PRIVACY & DATA PROTECTION POLICY

(Updated: October 2017)

We at WandX Pte. Ltd. (the “Company”, “we”, “us”, or “our”) recognise theimportance of safeguarding the “personal data” of the user (the “User”, “you”, or “your”) as defined under Singapore’s Personal Data Protection Act 2012 (No. 26 of 2012) (the “PDPA”), and take our responsibility to manage, protect and process your personal data seriously.

This Privacy & Data Protection Policy (“Policy”) outlines the Company’s practices in relation to the collection, storage, use, processing and disclosure of your personal data through your interactions with the Company’s Services (as defined in the Company’s Website Terms of Service), websites, applications, platforms, programmes, servers, and/or software including the following properties which are owned and operated by us:

  • websites including https://wandx.co/ (the “Website”) and the associated WandX platform (the “Platform”) and servers; and
  • all other properties which reference this Policy in a link or otherwise.

This Policy sets out the following:

  • The types of personal data being collected and the sources from which the Company collects such personal data;
  • The purposes for collection, use and disclosure of personal data;
  • Disclosure of personal data;
  • Care of personal data (accuracy, protection, retention and transfer); and
  • Care of personal data (accuracy, protection, retention and transfer); and The process by which the Company receives and responds to any feedback that may arise with respect to the collection, storage, use, processing and disclosure of personal data.

Capitalised words in the Policy shall have the same meaning ascribed to them in the Terms of Service (“TOS”), available at https://wandx.co/, specifically Clause 1(b) therein.

Please read this Policy carefully, and should you have any queries about how we may manage, protect, or process your personal data, please do not hesitate to contact our Data Protection Officer, whose details are included in Clause 13. By continuing to use the Website, Platform and our Services, you are deemed to have consented to the terms of this Policy. Please notify us and stop using our Website, Platform and Services immediately if you do not consent to this Policy.

  1. COLLECTION OF PERSONAL DATA AND OTHER USER INFORMATION,AND THE PURPOSES OF SUCH COLLECTION
    • Non-Personal Data: Non-Personal Data: If the User chooses to use the Website, Platform and Services, the User consents to allowing the Company to collect information about the User’s activity and trends through the Website, Platform and Services. Such information may include your browser’s name and technical information about your means of connection to our Website, Platform and Services, in particular the operating system and the internet service providers used among other similar information. This information is aggregated to provide statistical data about our users' browsing actions and patterns, and does not personally identify individuals.
    • Personal Data:
      • The User expressly agrees and acknowledges that the Company shall collect and store the User’s personal data including but not limited to the User’s username, passwords, email address, name, address, age, date of birth, sex, nationality, browsing history within the Website, identity verification information, such as images of your government issued ID, passport, national ID card, or driving licence, account information, such as username and password, and financial information, such as bank account numbers, bank statement, and trading information etc.
      • The Company uses your personal data to provide you with the Services and to operate its business. We may also use the data collected to communicate with you, for example, to inform you about new product features, security updates, or to inform you about your account. Your personal data may also be used to show you more relevant information, content, advertisements, whether through the Company’s own products or third-party applications and in combination with information from other sources.
      • Examples of how the Company uses your personal data include:
        • to process, record, monitor and fulfil your transactions or requests;
        • facilitating the Company’s provision of the Services through the Website, Platform or otherwise; communicating with you for research, marketing, advertising and
        • communicating with you for research, marketing, advertising and promotional purposes; administrative matters regarding the User account;
        • administrative matters regarding the User account;
        • diagnosis and maintenance of our Website, Platform, or Services; maintaining the security of our Website, Platform, or Services; or
        • such other purposes notified to you from time to time.
      • The User is aware that any and all information pertaining to the User collected by the Company, whether or not directly provided by the User to the Company (via the Website or otherwise), including but not limited to personal correspondence such as emails or letters, instructions from the User relating to the Services, or communications between the User and other users, may be collected and compiled by the Company and the User hereby expressly consents to the same.
      • The way your personal data is used will depend on the circumstances at hand, and it will be used in compliance with applicable laws and regulations.
    • Cookies: Cookies: The Company shall collect de-identified information by way of ‘cookies’. Cookies are small data files which are sent to the User’s browser from the Website and are stored on the User’s computer or device (hard drive). The cookies shall not provide access to data in the User’s computer or device (hard drive), such as email address or any other data that can be traced to the User personally. The data collected by way of cookies will allow the Company to administer the Website and provide a tailored and user-friendly service to the Users. Information collected from cookies is used by the Company to evaluate the effectiveness of the Website, analyse trends, and administer the Platform. The information collected from cookies allows the Company to determine such things as which parts of the Website are most visited, and difficulties visitors may experience in accessing the Website. With this knowledge, the Company aims to improve the quality of the User’s experience on the Platform by recognising and delivering the most desired features and information. In addition to cookies, the Company also uses a technology known as web bugs or clear gifs, which are typically stored in emails to help confirm receipt of, and response to, the emails sent by the Company and to provide the User with a personalised experience while accessing the Website.


