Privacy Notice

1. ABOUT THIS POLICY

1.1. This is the Privacy Policy for JERA Global Markets Pte. Ltd. (a company incorporated in Singapore and operating at 88 Market Street, #22-01, Singapore 048948) (hereinafter, referred to as “JERAGM”, “us”, “we” or “our”).

1.2. This Privacy Policy describes how we may collect, use, disclose and process your personal data when you:

1.2.1. access or use our Website (www.jeragm.com); and /or

1.2.2. provide us with your personal data through, or in connection with, your access or use of our Website.

1.3. We will only use your personal data where you have given us your consent or where we have another lawful basis for doing so, and in the manner set out in this Privacy Policy.

1.4. By providing us with your personal data, you acknowledge that our collection, use, disclosure and processing of your personal data will be in accordance with this Privacy Policy including, for the avoidance of doubt, the cross-jurisdictional transfer of your personal data.

1.5. This Privacy Policy supplements but does not supersede or replace any consents that you may have provided to us, or any other agreements or arrangements that you may have with us, in respect of your personal data.

1.6. Our Website may contain links to other websites that are not owned or maintained by us. These links are provided for your convenience only. You may also be accessing our Website through third party websites or platforms. When visiting these third party websites or platforms, their respective privacy policies apply. This Privacy Policy only applies to our Website.

1.7. If you have any feedback or issues in relation to your personal data or about this Privacy Policy or wish to make a complaint to us, you may contact our Data Protection Officer at:

E-mail Address: DataProtection@jeragm.com

Regulation of the European Union (“EU”) applies to you, you also have a right to lodge a complaint with a European supervisory authority, in particular in the Member State in the EU where you are habitually resident, where you work or where an alleged infringement of data protection law has taken place.

When you contact us, we may require that you submit certain forms or provide certain information, including verification of your identity, before we are able to respond to you.

2. AMENDMENTS TO THIS PRIVACY POLICY

2.1. We may amend this Privacy Policy from time to time without notice to you, in compliance with applicable laws or as we update our data usage and handling processes. The updated Privacy Policy will supersede earlier versions and will apply to personal data provided to us  previously. The updated Privacy Policy will take effect when made available on www.jeragm.com/privacy-notice. If we make a change that significantly affects your rights or,  to the extent we are permitted to do so, significantly changes how or why or for which  purposes we use personal data, we will notify you by way of a prominent notice on our  website or, if we have your e-mail address, by e-mail.

3. WHAT PERSONAL DATA WE COLLECT

3.1. What is personal data. “Personal data” is data that can be used to identify a natural person. Examples of personal data that we collect and process include your name, telephone number, e-mail address, information from your interactions with our Website (e.g. IP address) and any other information of a personal nature. 

3.2. Voluntary provision of personal data. We may collect personal data that you voluntarily provide to us. Please see paragraph 4 on “How We Collect Personal Data” for further details. What personal data we collect depends on the purposes for which the personal data is collected and what personal data you have chosen to provide us.

When our collection is based on consent, you can choose not to provide us with your personal data. You also have the right to withdraw your consent for us to continue collecting, using, disclosing and processing your personal data, by contacting us in accordance with paragraph 1.7 . However, if you do so, it may not be possible for us to fulfil the purposes for which we require the personal data, including processing your transactions or providing you with the products and services that you have requested or require. 

3.3. Providing personal data belonging to others. In certain circumstances, you may provide us with personal data of persons other than yourself. If you do so, you represent and warrant that you have brought this Privacy Policy to his / her attention, informed him / her of the purposes for which we are collecting his / her personal data and that he / she has consented to your disclosure of his / her personal data to us for those purposes and accepts this Privacy Policy. You agree to indemnify and hold us harmless from and against any and all claims by such individuals relating to our collection, lawful use, disclosure and other processing of such personal data in accordance with the terms of this Privacy Policy. 

3.4. Accuracy and completeness of personal data. You are responsible for ensuring that all personal data that you provide to us is true, accurate and complete. You are responsible for informing us of any changes to your personal data. 

3.5. Minors. Our Website is not intended to be accessed or used by children, minors or persons who are not of legal age. If you are a parent or guardian and you have reason to believe your child or ward has provided us with their personal data without your consent, please contact us in accordance with paragraph 1.7 .

