Thank you for visiting the website of FlaXbit UAB (together with its affiliated entities, representatives and/or agents, “FlaXbit”, “we”, “us” or “our”).  We are committed to protecting the privacy and security of visitors to our website (the “Site”).  Please read this privacy policy (the “Privacy Policy”) carefully to understand generally how we collect personally identifying information about you and how we may use and disclose that personal information.

This Privacy Policy is part of and incorporated into the Terms and Conditions for the Site (“Terms and Conditions”), which govern your use of the Site. Please review the Terms and Conditions prior to using the Site. Capitalized terms used but not otherwise defined herein shall have the meanings ascribed to them in the Terms and Conditions.

USE OF OUR SITE OR PROVISION OF ANY PERSONAL INFORMATION CONSTITUTES AGREEMENT TO THIS PRIVACY POLICY.  PLEASE DO NOT USE THE SITE OR PROVIDE INFORMATION (OR ALLOW OTHERS TO DO SO ON YOUR BEHALF) IF YOU (AND YOUR PRINCIPAL IF YOU ARE ACTING AS AGENT) DO NOT AGREE WITH ALL OF THE TERMS OF USE INCLUDING THIS PRIVACY POLICY.

This Privacy Policy supplements but does not supersede nor replace any other consents you may have previously provided to FlaXbit in respect of your Personal Data, and your consents herein are additional to any rights which FlaXbit may have at law to collect, use or disclose your Personal Data.

FlaXbit may from time to time update this Privacy Policy to ensure that this Privacy Policy is consistent with our future developments, industry trends and/or any changes in legal or regulatory requirements. Subject to your rights at law, you agree to be bound by the prevailing terms of this Privacy Policy as updated from time to time on our website https://flaxbit.com/Article/detail/id/143. Please check back regularly for updated information on the handling of your Personal Data.

1.Personal Data

In this Privacy Policy, “Personal Data” refers to any data, whether true or not, about an individual who can be identified (a) from that data; or (b) from that data and other information to which we have or are likely to have access, including data in our records as may be updated from time to time.

Examples of such Personal Data you may provide to us include (depending on the nature of your interaction with us) your name, national identification number, passport or other identification number, telephone number(s), mailing address, email address, transactional data and any other information relating to any individuals which you have provided us in any forms you may have submitted to us (including in the form of biometric data), or via other forms of interaction with you.

2.Collection of Personal Data

• Generally, we collect Personal Data in the following ways:
  1. when you establish an account on the Site in order to get access to the Platform;
  2. when you use our electronic services, or interact with us via the Site or use services on the Site;
  3. when you submit any form, including but not limited to application, declaration, proposal or referral forms;
  4. when you enter into any agreement or provide other documentation or information in respect of your interactions with or transactions on the Platform;
  5. when you interact with our staff, including customer service officers, relationship managers and other representatives, for example, via telephone calls (which may be recorded), letters, fax, face-to-face meetings and email;
  6. when you request that we contact you, be included in an email or other mailing list; or when you respond to our request for additional Personal Data, our promotions and other initiatives;
  7. when you are contacted by, and respond to, our marketing representatives and agents and other service providers;
  8. when you submit an employment application or when you provide documents or information including your resume and/or curriculum vitae in connection with any appointment as an officer, director, representative or any other position;
  9. when we seek information about you and receive your Personal Data in connection with your relationship with us, including for banking products, insurance policies or job applications, for example, from business partners, public agencies, your ex-employer and the relevant authorities; and/or
  10. when you submit your Personal Data to us for any other reason.

When you browse our website, you generally do so anonymously but please see the section below on cookies.

• If you provide us with any Personal Data relating to a third party (e.g. information on your customers, spouse, children, parents, and/or employees), by submitting such information to us, you represent to us that you have obtained the consent of such third party to you providing us with their Personal Data for the respective purposes.
• You should ensure that all Personal Data submitted to us is complete, accurate, true and correct. Failure on your part to do so may result in our inability to provide you with products and services you have requested, including termination of your access to the Site and the Platform.

