1.  Privacy

This Privacy and Cookies Policy forms part of our website Terms & Conditions. It explains how we will use your personal information should that be collected through this Website. In addition, it explains how we use cookies.

You may contact us at support@mtradeapp.com if you have any questions about this Policy. We may change it from time to time by updating this page.

Other sites linking to or from this Website will have their own privacy policies and we are not responsible for the privacy practices of the relevant operators.

2.  Personal information collected

We may typically collect the following information about you through this Website. This is not a definitive list and details may change from time to time:

• Your name and contact details, including email address, postal address, mobile and fixed

line telephone numbers

• On advisor sites, your job title, business contact details, the charitable body, private investor, corporate entity or other person or institution you represent for investment purposes and/or to whom you provide financial advisory services.
• Log in details and pin numbers and/or passwords as necessary to set up and administer

registered user accounts.

• Payment card details as necessary to facilitate your online
• Investment products and related services which are of interest to you, as relevant to your

direct marketing preferences.

• All personal information about you as may be contained in free text boxes, including in

relation to enquiries or comments submitted to us through this Website.

3.  Purposes

We may typically use your personal information for the following purposes. This is not a definitive list and may change from time to time:

• For our internal business administration and record keeping
• To provide you with information about our investment products and related services, to facilitate your online purchases and for all other administration as may be necessary in relation to the supply of our investment products and related services and the conduct of our investment management business.
• With your consent, for direct marketing purposes (for further details see “Direct Marketing and Managing Your Preferences” below).
• To respond to your enquiries or comments submitted through this

• Where necessary as part of any restructuring relating to MSR Capital Pte Ltd (the Company) and its business or assets, or as part of a sale of the Company or, as relevant, another company in the Company Investments group, or its/their assets.
• For legal and regulatory compliance purposes, including as necessary to respond to governmental, regulatory or law enforcement agency requests; to ensure the continuing security and integrity of our systems, business dealings, reputation or the security and reputation of the Company and its staff; to identify misuse of the Company’s systems and any fraud or other illegal or unlawful activity or any other activity which is or may be contrary to our legal and regulatory compliance obligations.
• As may otherwise be necessary for responsible corporate governance or as otherwise

required or permitted by applicable laws and/or regulations.

4.  Data disclosures and data sharing

Your personal information may be shared as necessary with our service providers. They may be retained, for example, to provide services in relation to administration, direct marketing; website hosting and management; data storage and back up; and such other services as may be relevant to our business from time to time. This includes disclosures to any person or company to whom we delegate responsibility for the administration, operation and/or maintenance of this Website. In addition, we may disclose your personal information:

• In response to a court order, request for cooperation from a law enforcement or other government agency; to establish or exercise legal rights; to bring or defend legal claims; as may necessary for responsible corporate governance or as otherwise required or permitted by applicable laws and/or regulations;
• In circumstances in which we believe disclosure is appropriate in connection with fraud prevention and prevention of other illegal or unlawful activity or any other activity which is or may be contrary to our legal and regulatory compliance obligations; to protect and defend the rights, property or safety of the Company and/or other companies in the Company Investments group, its/their investors and other clients, staff, and/or service providers; responsible corporate governance or compliance with applicable laws and/or regulations.
• To buyers in the event of any restructuring relating to the Company and its business or assets, or as part of a sale of the Company or, as relevant, other companies in the Company Investments group, or its/their assets.

5.  Data transfers

Your personal information may be transferred outside your own country. In particular, your personal information may be transferred to other countries. The Company will seek to ensure your personal information is protected in those other countries or territories in accordance with applicable data privacy law.

6.  Retention

In accordance with applicable data privacy law, we will retain your personal information for as long as is necessary for the relevant purposes described above.

7.  Updating and obtaining copies of your personal information

If you believe the personal information we hold about you is inaccurate, incorrect or

incomplete, please tell us as soon as possible. See “Contact Us” below. You may request

copies of your personal information from us. All requests must be in writing (i.e. by post or by

email)]. Please contact us for further details. See “Contact Us” below.

8.  Security

In accordance with our obligations under applicable data privacy law, we take all reasonable precautions to seek to keep your personal information secure, including precautions against unauthorised access or loss. Likewise, we seek to keep secure all confidential information you send to us. Our “Security Statement” on this Website contains more details about our website security measures. However, in common with all website operators, we cannot guarantee the security of any data transmitted by Internet email or through this Website.

9.  Data anonymisation and aggregation

We may process anonymised or aggregated data which does not identify you. We may share it with other companies in the Company Investments group or with other third parties. That data will not be subject to the relevant sections of this Privacy and Cookies Policy or to data privacy law. That data may be used for statistical analysis and administration, including analysis of trends, carrying out actuarial work, tailoring products and services, risk assessment and analysis of costs and charges in relation to our products and product support services, to compile (non-identifying) demographic data such as which pages of the Website are used most frequently (please refer to our Cookie Policy), sales, traffic patterns and related site information.

