Introduction


We are ICHX Tech Pte Ltd (referred to as the “Exchange”, “we”, “us” or “our”).

Our cookie policy (“Cookie Policy”) explains how and why we use cookies on our websites.

By continuing to use our website without changing your settings, you consent to our use of cookies as set out in this Cookie Policy. If you do not agree to our use of cookies as set out in this Cookie Policy, you should disable or delete the cookies associated with the websites by changing the setting on the web browser on your device accordingly.

We may from time to time amend the Cookie Policy. Such changes will be published here and effective upon publication. Please check the Cookie Policy regularly for updated information/version. Your continued access and/or use of our website, our products and/or our services will constitute your agreement to the revised Cookie Policy.


Cookies


Cookies are small files which are stored on your hard drive by your internet browser software while you are browsing.


How we use cookie


We use cookies to:

  1. manage the signing up process and general administration when you create an account with us;

  2. remember your user details for future correspondence when you submit data through a form;

  3. remember your preferences when viewing our websites;

  4. to remember when you are logged in to your account, which prevents you from having to log in every single time you visit a new page;

  5. ensure that your payment or purchase orders are remembered between pages so that we can process them properly;

  6. record and store your acceptance of our terms of services (including our Privacy Policy and the Cookie Policy);

  7. collect statistical information about users of our websites (for example, time spent on each page and which links our users choose to click); and

  8. from time to time when we offer surveys and questionnaires to understand our user base more accurately, such surveys and questionnaires may use cookies to remember who has already taken part in a survey to provide you with accurate results after you change pages.
Where third party marketing cookies are used to gather information about your browsing activities, please note that we do not have access to, nor control over these third parties’ use of cookies or other tracking technologies or the content of their advertisements.


Disabling cookies


You can prevent the setting of cookies by adjusting the settings on your browser.

Please note however that disabling cookies will typically result in disabling certain functionalities and features of this site. For example, we will not be able to know that you have opted out of targeted advertising on our website, recognise that you have agreed to the Privacy Policy and Cookie Policy, or remember your preferences.


Introduction


We are ICHX Tech Pte Ltd (referred to as the “Exchange”, “we”, “us” or “our”) and we are committed to protecting our stakeholders’ and customers’ personal data in accordance with the Personal Data Protection Act 2012 of Singapore (“PDPA”) and other applicable data protection laws.

Personal data” means any data about an individual who can be identified from that data, as more specifically defined under the PDPA and other applicable data protection laws.

Our privacy policy (“Privacy Policy”) describes how we collect, use, store and protect personal data. The Privacy Policy also describes how you can control the personal data that we hold on you, and your rights on your personal data, where applicable.

We may from time to time update the Privacy Policy to ensure that it is consistent with future developments, industry trends and/or any changes in legal or regulatory requirements or as we deem appropriate. Such changes will be published here and effective upon publication. Please check the Privacy Policy regularly for updated information/version. Your continued access and/or use of our website, our products and/or our services will constitute your agreement to the revised Privacy Policy.


Information that we collect from you


We collect, use, store and transfer different kinds of personal data about or relating to you, including but not limited to the following:

  1. Identity and contact data, which includes your name, passport or other identification number, telephone number, mailing address, email address, images of your passport or identification document, utility bill or driving license;

  2. Financial data, which includes information about your financial position, status and history, and payment account details (such as bank, credit, payment or other payment details);

  3. Transaction data, which includes details about payments to and from your accounts with us;

  4. Technical data, which includes details about the devices and technology you use including internet protocol address, your login data, and other technology on the devices you use to access our website, products and/or services;

  5. Usage data, which includes information about how you use our website, products and/or services, including cookies, IP address, and account details; and/or

  6. Blockchain data, which includes blockchain addresses and public keys.


How we collect information from you


We collect personal data from or relating to you in various ways, including but not limited to the following:

  1. when you access and/or use our website, products and/or services (or part thereof);

  2. when you submit forms relating to our website and/or any of our products or services;

  3. when you register for or use any of our services on websites owned or operated by us or when you register as a member of websites owned and/or operated by us, or use services on such websites;

  4. when you interact with our personnel such as customer service officers, marketing representatives and agents;

  5. when you request that we contact you;

  6. when you ask to be included in an email or other mailing list;

  7. when you respond to our promotions and other initiatives;

  8. when you enter into agreements with us;

  9. when we receive references from business partners and third parties, for example, where you have been referred by them; and/or

  10. when you submit personal data to us for any other reason.


