1. Introduction

(1) At Finsights, we are committed to protecting and safeguarding the confidentiality of your personal data. This Privacy Policy (the “Policy”) describes what types of personal data we collect, how we collect, use, and manage them, and with whom we may share it. It also provides details about your rights with respect to the processing of your personal data and how you can exercise those rights.

(2) This Policy applies to the processing of your personal data in relation to your use of Finsights’ website and/or services.

(3) Finsights acts as the controller in relation to your personal data, which means that we are responsible for deciding why and how we process your personal data, in accordance with this Policy.

(4) When you access our website, use our services or any of the communication channels available to contact us, we consider that you have read and understood the terms of this Policy. By using our website and/or services, you agree that this Policy including any amendments, will govern how we collect, store, use and share your personal data and your respective rights. This Policy, together with the Cookie Policy, forms part of the General Terms of Use.

2. Information We Collect

(1) We may collect the following information:

name and contact information (e.g. phone number, email)
country of residence
recordings of electronic communication;
IP address, location data and other IT communication data, such type of device, browser version and operating system;
data related to the use of our website and applications, such as pages visited, links and button clicked, content viewed and time spent;
your preferences to certain types of products and services;

(2) We collect this information mainly from you, through the demo account registration, website cookies, subscriptions to newsletters, emails or additional information provided when you visit or use our website, register online, or communicate with us.

(3) We may also collect this information from other sources, which may include, analytics providers and publicly available sources (e.g. company registers, websites and social media)

3. Legal Basis for Processing

(1) In addition to the consents you have provided to our collection, use and disclosure of your personal data, we may also collect, use and disclose your personal data without your consent where permitted under applicable law for our legitimate interests or those of a third party, such as, business analysis and development and risk management processes.

(2) We may also share non-personal, non-identifiable information in aggregate form with third parties for business purposes or we may disclose to our business partners the number of customers in certain demographic groups.

4. Marketing

(1) It is in our legitimate interests to process your personal data to selectively contact you and/or send you information about our products, services, activities and/or events that may be relevant to you (“Marketing Communications”). You may opt-out of receiving Marketing Communications [by clicking on the unsubscribe link in the email communication or by contacting Finsights at dpo@tradingkey.com. In certain instances where Marketing Communications from us are sent to your mobile device, you will have to follow certain prescribed steps to discontinue to the receipt of marketing communications from us.

5. How We Use Your Information

(1) We may process your personal data for the following purposes:

to provide our services , [including access to a demo account or technical support];
to assess and improve the services provided;
to provide our services , [including access to a demo account or technical support];
respond to any queries you may have or to investigate your complaints;
to fulfill our legal or regulatory obligations;
defend ourselves against any disputes or litigation;
to perform data analysis to develop, expand and improve our website content and navigation;
to improve our services and enhance our customer service; and
to provide you with updates on our services and products, market news and other marketing communications. Note that you may opt out from any marketing communication [by clicking on the unsubscribe link in the email communication or by contacting Finsights at dpo@tradingkey.com.

(2) We also use an automated process to research and analyse how our website services are used via cookies, web beacons and other similar technologies and personalise our services.

6. Data Sharing

(1) Where necessary, to conduct our business as described above, we may disclose your personal data to the following:

any of our group companies or affiliates – to ensure the proper administration of the website and business;
our employees, agents and/or professional advisors – to ensure the adequate use of personal data;
service providers who provide services to us which require the processing of personal data, such as in , marketing services and analytics, cloud services, IT or other services – to help service providers in receipt of any shared data to perform functions on our behalf to ensure the smooth running of the website;
to government authorities, courts, law enforcement authorities, supervisory authorities, tax authorities - where required by law or in response to legal and regulatory requests;
to auditors or contractors or other advisers auditing, assisting with or advising on any of our business purposes;
to any third-party - where such disclosure is required in order to enforce or apply the terms and conditions stipulated in the General Terms of Use or other relevant agreements; and
anyone authorized by you.

(2) Unless otherwise required by a regulator, law enforcement or other government authority competent, we shall disclose personal data to third parties on a “need to know” basis. Additionally, we require from each and every third party that may have access to personal data to conform to our privacy standards and more specifically, we require all third parties to respect the security of personal data and information and to treat them in accordance with the applicable regulations and this Policy.

(3) If we transfer your personal data to countries outside Singapore, it will be done in accordance with the relevant provisions under Singapore laws and regulations. You acknowledge and consent to the transfer of your personal data to any member of our group or affiliates as well as third party service providers and agents outside of Singapore for one or more of the purposes described in this Policy.

7. Data Security and Retention

(1) We take reasonable steps and precautions to safeguard your personal data and maintain appropriate technical and organizational measures to ensure that any personal data provided to us are secured and protected from accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to personal data transmitted, stored or otherwise processed.

(2) We store client information in secure systems/database, which we monitor at all times, and we perform regular backups to mitigate any risk of inadvertent loss of information.

(3) We have a Data Protection Officer, responsible to ensure that our processes and procedures in regard to personal data are in accordance with this Policy and in compliance with data privacy laws.

(4) Technical and organizational measures include measures to deal with any suspected data breach. If you suspect any misuse or loss or unauthorized access to your personal data, please let us know immediately by contacting us at dpo@tradingkey.com.

(5) Unless a longer retention period is required or permitted by law, Finsights will retain your personal data for as long as necessary to fulfill the particular purpose for which it was collected. We may also retain aggregate information beyond this time for research purposes and to help us develop and improve our services. You cannot be identified from aggregate information retained or used for these purposes.

