This website is made available for use by TradeGo Pte Ltd ("TradeGo", "we", "us", "our") having its registered office at 7 Temasek Boulevard, #10-01/02 Suntec Tower One, Singapore 038987. We are a data controller for the purpose of Data Protection Legislation (as defined below).
In this Privacy and Cookies Policy, references to "you" and "your" are references to a user of our website, mobile application(s), official social media platforms or other media resources that TradeGo operates on (our "Site(s)").
Introduction
We are committed to protecting and respecting your privacy and handling your information in an open and transparent manner.
This policy ("Privacy and Cookies Policy") explains what information we collect from you, or that you provide to us, what we will use it for and with whom we share that information. The policy also sets out your rights and who you can contact for more information. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
In this Privacy and Cookies Policy, your information is sometimes called "personal data". We may also sometimes collectively refer to handling, collecting, protecting and storing your personal data as "processing" such personal data.
In this Privacy and Cookies Policy the term "Data Protection Legislation" means all applicable legislation relating to privacy or data protection in force from time to time, including any statute or statutory provision which amends, extends, implements, consolidates or replaces the same, and in particular to the extent applicable and without limitation the EU General Data Protection Regulation 2016/679 (“GDPR”), the GDPR as it forms part of the domestic law of the United Kingdom by virtue of the European Union (Withdrawal) Act 2018 and the Data Protection Act 2018. The terms “personal data”, “controller", and “process” (and its derivatives) shall have the meanings given to them in the Data Protection Legislation.
What personal information do we collect you and how do we use it?
We may collect and process information relating to you (which includes personal data) in order to provide and improve our services to you. We shall process any information we collect in accordance with Data Protection Legislation and the provisions of this Privacy and Cookies Policy.
We may collect, record and use information about you in physical and electronic form and will hold, use and otherwise process the data in accordance with the Data Protection Legislation and as set out in this Privacy and Cookies Policy.
The personal data we collect and process may include:
your name;
your identity card number;
your contact information such as your email address and telephone number (or any telephone number used to call our customer services);
your postings in relation to the services that we provide;
your IP address, your browser type and language;
your payment details / financial data i.e. your bank name, account number and sort code;
your job title and employer organisation;
information about your visit to our website, including the full Uniform Resource Locators (URL), clickstream to, through and from our website (including date and time), length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs) and methods used to browse away from the page; and
your cookie data (Please see our sections on cookies for more information).
How we collect information about you
Information you give to us when you use our services. If you use our services you will need to provide certain information including your name, address and e-mail address.
Other information you give to us. This is information about you that you give us by filling in forms on our Sites (e.g. the contact us section or to sign up to our newsletter) or by corresponding with us by phone, e-mail or otherwise. It includes information you provide when you register on the Site for us to contact you, and when you report a problem with our Site. The information you give us may include your name and e-mail.
Information we collect about you. With regard to each of your visits to our Site we will automatically collect certain information e.g. your IP address used to connect your computer to the Internet.
How we use cookies
TradeGo uses cookies and other similar technologies (such as beacons, tags and scripts) on your device to obtain information about how you access and use the Sites. This helps us to provide you with a good experience and allows us to improve the Sites.
Cookies are text files containing small amounts of information which are stored on your computer or other device when you visit a Site. Cookies are then sent back to the originating Site during your browsing session or on each subsequent visit, or to another Site that recognises that cookie. The cookies we set do lots of different jobs, like help us to improve the Site and deliver a better and more personalised service, remember your preferences, and generally improve the user experience. You can find more information about cookies at http://www.allaboutcookies.org/.
We use the following cookies:
Strictly necessary cookies – These are cookies that are essential for the Site to function, including to use its features and enable the services you have specifically asked for, and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms.
Performance or analytical cookies – These are cookies which collect information about how users use the Site (for example, by recording which pages or features users use most often (on an anonymous basis)). This helps us improve the way the Site works, for example, by ensuring that users are finding what they are looking for easily.
Functionality cookies - These are cookies which are used to recognise you when you return to the Site. This enables us to provide personalise our content for you, greet you by name and remember your preferences (for example, user name or choice of language or region).
Targeting or advertising cookies - These are cookies which record your visit to our Site, the pages you have visited and the links you have followed. They collect information about a user's browsing habits and are usually placed by our advertising partners with our permission. We will use this information to make our Site and the advertising displayed on it more relevant to your interests. Where the cookies are set by such third parties, we have no direct control over the information that is collected by these cookies. If you do not allow these cookies, you will experience less targeted advertising.