10.  Direct Marketing and Managing Your Preferences

With your consent, we may use your personal information for direct marketing purposes, including sending you marketing communications about investment products and related services of the Company Investments group. Direct marketing may include communications by post, email, telephone calls, SMSs, communications through third party instant messaging systems and such other electronic communication as may become relevant from time to time. You may unsubscribe from direct marketing from the Company at any time by following the instructions in the marketing communication itself or by contacting us through this Website.

11.  Monitoring and interception of communications

Emails and telephone calls, SMSs, communications sent through this Website and communications through third party instant messaging systems (as relevant), as between you and the Company staff, may be monitored and, in specific circumstances, intercepted, for legal and regulatory compliance purposes; to address actual or potential HR disciplinary matters; to ensure the continuing security and integrity of the Company’s systems, business dealings, reputation or the security and reputation of the Company and its staff; and for all other purposes as may be required or permitted by applicable legal and regulatory obligations.

12.  IP Addresses

An IP address is a number which recognises the computer or other device used to access the Internet. Typically, a web server automatically collects IP addresses and uses them to administer a website. IP addresses are typically used in conjunction with cookies for the purpose of “remembering” computers or other devices used to access this Website. For further details see “Cookies” below.

Cookies

Cookies and consent collection

This Website uses cookies. Cookies are text files containing small amounts of information which are downloaded to your computer or other device when you visit a website. They are used to help you navigate websites efficiently and perform certain functions. On your first visit to our home page a banner appeared to make it clear that this Website used cookies and to direct you towards this Privacy and Cookies Policy. It was explained to you on that first visit that by continuing to browse this website you would be agreeing to our use of cookies. This means that by using this website, you are deemed to be giving your consent to our use of cookies in the manner set out below.

Classification of cookies

Cookies can be classified by duration and by source

Duration: This Website uses both session and persistent cookies:

• Session cookies – a cookie that is stored temporarily and is destroyed when you close the link, specifically by closing the browser and terminating the particular ‘active session’ you are on and during which you made your visit to this Website.
• Persistent tracker cookies – a cookie that enables a website to remember you on subsequent visits, speeding up or enhancing your experience of services or functions offered. These cookies are not deleted when you close your browser and they will remain on your computer or other device unless you choose to disable them (see above for how to do that).

Source

Cookies can be classified as first party or third party cookies. First party cookies are those issued on behalf of the website visited, all other cookies are third party cookies. This website uses both first party and third party cookies. For further details, see below.

Function of cookies

The cookies used on this website fall into the following categories (these categories are based on the UK International Chamber of Commerce cookie guide)

Essential (classified as ‘strictly necessary’) cookies: these are essential in order to enable you to move around this Website and use its features, such as by accessing secure areas such as the ‘My Account’ function. A session cookie is only stored on your computer’s hard drive for the duration of your visit (known as an ‘active session’), it is removed as soon as the active session has ended.

Functionality cookies: these cookies allow us to remember choices you make (such as language or the region you are in) and provide enhanced, more personal features. The Company uses functional cookies to recognise you when you return to this Website, enabling us to personalise our content for you and remember your preferences.

Performance cookies: these are used by web analytics and collect information in an anonymous form about how visitors use this website. They allow us to track site usage, page visits and monitor trends over time. The data collected is limited to managing the performance and design of this site. These cookies are third-party cookies (Google Analytics) but the information is in an anonymous form and is obtained for the exclusive use of the Company.

Advertising cookies: we use persistent third party cookies to track user history for advertising and targeted marketing purposes. We also use pixel tags or transparent GIF files (also known as beacons) in combination with cookies to target and personalise content. These cookies do not collect or otherwise process any specific personal information about you. They collect information in an anonymous form about how visitors use this website and other websites with the information used to tailor advertising or marketing on this website and other websites.

DoubleClick by Google – ad management and serving solution that helps agencies and advertisers manage the scope of digital advertising programmes.

Other third party cookies: this website has links to other third party websites, and the linking process may involve third party cookies being placed on your machine or other device. We may also use embedded widgets on this website to enable content sharing through social media networks.

Opt Out for Cookies

There are a number of options available to opt-out for cookies. You can set your browser to either block all cookies; to only allow “trusted” sites to set them, or to accept cookies only from the websites that you are currently on. If you choose to block all cookies, you may experience problems accessing certain areas of this website.

You can find out more about cookies at www.allaboutcookies.org and the site will give you guidance on how to control and delete unwanted cookies you have already accepted.

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