective) to facilitate business asset transactions (which may extend to any merger, acquisition or asset sale);

(c) our partners (and in particular, where you have consented to receiving information/newsletters from us);

(d) law enforcement authorities, regulatory authorities, statutory bodies or public agencies for the purposes of complying with their requirements, policies, directives or requests;

(e) banks, credit agencies and other financial and/or payment service providers;

(f) our professional advisers such as our board of directors, auditors and lawyers;

(g) external business and charity partners in relation to corporate promotional events; and/or

(h) any other party to whom you authorise us to disclose your personal data to;


4.2 We may share information about you in aggregate or anonymised form with the abovementioned entities or parties (e.g. our business partners).


4.3 In relation to particular services or in your interactions with us, we may also have specifically notified you of other purposes for which we collect, use, disclose and/or process your personal data.


4.4 We also reserve the right to monitor, check and process your personal data if necessary to investigate or obtain evidence concerning any complain, claim or dispute or any actual or suspected illegal or unlawful conduct or to aid in such investigation or evidence gathering by any law enforcement or regulatory authorities.


DEEMED CONSENT

5.1 You shall be deemed to have consented to us collecting, using and/or disclosing your personal data:

(a) where in response to a request for your personal data in connection with identified purposes, you voluntarily provide such personal data to us for such purpose(s) and it is reasonable that you would voluntarily provide such personal data; and

(b) where the collection, use and/or disclosure of your personal data is reasonably necessary for the conclusion and/or performance of a contract, between you and us or any other organisation entered into at your request, which may include recipients of your personal data not indicated in this Privacy Statement.


OTHER BASES FOR HANDLING OR PROCESSING YOUR PERSONAL DATA

6.1 Where permitted by applicable law, we may also collect, use and/or disclose your personal data without consent as further detailed below:

(a) for our legitimate interests or the legitimate interests of another person, including for:

(i) any investigations or proceedings;

(ii) fraud detection and prevention; and

(iii) detection and prevention of misuse of services by users; and

(b) for improving our products, services, processes or business, understanding customer preferences and personalizing experiences and recommendations.


KEEPING YOUR PERSONAL DATA ACCURATE AND UP-TO-DATE

7.1 All personal data submitted to us should be complete, accurate, true and correct. Failure to do so may result in our inability to provide you with services you have requested and/or to process or administer the personal data.


IP ADDRESSES/COOKIES

8.1 When you use our Platform, we may collect and store information about your computer or other electronic devices (including your IP address, operating system and browser type) for system administration. This is statistical data about the browsing actions and patterns of users of our Platform. This data could possibly lead to your identification, but we, and our data intermediaries, do not use it to do so unless required to do so or otherwise authorised or permitted by law.


8.2 You acknowledge and agree that our Platform may include analytics code and other tools that may allow us to gather information on any use of any of our websites and platforms, and may include our use of cookies. Cookies are small files which are stored in your computer or other electronic devices when you access a website – amongst other things; they help the website user to navigate efficiently between pages and the website operator to track usage of the site. Some cookies we use are from third party companies to provide us with web analytics and intelligence about our Platform. These companies collect information about your interaction with our websites and platforms. We use such information to compile statistics about visitors who interact with the Platform, to gauge the effectiveness of our communications, to provide more pertinent information to our visitors, and for the purposes of security. Cookies cannot contain viruses or anything else that might harm your computer or other electronic devices. You can find out more about cookies at www.allaboutcookies.org.


8.3 We may use the following types of cookies on our Platform:

(a) Essential. Essential cookies are cookies that are necessary in order to enable our websites and platforms to operate, for example, cookies that enable you to log onto secure parts of our websites and platforms and to allow our Platform to function at its most efficient. Our website also uses cookies to distinguish you from other users of our Platform by storing information on how you use our Platform on your computer or other electronic devices, including without limitation which pages you view and how many times you visit our Platform.

(b) Performance. Such cookies make navigating our website easier for you. For example, cookies may be used to help speed up your future interactions with our website by remembering your preferences.

(c) Analytics. Cookies are used to gather statistics on how you navigate and perform transactions on our website. This would allow us to better tailor our products and services to your interests and needs. For example:

(i) cookies information may be identified and disclosed to our vendors and business partners to generate consumer insights;

(ii) cookies are used to automatically receive and record information on our server logs from your browser for the purposes of analysis, statistical and site-related information including, without limitation, information relating to how a visitor arrived at the website or platform, the browser used by a visitor, the operating system a visitor is using, a visitor’s IP address, and a visitor’s click stream information and time stamp (which may include for example, information about which pages they have viewed, the time the pages were accessed and the time spent per web page and other actions);

(iii) cookies are used to personalise the Platform for you, including delivering advertisements which may be of particular interest to you and using cookie related information to allow us to understand the effectiveness of our advertisements.

