PRIVACY POLICY

DATED: March 15, 2019

Oxford Capital Markets Pte Ltd (hereinafter – Oxford) has a long-standing commitment to safeguard the privacy of information entrusted to us by our clients. Protecting the confidentiality and security of such information is an integral part of how we conduct our business worldwide. We pledge to continue to ensure that your privacy is protected.

We respect your Privacy

In the course of serving you as an individual or as someone associated with a corporation or institution, Oxford may collect, hold, use and/or disclose information received, which may constitute personal data, where applicable and in accordance to personal data laws in relevant jurisdictions.

Unless advised otherwise, all references to Oxford, “we”, or “our” in this Privacy Policy includes, individually and collectively, Oxford that process personal data in the relevant jurisdiction. You may, however, in connection with specific products or services offered by Oxford, be provided with privacy policies or statements that supplement this Privacy Policy.

This Privacy Policy describes:

What personal data we collect;

How we collect your personal data;

The purposes for which we use your personal data;

Monitoring;

When we disclose your personal data;

How we protect the security and confidentiality of your personal data;

Your rights under relevant jurisdiction Data Protection Laws;

How we update this Privacy Statement; and

How you can contact us;

Please read this Privacy Policy carefully to understand how we process your personal data.

What Personal Data do we collect?

If you deal with Oxford as a private client or otherwise in your individual capacity, then typically we collect the following types of personal data about you:

Personal details such as name, age, occupation and marital status;

Contact details such as address, telephone, email, in some cases both private and work related contact details.

Please note that the types of personal data information mentioned above are not exhaustive and we may require further information from you where applicable.

Of course, you are not obligated to supply any of the personal data that we may request. However, failure to supply any of the personal data that we may request may result in our being unable to provide services to you or your company, discuss any other opportunities with you and/or deal with you on any other matter related to our services.

While we make every effort to ensure that all information furnished to us are accurate, complete and up to date, you can help us considerably in this regard by promptly notifying us if there are any changes to your personal data. We shall not be responsible for the authenticity of any personal data or sensitive personal data or any losses arising from any inaccurate or deficient personal data that you supply to us.

How do we collect your Personal Data?

The personal data we collect from you come primarily from information that you submit to us during the course of your relationship with us. We obtain your personal data from the application form and documents submitted by you when you register with us, from your transactions with us, from your access to or use of our products and services or from third parties authorized to provide us with such information. We also collect personal data when we monitor or record our communications with you or through use of certain technology as detailed further below.

What are the purposes for which we use your Personal Data?

We may process and use your personal data to:

In the course of the operational support and development of our businesses;

To contact you about other services and products we offer;

To exercise and defend our legal rights;

For any other legitimate business purposes; and

As otherwise permitted under relevant applicable law and/or regulation.

Monitoring

Oxford will record and/or monitor communications such as email, instant messaging, post, facsimile, telephone and any other means of communications, not specifically mentioned herein, with you and/or your agent(s) to the extent permissible under the applicable law for legitimate business purposes and for purposes permitted by law from time to time, including without limitation:

to safe guard against any unauthorized and unlawful conduct;

nvestigating or detecting unauthorised use of our systems and other materials (e.g., monitoring to ensure compliance with our policies and procedures and to evaluate the quality of customer service);

for security or health and safety purposes; and/or

support, training and administration purposes.

When do we Disclose Personal Data we collect about you?

You should know that:

Oxford does not sell, rent, trade your personal data; and

Oxford does not disclose your personal data, except as abovementioned in this Privacy Policy.

Our processing and use of your personal data, for the purposes specified in this Privacy Policy, may include disclosure of your personal data for the following activity(ies):

To other persons processing your personal data on our behalf or otherwise providing us or them with professional or other services;

To third parties such as banks or exchange to whom we disclose in the course of providing products and services to you;

To persons to whom we assign or novate our rights or obligations.

These disclosures may involve overseas storage and other overseas transfer, processing and use of your personal data, and disclosure to these third parties, including in or to countries or territories which do not offer the same level of protection of personal data as may be enjoyed within your home country.

How do we Protect the Security and Confidentiality of your Personal Data we collect about you?

Oxford maintains appropriate physical, technical and procedural safeguards to protect any information that you provide to us from accidental or unauthorised loss, misuse, damage, modification, access and/or disclosure.

Oxford has established an information security system to:

Safeguard the confidentiality and privacy of information resources;

Properly classify information resources;

Meet legal and regulatory obligations concerning the protection of information resources;

Implement and maintain information security policies and procedures;

Integrate protection of information resources into the process lifecycles of the business;

Educate those working for or on behalf of Oxford on policies and responsibilities; and

Authenticate users and limit access to information resources based on authorization that has been granted.

Third parties who process your personal data on our behalf are required to adhere to appropriate security standards to protect such information against unauthorised access, destruction, loss and/or disclosure.

What rights do you have?

If you wish to access a copy of your personal data or you wish to modify any personal data which we hold about you, or you want us to cease processing any of your personal data held by us, subject to applicable law, you can do so by written request to Oxford.

In the case of a request for access to personal data, we reserve the right to request for a valid means of identification as a security precaution to assist us in preventing any unauthorized disclosure of your personal data. We will process your request within a reasonable time.

How do we update this Privacy Policy?

We may change and/or update portions of this Privacy Policy to reflect changes in our practices and/or applicable law and regulation. Please check this Privacy Policy from time to time so you are aware of any changes or updates to the Privacy Policy, which may be indicated by a change in the effective date noted at the beginning of the Privacy Policy. We shall not be held responsible and/or liable for not giving prior notice to any change and/or update made to this Privacy Policy.

How can you Contact Us?

If you would like to contact us in respect of any element of this Privacy Policy, including, without limitation and subject to applicable law, where you wish to access a copy of your personal data or where you wish to raise a complaint or grievance please contact us by filling up “Contact Us” form contained on the website.