Privacy Policy

1. Consent to Collection of Information

Exchange International shall not, as a condition of providing services to you, require your consent to the collection, use, or disclosure of your personal data beyond what is reasonable to provide you with the services. As part of our continuous efforts to keep you informed on our new services, we may contact you via mail, email, telephone, SMS, or by any other means. You have the option to decline any or all of these communications by following the instructions included in these communications, or by contacting us directly at privacy@thinmargin.com.

Exchange International does not knowingly collect or solicit personal data from those below the age of 18, or knowingly allow such persons to register an account with Exchange International. If you are under the age of 18, please do not use the Website, or attempt to register an account or send any personal data to us.

2. Collection of Information

Exchange International may collect personal or non-personal information or data, including, without limitation, through web and data analytics, cookies, tracking technology, when you voluntarily submit information, or any other technologies, in accordance with the Personal Data Protection Act 2012 ("PDPA"). Information that you submit to us via the Website shall be deemed to be collected by us with your permission. Such information may include, but is not limited to, your full name, contact numbers, email addresses, home and/or addresses, date of birth, identification number and details, and any other information necessary for the provision of our services.

We will only be able to collect your personal information if you voluntarily submit the information to us. If you choose not to submit your personal information to us or subsequently withdraw your consent to our use of your personal information, we may not be able to provide you with our services. If you provide personal information of any third-party to us, we assume that you have obtained the required consent from the relevant third-party to share and transfer his/her personal information to us.

3. Use of Information

Exchange International uses personal or non-personal information or data for the primary purpose for which it was collected, for purposes where the individual has consented, to inform you about services that you request from Exchange International or that may interest you, where you have consented to be contacted for such purposes, to respond to your enquiry(s), to conduct analysis to maintain and/or improve the Website or Exchange International's services, to comply with all regulatory or legal obligations, or for any other purposes reasonably necessary or ancillary.

Exchange International may use your personal or non-personal information or data for some or all, but not limited to the following purposes and/or other purposes as notified to you or as permitted by law:

• to confirm your identity and ensure that you are eligible to access and use the services provided by Exchange International;
• to process your registration for the provision of our services;
• to process orders and transactions made by you;
• to respond to enquiries or requests from you and provide customer service;
• to send you information, notices, updates, or to otherwise contact you when necessary;
• to conduct know-your-customer (KYC) and anti-money-laundering (AML) screening procedures;
• to detect or investigate any prohibited, illicit, unauthorised, or fraudulent activities;
• to​ help us provide, maintain, develop, test, enhance, and personalise our services to you;
• to diagnose and resolve any problems or issues with our services;
• to generate and/or track anonymous analytics data;
• to back-up our systems and allow for disaster recovery;
• to comply with any law, court order or other legal compulsion.

4. Web-related Information

Exchange International may collect information from you via cookies without you actively providing the information when you access the Website. Cookies are small data text files stored in your local browser cache that send information about your previous visits to and activities on the Website. These cookies cannot be used to get data from your hard drive, to get any data that can be traced to you personally, and will not give Exchange International any personal information about you. Exchange International reserves the right to use the cookies to recognise your browser and thereby customise and optimise the Website to your preferences.

The Website uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses cookies to help analyse your use of the Website. The information generated by the cookies about your use of this Website (including your IP address) will be transmitted to a Google server and stored there. If you do not wish information about your behaviour at our Website or any mobile or web-based applications being collected and assessed by Google Analytics, you can install the Google Analytics opt-out browser add-on.

Exchange International may also collect your Internet Protocol (IP) addresses. Your Internet Service Provider allocates an IP address to your computer in order for it to access the Internet. The IP address is considered to be non-personal information and it may be dynamic (changing every time you connect to the Internet) or it may be static (unique to your computer). We collect your IP address in order to facilitate our administration and improvement of this site.