Purposes for the Collection, Use and Disclosure of Personal Data


Generally, the Exchange collects, uses and/or discloses personal data, and you consent to such collection, use and/or disclosure by the Exchange, for the following purposes:

  1. to provide products and services to you;

  2. to communicate with you on matters relevant to your relationship with or interest in us;

  3. to assess and improve the products and services that you use or may use;

  4. to selectively send you information about our products, services, activities and/or events that may be relevant to you;

  5. to fulfil the contractual/legal obligations under the contracts or other legal arrangements entered into between us and you, or entered into between the Exchange’s related corporations, affiliates, partners and/or representatives and you;

  6. to protect and enforce our contractual and legal rights and obligations;

  7. to verify your identity;

  8. to prevent, detect and investigate crime, including fraud and money-laundering, and analyze and manage other commercial risks;

  9. to conduct audits, reviews and analysis of our internal processes, for action planning and managing commercial risks;

  10. to prevent, detect and investigate crime and manage the safety and security of our premises and services (including but not limited to carrying out CCTV surveillance and conducting security clearances);

  11. to comply with any applicable rules, laws and regulations, codes of practice or guidelines or to assist in law enforcement and investigations by relevant law enforcement agencies, regulatory authorities and other governmental agencies, anywhere in the world; and/or

  12. any other purpose relating to any of the above.
We may share personal data with our related corporations, services providers, agents and other third parties, with your consent for the purposes set out above and any other reasonable ancillary purposes, for legal reasons, or where permitted under the PDPA and other applicable laws, such as in response to law enforcement agencies.

If we transfer personal data to countries outside Singapore, it will be done in accordance with the relevant provisions under Singapore laws and regulations. We will also comply with the relevant laws and regulations in relation to transfers of personal data outside countries where the personal data is collected.


Third Party Data


Where you disclose personal data of other individuals to us, you warrant that such individuals have consented to us collecting, using and/or disclosing such personal data for: (i) the relevant purpose for which you made the disclosure or as was notified to you at the relevant time; and (ii) the other purposes as described above in this Privacy Policy.


Marketing Communications


It is in our legitimate interests to process personal data to selectively contact you and/or send you information about our products, services, activities and/or events that may be relevant to you (“Marketing Communications”).

To the extent that our processing of your personal data for Marketing Communications is subject to the European General Data Protection Regulation, you have the right to object to such processing by us. Please email dpo@istox.com if you wish to exercise this right.

You may opt-out of receiving Marketing Communications by using the unsubscribe link contained in the email communications or by contacting us at dpo@istox.com.


Cookie


When you browse our websites, we use cookies to store information about how you use these websites in order to improve the quality of service provided to you.

To understand what type of cookies we use and how these work when you use our websites, please refer to our Cookie Policy.


Retention of personal data


We retain personal data about or relating to you for as long as is necessary for the purposes for which such personal data was collected (including the purposes stated in section entitled “Purposes for the Collection, Use and Disclosure of Personal Data” above), and take reasonable measures to destroy any personal data that is no longer necessary to meet those purposes.


Security measures


All personal data is kept confidential and we take all reasonable measures to protect it from unauthorized or accidental access, processing or loss, by implementing appropriate physical, electronic and supervisory controls.


How you can control your information


If you do not want us to contact you via electronic messaging – You may select the “unsubscribe” option in all our electronic communications with you. We also comply with the Singapore Spam Control Act.

If you want to be removed from our customer database – You may email us at dpo@istox.com.

If you believe we have inaccurate information about you and you want to correct such data – You may email us at dpo@istox.com.

If you wish to know what personal data we have on you in connection with your relationship with us and how your personal data has been used – You may email us at dpo@istox.com.

