1. Overview
Xfers Pte. Ltd. ("XfersTrade", "we", "us") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your personal data when you use our services.
We comply with the Personal Data Protection Act 2012 (PDPA) of Singapore and other applicable data protection laws.
2. Information We Collect
2.1 Personal Information
We collect the following types of personal information:
- Identity Data: Full name, date of birth, nationality, government ID numbers
- Contact Data: Email address, phone number, residential address
- Financial Data: Bank account details, payment card information, trading history
- Identity Documents: Passport, national ID, driver's license, proof of address
- Employment Data: Occupation, employer, source of funds
2.2 Technical Information
We automatically collect:
- IP address and device information
- Browser type and version
- Operating system
- Login timestamps and session data
- Platform usage patterns
3. How We Use Your Information
We use your personal data for:
- Account Management: Creating and managing your trading account
- KYC/AML Compliance: Verifying your identity and preventing fraud
- Service Delivery: Processing transactions and providing customer support
- Communications: Sending important updates, marketing (with consent)
- Legal Compliance: Meeting regulatory requirements and reporting obligations
- Security: Detecting and preventing unauthorized access or fraud
- Improvement: Analyzing usage to improve our services
4. Information Sharing
We may share your information with:
- Regulatory Authorities: MAS, tax authorities, law enforcement when required
- Service Providers: Payment processors, identity verification services, cloud providers
- Professional Advisors: Lawyers, auditors, consultants under confidentiality obligations
- Business Partners: With your consent, for joint services or promotions
We do not sell your personal data to third parties.
5. Data Security
We implement comprehensive security measures including:
- 256-bit SSL encryption for all data transmission
- Multi-factor authentication
- Regular security audits and penetration testing
- Employee access controls and training
- Secure data centers with physical security
- Incident response procedures
6. Data Retention
We retain your personal data for:
- Active Accounts: Duration of your account relationship
- Closed Accounts: Minimum 7 years after closure (regulatory requirement)
- Marketing Data: Until you withdraw consent
- Technical Logs: Up to 2 years
7. Your Rights
Under applicable laws, you have the right to:
- Access: Request a copy of your personal data
- Correction: Request correction of inaccurate data
- Deletion: Request deletion where legally permitted
- Withdrawal: Withdraw consent for marketing communications
- Portability: Request data in a portable format
- Objection: Object to certain processing activities
To exercise these rights, contact our Data Protection Officer at dpo@xferstrade.com
8. International Transfers
Your data may be transferred to and processed in countries outside Singapore. We ensure appropriate safeguards are in place, including:
- Standard contractual clauses
- Adequacy decisions
- Binding corporate rules
9. Changes to This Policy
We may update this Privacy Policy from time to time. We will notify you of significant changes via email or through our Platform. Continued use of our services after changes indicates acceptance of the updated policy.