5. Disclosure of Information

Exchange International will not sell, rent, or license any personal data that we have collected from any individual. Exchange International does not disclose any personal data for any secondary purpose unless your consent has been granted or if permitted or required under the PDPA, or any other application laws or regulations. From time to time, we may collaborate with third parties to organise joint marketing and promotional campaigns, offers or contests, and may require disclosure of your information to such third parties.

6. Security

Exchange International has implemented and will continue to maintain security measures adequate to prevent the unauthorised collection, use, disclosure, copying, modification, and disposal of your information. Exchange International uses 256-bit SSL (secure sockets layer) encryption technology when processing your information. Nevertheless, you acknowledge and agree that any information transferred to Exchange International is done so at your own risk. Exchange International does not warrant or guarantee that the information you provide will not be assessed, copied, used, or disposed of in breach of Exchange International’s security measures, and you agree to waive Exchange International of any loss or damage resulting therefrom. You acknowledge and agree that you are responsible for keeping confidential your username and password to your account with Exchange International.

7. Third-party Links

Exchange International may provide links to third-party websites that may be of relevance and interest to you. This Privacy Policy does not apply to third-party websites you may access through, or in the course of your use of, this Website. Exchange International has no control over, and is not responsible for the privacy practices or the content of such linked third-party websites, and you hereby waive any claim against us with respect to these linked third-party websites.

8. Storage and Retention of Information

Information collected in accordance with this Privacy Policy may be transferred, stored, or processed outside of Singapore. Exchange International will comply with its obligations under the PDPA in relation to personal data transferred, stored, or processed outside Singapore for as long as the data remains in Exchange International’s possession or control during the transfer.

Exchange International will take appropriate steps to ensure that, the recipient of the personal data who is located outside Singapore is legally obliged to provide to the personal data a comparable standard of protection. However, if data needs to be transferred to or stored or processed in countries that have less stringent personal data protection laws than Singapore in order to provide you with the services you request, you are deemed to consent to such transfer, storage, or processing in providing your personal data to Exchange International during your use of the Website. You may at any time inform Exchange International that you wish to withdraw your consent to such transfer, storage, or processing of your personal data.

Exchange International will retain all information collected for as long as you continue to use the Website or Exchange International’s services. If you are a Member and terminate your Exchange International account, Exchange International will retain the information, including personal data, collected during your membership for as long as reasonably necessary for any business or legal purpose.

9. Access and Withdrawal of Personal Information

You may withdraw your consent to our continued use of your personal information or seek access to your personal information (to a reasonable extent as permitted by the PDPA) at any time by contacting us at privacy@thinmargin.com.In withdrawing your consent, you acknowledge and agree that we may not be able to provide or continue providing our services to you and that we may cease such provisions accordingly without any liability.

If you would like to view the personal information we have on you or inquire about the ways in which your personal information has been or may have been used or disclosed by Exchange International within the past year, please contact us at privacy@thinmargin.com. We reserve the right to charge a reasonable administrative fee for carrying out your request.

There may be circumstances where Exchange International will not amend, update, or delete your personal information where the personal information is opinion data that is kept solely for evaluative purposes, and/or the personal data is in documents related to a prosecution if all proceedings relating to the prosecution have not been completed, and/or as required by any government, statutory or regulatory authority, or to comply with any applicable law, court order, directive, or proceeding of such authority.

10. Changes to Privacy Policy

We reserve the right to make changes to this Privacy Policy from time to time, with or without any advance notice, and any changes will be posted on this page. Unless otherwise stated, Exchange International’s current Privacy Policy applies to all information that Exchange International has about you and/or your account.

11. Legal Jurisdiction

This Privacy Policy and your use of the Website shall be governed in all aspects by the laws of the Republic of Singapore. Any dispute arising out of or in connection with this Privacy Policy shall be subject to the exclusive jurisdiction of the courts of the Republic of Singapore.

12. Contact Us

If you have any questions about this Privacy Policy or Exchange International’s information collection, use and disclosure practices, or if you would like to access, amend, or delete any personal information we have about you, you may contact us at privacy@thinmargin.com.