4. HOW WE COLLECT PERSONAL DATA

4.1. Personal data collected from you. We collect personal data that is relevant to your access and / or use of our Website, or when you do provide us with your personal data through, or in connection with, your access or use of our Website. We may collect your personal data directly or indirectly through various channels, such as when you request that we contact you through various communication channels such as through the “Contact Us” page on our Website, social media platforms, messenger platforms, telephone calls, e-mails, fax or letters.

5. WHAT WE DO WITH YOUR PERSONAL DATA

5.1. What we do. We collect, use, disclose and process your personal data where:

5.1.1. you have given us consent;

5.1.2. necessary to comply with our legal or regulatory obligations under applicable laws, such as responding to valid requests from public authorities;

5.1.3. necessary to support our legitimate business interests (please refer to paragraph 5.3 ), provided that your interests or rights do not override such interests; and

5.1.4. necessary to perform a transaction you have entered into with us or provide a service that you have requested or require from us.

5.2. General purposes. We collect, use, disclose and process your personal data for purposes connected or relevant to our business, and / or to manage your relationship with us. Such purposes include:

5.2.1. carrying out your transactions with us and our business partners, taking steps as may be directed by you, or to provide products and / or services to you;

5.2.2. facilitating your access and use of our Website;

5.2.3. communicating with you, and assisting you with your queries, requests, applications, complaints, and feedback;

5.2.4. resolving any disputes, investigating any complaint, claim or dispute or any actual or suspected illegal or unlawful conduct;

5.2.5. carrying out research and statistical analysis, including development of new products and services or evaluation and improvement of our existing products and services;

5.2.6. security purposes, such as protecting our Website from unauthorised access or usage and to monitor for security threats;

5.2.7. compliance with any legal or regulatory obligations, applicable laws, regulations, codes of practices, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and / or regulatory authority;

5.2.8. performing data analytics and related technologies on data, to enable us to deliver relevant content and information to you and to improve our Website and other platforms;

5.2.9. managing and engaging third parties or data processors that provide services to us, including IT services, technological services, delivery services, and other professional services; and

5.2.10. other purposes that may be informed to you when your personal data is collected. Where personal data is used for a new purpose and where required under applicable law, we shall obtain your consent.

5.3. Legitimate business interests. We may also collect, use, disclose and process your personal data for the following purposes to support our legitimate business interests, provided that your interests or rights do not override such interests. Our legitimate business interests include:

5.3.1. managing our business and relationship with you;

5.3.2. protecting our rights and interests, such as defending a legal claim made by, against or otherwise involving you; and

5.3.3. enforcing obligations owed to us or protecting ourselves from legal liability.

5.4. Marketing purposes. In order for us to market products, events and / or services which are of specific interest and relevance to you, we may analyse and rely on your personal data provided to us or data collected from your interactions with us. However, no marketing will be carried out unless you have provided us with your consent to use your personal data for such marketing purposes. If you do not want us to use your personal data for the purposes of marketing, you can withdraw your consent at any time by contacting us in accordance with paragraph 1.7 .

5.5. Use permitted under applicable laws. We may also collect, use, disclose and process your personal data for other purposes where this is required or permitted by law. Your personal data may, for example, be processed if it is necessary on reasonable request by a law enforcement or regulatory authority, body or agency or for the defence of a legal claim.

5.6. Contacting you. When we contact or send you information for the above purposes and purposes for which you have consented, we may do so by post, e-mail, SMS, telephone or such other means provided by you. If you do not wish to receive any communication or information from us, or wish to restrict the manner by which we may contact or send you information, you may contact us in accordance with paragraph 1.7 .

6. USE OF AUTOMATED DATA COLLECTION TECHNOLOGIES

6.1. Cookies. In order to improve our products or services, we collect data by way of “cookies”. A cookie is a small file of letters and numbers that we store via your browser on the hard drive of your computer or mobile device. There are three main types of cookies:

6.1.1. Session cookies: these cookies are specific to a particular visit and limited to sending session identifiers (random numbers generated by the server) so you do not have to re-enter information when you navigate to a new page or check out. Session cookies are not permanently stored on your device and are deleted when the browser closes;

6.1.2. Persistent cookies: these cookies record information about your preferences and are stored in your browser cache or mobile device; and

6.1.3. Third party cookies: these cookies are placed by someone other than us which may gather data across multiple websites or sessions.