3.Purposes for the Collection, Use and Disclosure of Your Personal Data

• Generally, FlaXbit collects, uses and discloses your Personal Data for the following purposes:
  1. responding to, processing and handling your complaints, queries, requests, feedback and suggestions;
  2. verifying your identity;
  3. managing the administrative and business operations of FlaXbit and the Platform and complying with internal policies and procedures;

facilitating business asset transactions (which may extend to any mergers, acquisitions or asset sales) involving FlaXbit or any of its affiliates;

4. matching any Personal Data held which relates to you for any of the purposes listed herein;
5. requesting feedback or participation in surveys, as well as conducting market research and/or analysis for statistical, profiling or other purposes for us to design our products, understand customer behaviour, preferences and market trends, and to review, develop and improve the quality of our Platform and Services;
6. preventing, detecting and investigating crime, including fraud and money-laundering or terrorist financing, and analysing and managing commercial risks;
7. project management;
8. providing media announcements and responses;
9. organising promotional events;
10. in connection with any claims, actions or proceedings (including but not limited to drafting and reviewing documents, transaction documentation, obtaining legal advice, and facilitating dispute resolution), and/or protecting and enforcing our contractual and legal rights and obligations;
11. complying with any applicable rules, laws and regulations, codes of practice or guidelines or to assist in law enforcement and investigations by relevant authorities; and/or
12. any other purpose relating to any of the above.

These purposes may also apply even if you do not maintain any account(s) with us, or have terminated these account(s).

• In addition, where permitted under the applicable law, FlaXbit may also collect, use and disclose your Personal Data for the following purposes (which we may describe in our documents and agreements as “Additional Purposes” for the handling of Personal Data):
  1. providing or marketing services, products and benefits to you, including promotions, loyalty and reward programs;
  2. matching Personal Data with other data collected for other purposes and from other sources (including third parties) in connection with the provision or offering of products and services, whether by FlaXbit or other third parties;
  3. administering contests and competitions, and personalising your experience at FlaXbit’s touchpoints;
  4. sending you details of products, services, special offers and rewards, either to our customers generally, or which we have identified may be of interest to you; and/or
  5. conducting market research, understanding and analysing customer behaviour, location, preferences and demographics for us to offer you products and services as well as special offers and marketing programmes which may be relevant to your preferences and profile.
• If you have provided your telephone number(s) and have indicated that you consent to receiving marketing or promotional information via your telephone number(s), then from time to time, FlaXbit may contact you using such telephone number(s) (including via voice calls, text , fax or other means) with information about our products and services (including discounts and special offers).
• In relation to particular products or services or in your interactions with us, we may also have specifically notified you of other purposes for which we collect, use or disclose your Personal Data. If so, we will collect, use and disclose your Personal Data for these additional purposes as well, unless we have specifically notified you otherwise.

4.Disclosure of Personal Data

• FlaXbit will take reasonable steps to protect your Personal Data against unauthorised disclosure. Subject to the provisions of any applicable law, your Personal Data may be provided, for the purposes listed above (where applicable), to the following entities or parties:
  1. FlaXbit’s affiliates or related corporations;
  2. counterparties and their respective banks in relation to fund transfers, payments, drawing of cheques, and other transactions;
  3. agents, contractors or third party service providers who provide operational services to FlaXbit, such as courier services, telecommunications, information technology, payment, payroll, processing, training, market research, storage, archival, customer support investigation services or other services to FlaXbit;
  4. vendors or other third party service providers in connection with promotions and services offered by FlaXbit;
  5. credit reporting agencies;
  6. any business partner, investor, assignee or transferee (actual or prospective) to facilitate business asset transactions (which may extend to any merger, acquisition or any debt or asset sale) involving FlaXbit;
  7. external banks, credit card companies and their respective service providers;
  8. our co-brand and other business partners, to the extent applicable;
  9. our professional advisers such as our auditors and lawyers;
  10. relevant government regulators, government ministries, statutory boards or authorities and/or law enforcement agencies, whether local or overseas, including the Monetary Authority of Singapore, the Accounting and Corporate Regulatory Authority of Singapore, the Securities and Exchange Commission of the United States, and other applicable governmental agencies, to comply with any directions, laws, rules, guidelines, regulations or schemes issued or administered by any of them;
  11. surveyors, auctioneers, valuers or other third parties in relation to loans and other credit facilities such as mortgages;
  12. brokerage houses, Central Depository (Pte) Limited, fund houses, registrars, custodians, nominee banks, external banks and investment vehicles in relation to asset management and investment product settlement processing;
  13. to the extent applicable, any swap repository, trade data repository, reporting agent, clearing house, centralised clearing party (including any clearing member of such clearing house or centralised clearing party), clearing broker, multilateral or other trading facility, system or platform or such other communication network or auction facility; and/or
  14. any other party to whom you authorise us to disclose your Personal Data to.