If you have any questions about this Privacy Policy, or our handling of your personal data – You may email us at dpo@istox.com.

It is important to note that we use personal data to provide you with the products and services you wish to use. We also comply with various regulatory requirements in doing so, including the requirements for customer due diligence. Withdrawal of consent for the Exchange to collect, use or disclose personal data means that we may need to stop these activities. The absence of certain key personal data, including but not limited to your name, address, email and/or telephone contacts, personal identification numbers or banking information, may cause us to be unable to continue providing the relevant products and services to you.


Your rights regarding your personal data


To the extent that our processing of your personal data is subject to the European General Data Protection Regulation, you may have the following rights:

  1. access to your personal data;

  2. rectification of your personal data;

  3. erasure of your personal data;

  4. restrict processing of your personal data;

  5. object to processing (including object to receiving marketing) of your personal data;

  6. data portability; and

  7. lodge a complaint with a EU supervisory authority.
If you wish to exercise these rights, or have any questions about these rights, you may email us at dpo@istox.com or write to us at:

ICHX Tech Pte Ltd
9 Temasek Boulevard
#38-02
Suntec City Tower 2
Singapore 038989


Contacting us


We have designated Mr Barry Koh as our Data Protection Officer.

If you have any questions about this Privacy Policy, or our handling of your personal data, please email our Data Protection Officer at dpo@istox.com.

General Website Terms of Use


The following terms and conditions (“General Terms”) govern your use and access of the www.istox.com which is owned and operated by or on behalf of ICHX Tech Pte Ltd (“Exchange”) (this “Site”) and all content or web pages thereunder, including the information, images, links, sounds, graphics, video, software, applications and other materials displayed or made available therein and the functionalities or services provided therein (collectively the “Exchange Materials”). By accessing and/or using the Site or the Exchange Materials, you are indicating your acceptance and agreement to these General Terms below. If you do not accept these General Terms, you must stop using/accessing the Site and the Exchange Materials.

We may from time to time update these General Terms to ensure that it is consistent with future developments, industry trends and/or any changes in legal or regulatory requirements or as we deem appropriate. Such changes will be published here and effective upon publication. Please check these General Terms regularly for updated information/version. Your continued access and/or use of the Site and/or the Exchange Materials will constitute your agreement to the revised General Terms.


General use and access


Guidelines to the use of Site: You agree to comply with any and all the guidelines, notices, rules and policies pertaining to the use and/or access of the Site and/or the Exchange Materials, as well as any amendments to the aforementioned, issued by us, from time to time. We reserve the right to revise these guidelines, notices, rules and policies at any time and such changes will be published here and effective and binding on you upon publication.

Changes to the Site and/or Exchange Materials: We may, from time to time and without giving any reason or prior notice, upgrade, modify, suspend or discontinue the provision of or remove the Site and/or Exchange Materials (whether in whole or in part), and shall not be liable if any such upgrade, modification, suspension or discontinuation prevents you from accessing the Site and/or Exchange Materials.

Restricted activities: You agree and undertake not to: (i) use or upload, in any way, any software or material that contains, or which you have reason to suspect that contains, viruses, damaging components, malicious code or harmful components which may impair or corrupt the Site’s data or the Exchange Materials or damage or interfere with the operation of another user’s computer or mobile device or the Site; (ii) post, promote or transmit any materials or information through the Site which are or may be illegal, misleading, incomplete, erroneous, offensive, indecent, defamatory or which may not be lawfully disseminated under applicable laws or which is otherwise objectionable; (iii) use the Site other than in conformance with the acceptable use policies of any connected computer networks, any applicable Internet standards and any other applicable laws, or view, listen to, download, print or use the Exchange Materials other than as allowed under applicable laws; or (iv) impersonate any person or entity or to falsely state or otherwise misrepresent your affiliation with any person or entity.

Contents of transmissions or communications: With respect to all contents of transmissions or communications you make or submit through the Site, we shall be free to reproduce, use, disclose, host, publish, transmit and distribute all such contents of transmissions or communications or any part thereof to others without limitations, and you hereby grant to us and our agents, a non-exclusive, world-wide, royalty-free, irrevocable licence and right to do the same.