6.2. How we use cookies. We use cookies for the following purposes:

6.2.1. Strictly necessary: these cookies are essential for you to browse our Website and use its features. The information collected relates to the operation of the Website (e.g. website scripting language and security tokens) and enables us to provide you with the service that you have requested.

6.2.2. Functionality: these cookies remember the choices that you have made, for example the country you visit our Website from, your language and any changes you have made to text size and other parts of the web pages that you can customise to improve your user experience and to make your visits more tailored and enjoyable.

6.2.3. Performance / analytics: these cookies collect information on how users use our Website, for example which pages you visit most often, whether you receive any error messages and how you arrived at our Website. Information collected by these cookies is used only to improve your use of our Website. These cookies are sometimes placed by third party providers of web traffic and analysis services.

6.2.4. Targeting or advertising: these cookies collect information about your browsing habits and inferred interests to make advertising more relevant to you. They are also used to limit the number of times you see an advert as well as to measure the effectiveness of an advertising campaign. These cookies are usually placed by third party advertising networks. They remember the websites you visit, and this information is shared with third party organisations such as advertisers.

6.2.5. Social Media: these cookies allow users to share our website content on social media such as Facebook and Twitter. These cookies are not within our control. Please refer to the respective privacy policies of the social media providers for how their cookies work. 

We may also automatically collect and store certain information about your interaction with our Website, including IP address, browser type, internet service provider, referring/exit pages, operating system, date/time stamps and related data.

6.3. Other technologies. In addition to cookies, we use some other similar technologies, such as:6.3.1. Web Beacons: these are small graphic images included on our Website or e-mails or those of third parties to provide analytics information.

6.3.2. Social widgets: these are buttons or icons provided by third party social media networks which may collect browsing data and will be received by the third party and are controlled by the third party.

6.3.3. SDKs: these are mobile application third party software development kits used in our apps. They enable us to collect information about app activity and the device it runs on.

6.3.4. Local shared objects: these are sometimes called flash cookies and can be stored on your browser. They are used to maintain preferences and usage records.

6.4. Refusing or deleting cookies. Most internet browsers are set up by default to accept cookies. However, you can decide to reject or delete such cookies in the following ways:

6.4.1. When you visit our Website, a Cookie Consent Manager in the form of a pop-up window will be presented to you. In this Cookie Consent Manager, you may accept or reject the cookies.

6.4.2. To delete cookies, please refer to the help and support area on your browser for instructions on how to delete them (e.g. on Internet Explorer, Google Chrome, Mozilla Firefox and Safari).

Please note that you may not be able to take advantage of all the features of our Website, including certain personalised features, should you choose to reject or delete cookies. 

6.5. Mobile Opt-out. If you access our Website through mobile devices, you can enable a “do not track” feature so as to control interest-based advertising on an iOS or Android mobile device by selecting the Limit Add Tracking option in the privacy section of your Settings on iOS or via advertising preferences on Android devices (e.g. in Google Settings). This will not prevent the display of advertisements but will mean that they will no longer be personalised to your interests.

6.6. If you are a resident in the EU. For more information on managing cookies, please visit www.youronlinechoices.eu and www.aboutcookies.org. These links have further information about behavioural advertising and online privacy.

6.7. Changes to our uses of cookies. If we change anything important about this paragraph 6 on cookies, we will notify you through a pop-up on our Website for a reasonable length of time prior to and following the change. You may review this paragraph by visiting www.jeragm.com/privacy-notice.

7. DISCLOSURE OF PERSONAL DATA

7.1. Disclosure to third parties. We may also disclose your personal data to third parties for purposes described in paragraph 5 . In general, your personal data is shared with or disclosed to the following categories of third parties for the purposes described below:

For the avoidance of doubt, the types of third parties / services providers described above are non-exhaustive and we may disclose or share your personal data with other third parties or services providers for the purposes described in paragraph 5.