5.Use of Cookies

• When you interact with us on the Site, we automatically receive and record information on our server logs from your browser. We may employ cookies in order for our server to recognize a return visitor as a unique user including, without limitation, monitoring information relating to how a visitor arrives at the website, what kind of browser a visitor is on, what operating system a visitor is using, a visitor’s IP address, and a visitor’s click stream information and time stamp (for example, which pages they have viewed, the time the pages were accessed and the time spent per web page).
• Cookies are small text files stored in your computing or other electronic devices which allow us to remember you or other data about you. The cookies placed by our server are readable only by us, and cookies cannot access, read or modify any other data on an electronic device. All web-browsers offer the option to refuse any cookie, and if you refuse our cookie then we do not gather any information on that visitor.
• Should you wish to disable the cookies associated with these technologies, you may do so by changing the setting on your browser. However, you may not be able to enter certain part(s) of the Site.

6.Data Security

• FlaXbit will take reasonable efforts to protect Personal Data in its possession or its control by making reasonable security arrangements to prevent unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks. However, we cannot completely guarantee the security of any Personal Data we may have collected from or about you, or that for example no harmful code will enter the Site (for example viruses, bugs, trojan horses, spyware or adware). We are not responsible for the intentional or criminal acts of third parties such as hackers or “phishers.” You should be aware of the risks associated with using the Site.
• While we strive to protect your Personal Data, we cannot ensure the security of the information you transmit to us via the Internet or when you access the Platform via mobile phones, and we urge you to take every precaution to protect your Personal Data when you use such platforms. We recommend that you change your passwords often, use a combination of letters and numbers, and ensure that you use a secure browser.
• If applicable, you undertake to keep your username and password secure and confidential and shall not disclose or permit it to be disclosed to any unauthorised person, and to inform us as soon as reasonably practicable if you know or suspect that someone else knows your username and password or believe the confidentiality of your username and password has been lost, stolen or compromised in any way or that actual or possible unauthorised transactions have taken place. We are not liable for any damages resulting from any security breaches, on unauthorised and/or fraudulent use of your username and password.

7.Third-Party Sites

• The Site may contain links to other websites operated by third parties. We are not responsible for the privacy practices of websites operated by third parties that are linked to the Site. We encourage you to learn about the privacy policies of such third party websites. Once you have left the Site, you should check the applicable privacy policy of the third party website to determine how they will handle any information they collect from you.

8.Contacting Us - Feedback, Withdrawal of Consent, Access and Correction of your Personal Data

• If you have any questions or feedback relating to your Personal Data or our Privacy Policy or if you want to withdraw your consent to any or all use of your Personal Data granted by you, you can email us at [email protected].
• If you withdraw your consent to any or all use of your Personal Data, depending on the nature of your request, FlaXbit may not be in a position to continue to provide its products or services to you, administer any contractual relationship already in place. This may also result in the termination of any agreements you have with FlaXbit, and your being in breach of your contractual obligations or undertakings. FlaXbit’s legal rights and remedies in such event are expressly reserved.

9.Governing Law and Arbitration

• This Privacy Policy and your use of this website shall be governed in all respects by the laws of Singapore.
• Any dispute arising out of or in connection with this Privacy Policy, including any question regarding its existence, validity or termination, shall be referred to and finally resolved by arbitration in Singapore in accordance with the Arbitration Rules of the Singapore International Arbitration Centre for the time being in force, which rules are deemed to be incorporated by reference in this clause. The dispute shall be resolved by one (1) arbitrator appointed by the parties. If the parties cannot agree on one (1) arbitrator, the dispute shall be resolved by three (3) arbitrators, one (1) appointed by FlaXbit, one (1) appointed by you and the third appointed by the first two (2) arbitrators. The arbitration proceedings shall be conducted in English. Any award is final and may be enforced in any court of competent jurisdiction. The award shall apportion the costs of arbitration. The parties shall duly and punctually perform their obligations hereunder pending issuance of the arbitral award. 

10.Effective Time

The effective date of this Privacy Policy was February 27, 2024.