      The cookies shall enable the Users to access certain features or services of the Website. Most web browsers and devices can be set to notify when a User receives a cookie or to prevent cookies from being sent. If the User limits the use of cookies, it may limit the functionality that the Company can provide when a User visits the Website.
    • Purpose for which personal data is collected: The Company will handle personal data appropriately, in line with the circumstances. If any intended use of personal data will likely go beyond the purposes envisioned during collection, the Company will notify Users of the new purpose(s) and seek consent to use their personal data for such purpose(s).
    • Retention, Administration & Management:
      • We will take reasonable efforts to ensure that your personal data is accurate and complete, based on the information that you have provided us with. Please ensure that all information provided to us is up to date and keep us informed of any relevant changes.
      • The User is aware that personal data may continue to be stored and retained by the Company for a reasonable period under applicable law and until it is no longer necessary for any other legal or business purposes (whichever is later).
      • Where your personal data is to be transferred out of Singapore or such other jurisdiction in which it is collected, we shall take reasonable steps to ascertain that the recipient of the personal data is bound by legally enforceable obligations to protect your personal data in accordance with this Privacy Policy and the PDPA.
  2. DISCLOSUREOF PERSONAL INFORMATION TO THIRD PARTIES
    • The User acknowledges that to enable the provision of the Website, Platform and Services to the User, it may be necessary in certain circumstances for the Company to share the User’s personal data with third parties such as affiliates of the Company, or any third parties engaged by the Company to provide Services and features targeted at the User, that are most likely to meet the User’s needs, and to customize and improve the Website and the general experiences of its users, including for any research or analysis of the data collected.
    • In general, the Company will not disclose your personal data except in accordance with the following:
      • in order to carry out the purposes for which such personal data was collected;
      • where the User has consented;
      • where disclosure is clearly in the User’s interests, and if User consent cannot be obtained in a timely way;
      • where permitted under the PDPA or other applicable law; or
      • if required by applicable law.
    • Where we disclose your personal data to third parties, we will employ our best efforts to require such third parties to protect your personal data.
    • Except as otherwise stated in this Policy or the TOS, the Company shall not sell or license to any third parties any personal data that it collects from a User.
  3. THIRD PARTY USER EXPERIENCE IMPROVEMENT SERVICES
    • The Company uses third party services (including but not limited to those provided by Google, Inc. or its affiliates, for instance Google Analytics) and applications to better understand the behaviour of the Users of the Website.
    • The information collected in relation to a User for such purpose may include (but is not limited to):
      • name;
      • email address;
      • gender;
      • interests; and
      • orders
    • A User’s relationship with these third parties and their services and tools is independent of the User’s relationship with the Company. These third parties may allow the User to permit or restrict the information that is collected and it may be in the User’s interest to individually restrict or enable such data collections.
    • The place of processing depends on each third party service provider and the User may wish to check the privacy policy of each of these service providers to identify how much data is shared, to whom and for what purposes.
  4. THIRD PARTY AUTHENTICATION SERVICES
    • The Company uses third party authentication services. In such cases, the Company may be privy to, granted access to or store, certain data available to it with these third parties for registration and identification purposes.
    • The place of processing depends on each third party service provider and you may wish to check the privacy policy of each of these service providers to identify how much data is shared, to whom and for what purposes.
  5. THIRD PARTY STORAGE
    • The Company and the Website uses international web hosting facilities and cloud server services which are maintained in accordance with tight security standards and applicable laws.
  6. EXPORT OF PERSONAL DATA
    • We store and process your information which may include your personal data in data centres around the world, wherever the service providers are located. As such, we may transfer your personal data outside Singapore. Such transfers are undertaken in accordance with all relevant applicable laws and regulatory obligations including the PDPA.