Records: You acknowledge and agree that the Exchange’s records and any records of the communications, transactions, instructions or operations made or performed, processed or effected through the Site by you or any person purporting to be you, acting on your behalf or purportedly acting on your behalf, with or without your consent, or any record of communications, transactions, instructions or operations relating to the operation of the Site and any record of any communications, transactions, instructions or operations maintained by the Exchange or by any relevant person authorised by the Exchange relating to or connected with the Site shall be binding on you for all purposes whatsoever and shall be conclusive evidence of such communications, transactions, instructions or operations.

Other applicable terms: In addition to these General Terms, the access and/or use of specific aspects of the Site and/or the Exchange Materials may be subject to additional terms and conditions which will apply in full force and effect.


No warranty


The Site and the Exchange Materials have been made available for your use on an "as is" and "as available" basis, and at your sole risk. The Exchange assumes no responsibility and makes no representation or warranty on the accuracy, validity or completeness of the materials or information contained in the Site and/or the Exchange Materials, and disclaims all liability for any errors, delays or omissions in the Site and/or the Exchange Materials, or for any action taken in reliance thereon. No warranty of any kind, implied, express or statutory, including but not limited to the warranties of non-infringement of third party rights, title, merchantability, satisfactory quality or fitness for a particular purpose, is given in conjunction with the Site or the Exchange Materials.

The Exchange does not warrant that any of the Exchange Materials or that the Site will be provided uninterrupted or free from errors, or that any identified defect will be corrected. Further, no warranty is given that the Site and the Exchange Materials are free from any viruses, damaging components, malicious code or harmful components.

The Exchange does not warrant the security of any information transmitted by you or to you through the Site or that there would be no delay, interruption or interception in data transmission. You accept the risk that any information transmitted or received through the Site may be accessed by unauthorised third parties, and that transactions over the Internet may be subject to interruption, transmission blackout, delayed transmission due to internet traffic or incorrect data transmission due to the public nature of the Internet. Regardless of any security measures taken by the Exchange, the Exchange shall assume no responsibility whatsoever for any loss or expense resulting from such delays, interruptions and/or interceptions.

Any materials or information presented via the Site and/or the Exchange Materials is made available by the Exchange for informational purposes only, and is subject to change without notice. You must make your own assessment of the relevance, timeliness, accuracy, adequacy, commercial value, completeness and reliability of the materials or information provided in the Site or the Exchange Materials and such independent investigations as you may consider necessary or appropriate for the purpose of such assessment. Any opinion or estimate provided in the Site and/or the Exchange Materials is made on a general basis and is not to be relied on by you as advice. Accordingly, no warranty whatsoever is given by the Exchange and no liability whatsoever is accepted by the Exchange for any loss arising whether directly or indirectly as a result of you acting on any materials, information, view, opinion, projection or estimate provided in the Site and/or the Exchange Materials.

The Site and the Exchange Materials are not intended to provide specific investment, tax or legal advice or to make any recommendations about the suitability of any investments or products for any particular investor. No consideration has been given to the specific investment objective, financial situation and particular needs of any specific person, and the information herein should not be used as a substitute for any form of advice. You should seek your own independent financial, legal, regulatory, tax or other advice before making an investment in the investments or products. In the event that you choose not to seek advice from a relevant adviser, you should consider whether the investment or product is suitable for you.

The Exchange controls and maintains the Site from Singapore and makes no representation that the materials or information provided on or via the Site is appropriate or available for use in other locations. If you use the Site from other locations, you are responsible for compliance with applicable local laws.

Where the Site contains hypertext links to third party websites, such links are not an endorsement by the Exchange of any content, products or services provided on or via such websites. The use of such links is entirely at your own risk and the Exchange accepts no responsibility or liability for the content, use or availability of such websites or for the relevance, timeliness, accuracy, adequacy, commercial value, completeness or reliability of any content, products or services contained in or provided on or via such websites. The Exchange makes no representations or warranty as to having reviewed or verified the relevance, timeliness, accuracy, adequacy, commercial value, completeness or reliability of the content, products or services of such websites.