7.2. When disclosing personal data to third parties, we will enter into contracts with these third parties to protect your personal data in a manner that is consistent with all applicable laws and /or ensure that they only process your personal data in accordance with our instructions.

8. TRANSFER OF PERSONAL DATA TO OTHER COUNTRIES

8.1. Transfers. We may transfer your personal data to different jurisdictions in connection with the purposes described in paragraph 5 and 7 :

8.1.1. from the jurisdiction where it is collected (which is usually where you are located) to any other jurisdictions that we operate in; and

8.1.2. to third parties in other jurisdictions.

8.2. Safeguards. Where we transfer your personal data across jurisdictions, we will ensure that your personal data is protected in accordance with this Privacy Policy and applicable laws regardless of the jurisdictions they are transferred to, but in any event to a level that is no less stringent than the jurisdiction from which the personal data is transferred and the data protection law that applies to you. When we transfer your personal data and where required by applicable law, such as under the GDPR, we will put in place appropriate safeguards including EU Standard Contractual Clauses or rely on the EU Commission’s adequacy decisions. You may obtain details of these safeguards by contacting us in accordance with paragraph 1.7 .

9. SECURITY AND RETENTION OF PERSONAL DATA

9.1. Unauthorised access. While we take reasonable precautions to safeguard your personal data in our possession or under our control, to the maximum extent permitted by applicable laws, you agree not to hold us liable or responsible for any loss or damage resulting from unauthorised or unintended access that is beyond our control, such as hacking or cybercrimes.

9.2. Vulnerabilities. To the maximum extent permitted by applicable laws, we do not make any warranty, guarantee, or representation that your use of our Website is safe and protected from malware and other vulnerabilities. To the maximum extent permitted by applicable laws, we also do not guarantee the security of data that you choose to send us electronically. Sending such data is entirely at your own risk.

9.3. Period of retention. We retain your personal data only for as long as is necessary to fulfil the purposes we collected it for, and to satisfy our business and/or legal purposes, including data analytics, audit, accounting or reporting purposes. How long we keep your personal data depends on the nature of the data. For example, we keep personal data for at least the duration of the limitation period for bringing claims if the personal data may be required to commence or defend legal proceedings. Some information may also be retained for longer, in particular where we are required to do so by law.

9.4. Anonymised data. In some circumstances we may anonymise your personal data so that it can no longer be associated with you, in which case we are entitled to retain and use such data without restriction under data protection law.

10. YOUR RIGHTS

10.1. Rights you may enjoy. Depending on the jurisdiction that you are in or where we operate, you may enjoy certain rights under applicable law in relation to our collection, use, disclosure and processing of your personal data. Such rights may include:

10.1.1. Access: you may request access to a copy of and information on the personal data that we hold about you.

10.1.2. Correction: you may request that any incomplete or inaccurate personal data that we hold about you is completed or corrected.

10.1.3. Erasure: you may ask us to delete or remove personal data that we hold about you in certain circumstances.

10.1.4. Restriction: you may ask us to restrict or suspend the processing of your personal data if statutory prerequisites apply, such as if you want us to establish its accuracy.

10.1.5. Portability: you may request to receive the data provided by you in a structured, commonly used and machine-readable format and to have such data transferred to another party, to the extent that this is technically feasible, under certain conditions

10.1.6. Withdrawal of consent: you may withdraw your consent to our collection, use, disclosure or processing of your personal data at any time, without giving reasons and with effect from the date of withdrawal. The withdrawal of your consent will not affect the lawfulness of the processing of your personal data based on your consent before your consent was withdrawn.

10.1.7. Objection: where we are processing your personal data based on our legitimate interests or those of a third party, you may object to the processing on this ground. 

If you wish to exercise any of your rights, you may contact us in accordance with paragraph 1.7 . We may require that you submit certain forms or provide certain information to process your request. Where permitted by law, we may also charge you a fee to process your request.

10.2. Limitations. We may be permitted under applicable laws to refuse a request. For example, we may refuse: (a) a request for erasure where the personal data is required for in connection with legal claims; or (b) an objection request and continue processing your personal data based on compelling legitimate grounds for the processing.