We also use web analytics services such as Google Analytics. The information that Google collects, why it is collected and how you may update, manage, export and delete your information is detailed in Google’s Privacy Policy available at https://policies.google.com/privacy . You may learn more how Google uses the information collected from us at https://policies.google.com/technologies/partner-sites , and the terms governing our use of Google Analytics at https://marketingplatform.google.com/about/analytics/terms/us/ . You may prevent your data from being used by Google Analytics by downloading and installing the Google Analytics Opt-out Browser Add-on at https://tools.google.com/dlpage/gaoptout/.


8.4 While some limited information is personally identifiable for the purposes of managing your experience on the website, any other information is anonymised and aggregated to produce statistical reports that enable us to evaluate the use of our website, and to make improvements to, and increase efficiency of your browsing on, our Platform.


8.5 We may also collect information about your precise or approximate location as determined through data such as your IP address or device’s GPS to offer you an improved user experience. Most mobile devices allow you to control or disable the use of location services for applications in the device’s settings menu. We may also collect this information even when you are not using the Platform if this connection is enabled through your settings or device permissions. We may also monitor, track and share with third parties your geo-location information obtained by our Platform for safety, security, technical, marketing and commercial purposes, including to provide and improve our products and services.


8.6 You can view and manage your cookie settings under the tab “Cookie Settings” on the Co-Axis website. If you wish to disable cookies on your computer or other electronic devices, you may do so by changing your browser settings. Unless you have adjusted your browser settings to block cookies, our system will issue cookies as soon as you visit our site or click on a link in a targeted email that we have sent you, even if you have previously deleted our cookies. Please note that changing these settings or deleting our cookies may limit the functionality of some web pages or prevent them from loading properly. Additionally, the major browsers have attempted to implement the draft “Do Not Track” (DNT) standard of the World Wide Web Consortium in their latest releases. As this standard has not been finalised, the website is not compatible with DNT and does not process DNT messages.


THIRD PARTY INFORMATION

9.1 Certain links contained on our Platform may direct you to co-branded websites maintained by us or to companies which we have established business relationships. When you submit information to one of these co-branded sites or partner companies, you may be submitting it to both us and these business partners. This Privacy Statement does not apply to any information that you may provide to third parties, such as through other sites linked to our website. We are not responsible for those sites and cannot control the content of what is offered on those sites, or links from those sites, or the privacy policy or data security, if any, of those sites, and you should read their respective privacy policies as they may differ from ours.


WHERE WE STORE YOUR PERSONAL DATA

10.1 The data that we collect from you may be transferred to, and stored at, locations outside of Singapore. It may also be processed by staff operating outside Singapore who work for us or for one of our service providers.


10.2 By submitting your personal data, you agree to this transfer, storing and processing. We will take appropriate steps to ensure that your data is treated securely and that the transfer of your personal data is in accordance with this Privacy Statement and applicable laws.


SECURITY

11.1 We use technical and organisational security precautions, including that of our data intermediaries, to protect your personal data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risk, as well as the loss of any storage medium or device on which personal data is stored. Our security procedures are reviewed on a regular basis based on new technological developments.


11.2 Notwithstanding the above, you acknowledge that there are inherent risks in the transmission of data over the internet and we cannot completely guarantee the security of any personal we may have collected from or about you, or that for example no harmful code will enter our Platform. We cannot ensure the security of the information you transmit to us via the Internet, and we urge you to take every precaution to protect your personal data when you use our Platform. We recommend that you change your passwords often, use a combination of letters and numbers, and ensure that you use a secure browser.


ACCESS/CORRECTION OF PERSONAL DATA OR WITHDRAWAL OF CONSENT

12.1 You have the right to request access to or correct your personal data, or to withdraw consent to our use of your personal data in accordance with applicable laws.


12.2 All requests for the withdrawal of consent, access to, or correction of personal data held by us shall be made via dpo@coaxis.network


CHANGES TO PRIVACY STATEMENT

13.1 We may update this Privacy Statement from time to time by posting the updated version on our website(s) and, where required by applicable law, notifying you of the same via other forms of communication. The revised version of this Privacy Statement will be effective once posted and you agree to be bound by the prevailing Privacy Statement as may be updated from time to time on our website or as you may be notified. Please review this page for updated information on our policies and practices regarding the handling of your personal data.


GOVERNING LAW

14.1 This Privacy Policy shall be governed in all respects by the laws of Singapore.


Effective Date: April 15, 2024

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