(6) Where information is no longer required to be held or retained by us for any purpose or legal obligation, we will take all reasonable steps to destroy or de-identify the information, accordingly. Even if we delete your personal data, it may persist on backup or archival media for legal, tax or regulatory purposes.

8. Cookies And Tracking Technologies

(1) Our website and app use cookies and other similar technologies (collectively referred as “Cookies”) to collect data from your device. Cookies are often used to improve your user experience, enable functionalities on the website and the app, facilitate security and provide the business with marketing information about the website’s and app visitors.

(2) We rely on your consent for using cookies, except from those which are essential for the smooth operation of the site or the app. You can reject cookies at any time by adjusting your browser’s or app settings; however, this may impact your ability to fully explore and utilize the features of our website or app.

(3) We use the following type of cookies:

(a) Necessary cookies also known as essential cookies, are used in order to ensure a smooth operation of our website or app and provide core functionalities. Due to the fact that these cookies are necessary, they cannot be turned off on your system;

(b) Statistics cookies are employed to analyse traffic and improve the navigation and performance of our website or app. They help us to understand which pages are most and least popular and see how visitors navigate the site. All information collected by these cookies is aggregated and processed anonymously.

(c) Preferences cookies enable us to provide enhanced functionality and personalization by remembering your preferences and choices you made in the past.

(d) Marketing cookies are used to collect information about the user’s behavior and preferences to deliver adverts that are more relevant to your interests. They are usually employed by third party advertising networks.

9. Links to non-Finsights websites

(1) The Finsights website may provide links to third-party websites for customer convenience and information. This Policy does not apply to other advertisers or websites. If you decide to access those links, you will leave the Finsights website. We do not control those third-party sites or their privacy practices, which may differ from Finsights’. You are advised to consult the respective privacy policies of these third party ad servers for more detailed information on their practices and how to opt-out of certain options.

(2) Third-party ad servers or ad networks use technologies like cookies, JavaScript, or web beacons that are used in their respective advertisements and links that may appear on the Finsights website, which are sent directly to your browser. They automatically receive your IP address when this occurs. These technologies are used to measure the effectiveness of their advertising campaigns and/or to personalize the advertising content that you see on websites you visit. We have no control over the cookies that are used by third party advertisers.

10. For Customers Who Are Resident in the European Union (EU)

(1) The personal data we collect from you may be transferred to and stored at a destination outside the European Economic Area (the “EEA”). In such cases, we will ensure that a similar degree of protection is afforded such as standard contractual clauses or other legal mechanisms that safeguard the security and confidentiality of your personal data during such transfers. In any case, we will employ all reasonable measures to guarantee the proper treatment of your data, consistent with the principles outlined in the present Policy.

(2) You have certain rights which are detailed below. Note however, that these rights may not apply in all circumstances:

Right to access: you have the right to request a copy of the personal data that we hold about you. This information is provided free of charge, except from cases where a request is manifestly unfounded, excessive or repetitive, or when receive a request to provide further copies of the same data. In such cases, we will send you a fee request which you will have to accept prior to us processing your request. Alternatively, we may refuse to comply with your request in these circumstances.
Right to rectification: you can request us to correct the personal data that we hold about you that may be inaccurate or incomplete;
Right of erasure: you may ask us to delete your personal data, if they are no longer needed for the purposes originally collected, or when you withdraw your consent or object to the processing, or when the processing was unlawful. Note, however, that your right for erasure does not apply when we are required to retain your personal data for legal or regulatory purposes;
Right to restrict processing: you can request us to suspend the processing of your personal data:

a. until we rectify any data that you contest its accuracy;
b. when our use is unlawful but you oppose deletion;
c. if we no longer need your personal data, but you need it to establish, exercise or defence legal claims; or
d. where you have objected to the processing, but we are verifying whether we have overriding legitimate grounds to use it.

Right to data portability: you can request the transfer of the personal data you provided to us, either to you or a third party, if this is technically feasible. We will transfer the data in a structured, commonly used and machine-readable format.
Right to object: you can object to the processing of your personal data, at any time:

a. on ground relating your particular situation, when the processing is based on our legitimate interests. However, we may be able to continue processing your personal data, if we can demonstrate compelling legitimate grounds for the processing, which override your interests, rights and freedoms or when the processing is for the establishment, exercise or defence of legal claims;
b. for direct marketing purposes, including profiling related to direct marketing. Where you have subscribed to our newsletters, market news and other promotional communications, you may opt out by clicking on the unsubscribe link in the email communication or by contacting Finsights at dpo@tradingkey.com.

Right to withdraw: you can withdraw your consent at any time, where we are relying on consent, to process your personal data. Note that if you withdraw your consent, we may not be able to provide certain products or services to you.
Rights relating to automated decision making and profiling: you have the right not to be subject to a decision based solely on automated processing, including profiling, if such decision has legal consequences for you or otherwise significantly affects you. This right shall not apply when the automated decision making is necessary for entering into, or performance of, a contract between us, or when is authorized by law, or is based on your explicit consent.
Right to lodge a complaint: If you are not satisfied with the way we address your requests or concerns, you may lodge a complaint to a EU supervisory authority.

How To Contact Us

If you have a query concerning this Policy or you wish to lodge a complaint or exercise any of the abovementioned rights, please send your requests to our Data Protection Officer at dpo@tradingkey.com or write to us at 9 Raffles Place, #17-01 Republic Plaza, Singapore 048619. We put our best efforts and aim to respond within 1 (one) month. In case your request takes longer than 1 (one) month, we will notify you accordingly and keep you updated.

We keep our Privacy Policy under regular review, therefore, this Policy may change at any time in the future. In the event of updates, the revised version will be posted on our website and you are deemed to have accepted any modifications to this Policy on the date of your first use of the website following the update.