Security cookies – These are cookies which we use to authenticate users, prevent fraudulent usage of login credentials and protect your data. We use these cookies to help identify and prevent potential security risks.
Cookies can also be categorised in accordance with how long they are saved on your device: "session cookies" are short-term cookies that are only saved on the device's memory for the duration of a user's visit to the Site, whereas "persistent cookies" remain saved in the device's memory for a set period of time being thirty (30) days, even after the browser session has ended.
How we use your information
Our primary purpose in collecting user information is to provide you with a safe, smooth, efficient, and customised experience and to provide the services you have requested. We may also use the information that you have provided to ensure that the content on our Site is presented in the most effective manner for you and your computer.
We use your information for the following specific purposes:
in relation to obligations arising from the TradeGo User Agreement entered into between you and us (the "TradeGo User Agreement") and to provide you with the information and services that you request from us;
to notify you about changes to our services;
to ensure that content from our Site is presented in the most effective manner for you and for your computer;
to administer our Site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
as part of our efforts to keep our Site safe and secure;
to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
to improve the services provided on the Site;
to send you our newsletter or updates, or to make suggestions and recommendations to you and other users of our Site about services that may interest you or them; and provide you or them with targeted marketing in relation to our services (unless you or they indicate at any time that you or they do not wish us to do so); and
When requesting material or asking someone to contact you, you will have the option to request other information that may be of interest.
Legal grounds for using your personal information
The law permits us to process your personal data in the way that it does because the processing is:
necessary for the purposes of the legitimate interests that we pursue, which are to run and administer our business, to discharge our legal obligations to store and disclose information where necessary, to evaluate, develop and improve our services, to prevent fraud, to ensure that complaints are investigated and to keep our client's informed about relevant services; and/or
necessary for the performance of the TradeGo User Agreement; and/or
necessary in order to comply with a legal obligation to which we are subject.
Sharing your information
The following categories of recipients may receive your personal information and process it for the purposes outlined in this Privacy and Cookies Policy:
We may disclose data to provide our services, to respond to legal requirements, enforce our policies, and protect our rights and property.
The personal information you provide to us may also be shared with third party companies, agents, contractors, service providers or related companies (including payment processors) if this is necessary to provide you with our services, respond to your inquiries or for any other related purposes.
We may also share your personal information with:
other TradeGo related entities;
other companies we have instructed to provide services for us (including but not limited to professional advisory services);
analytics and search engine providers that may assist us in the improvement and optimisation of our Site;
third parties who support our information technology or handle mailings or events on our behalf;
law enforcement agencies, other governmental agencies or third parties if we are required by law to do so, or in other limited circumstances (for example if required by a court order or regulatory authority, or if we believe that such action is necessary to prevent fraud or cyber-crime or to protect the Site, our technology assets or the rights, property or personal safety of any person);
other third parties for those purposes that may be reasonably ascertained from the circumstances in which the information was submitted;
other business entities should we plan to merge with or be acquired by that business entity, or if we undergo a re-organisation with that entity; and
any successor in interest, in the event of a liquidation or administration of TradeGo.
TradeGo does not undertake marketing activities for third parties, nor does it provide information to third parties for their own marketing purposes.
Links to Other Sites
The Site contains links to other websites. TradeGo is not responsible for the privacy policies of third party websites to which links are provided. You should check the privacy policies on these sites before providing any personal information. This privacy statement relates only to information contained on, or gathered via, the Site.
How we protect your information
We take your online security seriously and have implemented generally accepted standards of technology and operational security to protect your personal information from loss, misuse, alteration or destruction. Once we have received your information we will ensure that the collection and use of your information is in accordance with Data Protection Legislation. All personnel of TradeGo are required to keep personal information confidential and only authorised persons have access to such information.
Please note, however, that the transmission of information via the Internet is not completely secure and we cannot guarantee the security of your personal information transmitted to us or provided though the Site.
How long we keep your information
We will only keep the information we collect about you, through your use of the Site or otherwise, for as long as required for the purposes set out above or as required to comply with any legal obligations to which we are subject. This will involve us regularly reviewing our files to check that information is accurate, up-to-date and still required.
International data transfers
Data that you submit via our website is sent to and stored on secure servers owned by or operated for us. Your personal data may be transferred to, and processed outside, the country in which you are resident. These other jurisdictions may have data protection laws that are different from the laws of your country (and, in some cases, not as protective). Such transfers may be made in order to improve the Site or to assist in our security or fraud protection activities.