    • Further to Clause 6(a) above, third parties processing your personal data either on our behalf or otherwise may be located in a different country from the point of collection of your personal data (e.g. transfer to overseas servers), or may have multiple physical locations and backups (e.g. cloud based services).
    • By using the Company’s Website, Platform and Services, you agree that the transfer of your personal data to various countries is reasonably necessary for us to provide you with these tools, products and services.
  7. USER PROFILES
    • A User's profile page may be, by default, set up to display information such as the User's display name, images, location (city/state/country), groups that the User has joined and optional information added by the User. Profile information is used by the Company primarily to be presented back to and edited by the User when the User accesses the Website and to be presented to other users of the Website permitted to view that information on the Website. The Company may offer Users the ability to manage their public profile and use profile preference settings as explained on the Platform's profile preferences, the functionality and features of which are subject to change from time-to-time. The Company recommends that its Users do not post information or content as part of their profile that Users are not willing to make public. Changing setting options may not result in immediate changes to the settings, which are subject to the Company’s operations and maintenance schedules.
  8. SECURITY MEASURES
    • The Company implements certain security measures including encryption, firewalls and secure socket layer technology to protect the User’s personal data from unauthorised access. However, the User agrees and acknowledges that the above-mentioned measures do not guarantee absolute protection and by accessing the Services, the User agrees to assume all risks associated with disclosure of personal data arising due to breach of firewalls and secure server software.
    • All financially sensitive or credit information is transmitted via secure socket layer technology and encrypted in our database. Only authorised personnel of the Company are permitted access to your personal data, and these personnel are required to treat the information as highly confidential. The Company undertakes to review the security measures from time to time in light of new and relevant legal and technical developments and in accordance with applicable laws and regulations including the PDPA.
  9. BUSINESS TRANSITIONS
    • The User is aware that in the event the Company goes through a business transition, such as a merger, acquisition by another organisation, or sale of all or a portion of its assets, the User’s personal data might be among the assets transferred as a result of the business transition.
  10. REQUEST FOR ACCESS AND/OR CORRECTION OF PERSONAL DATA
    • You may request access to or correct the personal data held by us by submitting a written request at any time to the Data Protection Officer at [email protected] We may require further information from you to verify your identity as well as the nature of your request. Handling and processing fees may be payable before we can proceed with your request. Once we have sufficient information to deal with your request, we will seek to provide you with the relevant personal data or information within 30 days of your request, unless otherwise stated.
  11. REQUEST TO WITHDRAW CONSENT
    • Should you wish to withdraw your consent to the Company’s use of your personal data, please stop using our Website, Platform and Services immediately and notify us in writing at [email protected] to inform us that you wish for us to stop collecting, using or sharing your personal data and we will process your request within a reasonable time from such a request. You may also elect to withdraw your consent to the use of your personal data for a specific purpose, so please ensure that your notification contains sufficient and specific information to enable us to comply with your request.
    • However, your withdrawal of consent could result in certain legal consequences arising from such withdrawal. In this regard, depending on the extent of your withdrawal of consent for us to process your personal data, it may mean that we will not be able to continue with your existing relationship with us.
  12. UPDATES TO THIS POLICY
    • As part of our efforts to ensure that we properly manage, protect and process your personal data, we will be reviewing our policies, procedures and processes. The Company reserves its right to revise, modify and update this Policy at any time, without prior notice, at the sole discretion of the Company. The Company undertakes to notify the Users on the Website in the event the Policy is revised and make available the revised Policy. Any revised Policy will be posted on our Website, and can be accessed at https://wandx.co/. You are encouraged to visit the Website from time to time to ensure that you are well informed of our latest policies in relation to personal data protection.
  13. QUERIES
    • If you have questions or concerns about the Policy, you may contact us at:

    • Data Protection Officer
    • WandX Pte. Ltd.
    • Address: 17 Phillip Street, #05-01, Grand Building, Singapore 048695
    • Email: [email protected]