Privacy Policy of Singapore Bullion Market Association (“SBMA”)

1. INCORPORATION OF TERMS AND CONFIDENTIALITY OF PERSONAL DATA

1.1

The SBMA respects the confidentiality of your personal data and wants you to know what information about you it collects, and what it does with that information.

1.2

By providing personal data, you consent to the use of your information by SBMA and its agents, subcontractors and representatives as described herein and in the Terms and Conditions of Use of the SBMA (the “Terms”). The Terms set out detailed information about the services and materials provided by SBMA. Capitalized terms that are used in this Privacy Policy which are not otherwise defined herein have the same definition given to them in the Terms.

2. INFORMATION THAT MAY BE COLLECTED

2.1

While you are not required to register or give us any personal information about yourself in order to visit the SBMA Website and/or to view certain parts or features that have been made generally available to you on our Website, you acknowledge and agree that this may change and SBMA may in the future or in certain circumstances require you to register or give us personal information in order for you to access parts of the SBMA Website. However, only SBMA members may access Other Materials. In order to do so, an SBMA member will have to register for an Account with SBMA. Certain information would be required in order to register for an Account, such information may include certain personal information about you, including your first and last name, your profession, the country in which you reside, your email address, your phone number etc….

2.2

In addition, where you sign up for any seminars or events on the SBMA website either organised by the SBMA or by other associations or entities, you may be required to provide information regarding your credit card, your billing address and other related personal details to a third party service provider or vendor such as event organisers and payment processors. For the purpose of processing your payment when you sign up for such seminars or events, you agree that your information may be transferred by SBMA to such a third party service provider or vendor which in turn may transfer your information to another jurisdiction for the purposes of processing payment or similar. If you agree, your credit card and personal information may be archived in the database of a third party service provider or vendor to facilitate your checkout process for future transactions.

2.3

SBMA will only activate the Account and provide access to Other Materials if it is of the view that there are no discrepancies, ambiguity, or contradiction in the information submitted by you. For the avoidance of doubt, SBMA is not obliged or required to check the information submitted for any discrepancy, ambiguity or contradiction. SBMA may at its sole and absolute discretion suspend or discontinue an Account Holder’s access to the Account or the provision of, or modify, all or any of the Other Materials without giving any reason.

2.4

SBMA may collect certain information about your use of the Website or the Services. SBMA may collect information including but not limited to those concerning the type of browser you use, the type of computer operating system you use, your IP address, your connection speed, the domain name of your Internet service provider, the geographic location from which you are accessing our Services and/or the website or advertisement from which you linked to the Website.

2.5

If you use a mobile device like a tablet or phone to access the Website or the Services, SBMA may access, collect, monitor, store on your device, or remotely store one or more “device identifiers.” Device identifiers are small data files or similar data structures stored on or associated with your mobile device, which uniquely identify your mobile device. SBMA may also track and collect information about you, including your Website usage patterns, such as the pages on the Website you have visited, searches you have conducted and the amount of time you have spent on the Website.

2.6

Any personal data provided by you or communications sent by you to SBMA through the Website may be kept for our records or for any such use as may be deemed necessary or appropriate by SBMA, and for as long as it deems fit or as may be required by applicable laws.

3. USE OF INFORMATION COLLECTED

3.1

Information collected may be used, both by SBMA and by our authorized third party service providers, to collect, discover, and prepare aggregate statistical and volume information, and other similar data, including with respect to the number, characteristics, behavior, of visitors to the Website, (collectively, “Aggregate Site Information”). SBMA may use, and permit our authorized third party vendors or service providers to use this Aggregate Site Information in order to administer the Website, for research purposes to further develop, improve and promote SBMA and the Website, to improve visitor experience, to manage the Services, track visitor behavior and for other purposes as described in this privacy policy from time to time and which are not prohibited by applicable law.

3.2

In order to keep you informed about the Services, you agree that the SBMA may from time to time send you notices, announcements, alerts or any other information by way of emails, postal mail, facsimile transmissions, SMS or other text messages, voice calls or any other forms of communication,

3.3

SBMA will not forward, disclose, share, sell or rent your personal data to third-party organizations, except as in circumstances required by any applicable law or as otherwise described herein. Exceptions of disclosure and sharing of personal data may include, but are not limited to legitimate interests of relevant law enforcement authorities in relation to any sanction program (such as an embargo, trade prohibition) adopted by Singapore, ASEAN, the European Union, the United Kingdom, the United States and the United Nations.

4. SECURITY OF INFORMATION COLLECTED

4.1

Information collected by SBMA may be stored in servers in Singapore and/or other countries that may have different levels of privacy protection. To the extent allowed by any applicable law, you consent to such transfer and processing of the information in such other countries.

4.2

SBMA will use reasonable measures and to the extent permitted by applicable law to maintain the security of all information collected against any loss, theft, unauthorised use, disclosure, or modification and to ensure the integrity of the information.

5. COOKIES

5.1

Cookies are small text files that a website sends to your web browser. They are then stored on your computer. Cookies enable a website to collect information about you such as your browsing behaviour on the website or your preferred language, in order to improve your browsing experience and the functionalities of the website.

5.2

SBMA may install cookies on your computer or mobile device to improve your browsing experience. You agree for SBMA to install cookies on your computer or mobile device in this regard.

6. ACCESS AND UPDATING INFORMATION

6.1

You may request to access, review, rectify or delete any personal information collected by SBMA at [email protected]. While SBMA will make reasonable efforts to accommodate your request, to the extent allowed by applicable law, SBMA reserves the right to impose certain restrictions and requirements on such access request.

6.2

You may also withdraw consent to your personal data being collected, used or disclosed by the SBMA. In this case, generally your Account registered with the SBMA will be terminated and you will cease to have access to the Other Materials.