When we, or our permitted third parties, transfer your information we implement appropriate safeguards to protect your personal information in accordance with this Privacy and Cookies Policy.
In some jurisdictions, international transfers may take place when there is an adequate level of protection to the fundamental right of individuals to data protection. In some circumstances, we may choose to rely upon an adequacy decision to lawfully transfer personal information. Standard contractual clauses are one of several mechanisms that allow for personal information to be transferred across jurisdictional borders and we rely on these for transfers to and from our affiliates, vendors and business partners where applicable. Additional safeguards may also be implemented where personal information is transferred. Please contact us to request a copy of our appropriate safeguards.
Opting out
You have the option of "unsubscribing" from our mailing list for newsletters, alerts and updates at any time, thereby disabling any further such e-mail communication from being sent to you.
Details of how to unsubscribe will be included on each electronic mailing we send you. Alternatively, just send an email to legal@tradego.com with "URGENT – UNSUBSCRIBE REQUEST" in the subject line and the email address that you wish to be removed within the email.
We will action any opt out request from you without delay, and in any event within one month.
Your rights
At any time, you have the right:
to be informed about the processing of your personal data (i.e. for what purposes, what types, to what recipients it is disclosed, storage periods, any third party sources from it was obtained, confirmation of whether we undertake automated decision-making, including profiling, and the logic, significance and envisaged consequences);
to request access to or a copy of any personal data which we hold about you;
to rectification of your personal data, if you consider that it is inaccurate;
to ask us to delete your personal data, if you consider that we do not have the right to hold it;
to withdraw consent to our processing of your personal data (to the extent such processing is based on previously obtained consent);
to ask us to stop or start sending you marketing messages (e.g. our newsletter) at any time by using the below contact details;
to restrict processing of your personal data;
to data portability (moving some of your personal data elsewhere) in certain circumstances;
to object to your personal data being processed in certain circumstances; and
to not to be subject to a decision based on automated processing and to have safeguards put in place if you are being profiled based on your personal data.
Any request for access to or a copy of your personal data must be in writing and we will endeavour to respond within a reasonable period and in any event within one month in compliance with Data Protection Legislation. We will comply with our legal obligations as regards your rights as a data subject.
We will correct any incorrect or incomplete information and will stop processing your personal data, or erase it, where there is no legal reason for us to continue to hold or use that information.
We aim to ensure that the information we hold about you is accurate at all times. To assist us in ensuring that your information is up to date, do let us know if any of your personal details change.
Refusing or restricting cookies
You can choose to accept or decline all cookies we can set by clicking this link. Do note however that strictly necessary cookies are always active.
You can also set your browser to refuse all or some browser cookies. The "Help" or "Internet Settings" functions within your browser should tell you how. Alternatively, you may wish to visit http://www.allaboutcookies.org/ which contains detailed information on cookies and how to delete, restrict or block them on a wide variety of browsers. For information on how to do this on the browser of your mobile phone you will need to refer to your handset manual.
If you refuse, disable or restrict cookies, please note that you may be unable to access certain parts of the Site or some parts of the Site may not function properly.
Privacy of Minors
Services provided by us are not available to anyone under the age of 18 ("Minors"). We do not knowingly collect personal data from Minors. If you are a parent or guardian and you are aware that your child has provided personal data to us, please contact us. If it comes to our attention that personal data of a Minor has been collected without parental consent, we will take steps to remove that information from its servers.
Changes to this Privacy and Cookies Policy
Any changes we make to our Privacy and Cookies Policy in the future will be posted on this page of the Site and, where appropriate, notified to you by e-mail.
We would encourage users to check the Privacy and Cookies Policy each time they use the Site. If our Privacy and Cookies Policy changes in any way, we will place an updated version on this page. Changes to this Privacy and Cookies Policy are effective upon posting on this page or otherwise upon notifying users in writing. Regularly reviewing this page ensures that you are always aware of what information we collect, how we use it and under what circumstances, if any, we will share it with other parties.
Contacting us
Questions, comments and requests regarding this Privacy and Cookies Policy are welcomed and should be addressed to TradeGo. You may also use these contact details if you wish to make a complaint to us relating to your privacy.
If you have any concerns about our use of your information, you also have the right to make a complaint to your local privacy regulator or data protection authority.
Version: 14 February 2024