Without prejudice to other provision in these General Terms, the Exchange shall in no event nor for any reason whatsoever be liable (even if the Exchange or its agents or employees may have been advised of, or otherwise might have anticipated, the possibility of such loss, damages or expenses) for any loss, damages or expenses (including any direct, indirect, incidental, special, consequential or punitive damages or economic loss or any claims for loss of profits or loss of use) whatsoever or howsoever caused (regardless of the form of action) arising directly or indirectly in connection with: (i) any access, use, misuse or inability to use the Site and/or Exchange Materials, or reliance on the Exchange Material; (ii) any system, server or connection failure, error, omission, interruption, interception or delay in transmission. or viruses, damaging components, malicious code or harmful components; (iii) any use of and/or access to any third party websites linked to or provided through the Site; or (iv) any services, products, information, data, software or other material obtained or downloaded from the Site and/or the Exchange Materials or from any third party websites linked to or provided through the Site.


Password-restricted areas of the Site


Secure areas: Access to and use of password-protected and/or secure areas of the Site are restricted to authorised users only. You may not obtain or attempt to obtain unauthorised access to such parts of the Site, or to any other protected information, through any means not intentionally made available by us for your specific use. In order to access and/or use the password-protected and/or secure portions of the Site and/or the Exchange Materials, you must register for an account with us (which is subject to our approval at our absolute discretion).

Username and Password: If you request to create an account with us, a Username and Password may either be: (i) determined by and issued to you by us; or (ii) provided by you and accepted by us in our absolute discretion. We may at any time in our absolute discretion forthwith suspend your account and/or invalidate the Username and/or Password without giving any reason or prior notice and shall not be liable or responsible for any loss or damage suffered by or caused by you or arising out of or in connection with or by reason of such suspension and/or invalidation. The Username and Password is for each user’s personal use only and neither may be transferred to any other person or entity. “Username”, in relation to each user who has an account with us, refers to the unique login identification name or code which identifies such user, and “Password”, in relation to each user who has an account with us, refers to the valid password that such user may use in conjunction with the relevant Username to access the Site.

You hereby agree to change your Password from time to time and to keep the Username and Password confidential and shall be responsible for the security of your account and liable for any disclosure or use (whether such use is authorised or not) of the Username and/or Password. You shall notify us immediately if you have knowledge that or have reason for suspecting that the confidentiality of the Username and/or Password has been compromised or if there has been any unauthorised use of the Username and/or Password.

Purported use/access: You agree and acknowledge that any use or purported use of or access to or purported access to the Site and/or the Exchange Materials and any information, data, instructions or communications referable to the Username and Password shall be deemed to be, as the case may be: (i) use of or access to the Site and/or the Exchange Materials by you; and/or (ii) information, data, instructions or communications carried out, transmitted or validly issued by you. We shall be entitled (but not obliged) to act upon, rely on and/or hold you solely responsible and liable in respect thereof as if the same were carried out, transmitted or validly issued by you. You further agree and acknowledge that you shall be bound by any access or use of the Site and/or the Exchange Materials(whether such access or use is authorised by you or not) and/or information, data, instructions or communications referable to your Username and Password.


Transactions with third parties


Under no circumstances shall it be construed that, in case of your access to and use of systems, services, content, materials, products or programmes of any third party, the Exchange is a party to any transaction, if any, between you and such third party or that the Exchange endorses, sponsors, certifies, or is involved in the provision of such systems, services, content, materials, products or programmes contained in or provided on or via the Site and/or the Exchange Materials and the Exchange shall not be liable in any way for your access to and use of systems, services, content, materials, products or programmes of any third party, or for purchases or subscription made in relation thereto, each of which shall be your responsibility or that of the relevant third party.

You acknowledge and agree that you will be solely responsible for any access or use of third party systems, services, content, materials, products or programmes contained in or provided on or via the Site and/or the Exchange Materials. If you access or use such third party systems, services, content, materials, products or programmes, you must comply with the relevant terms and conditions for the access or the use thereof.


Intellectual property


The Exchange or its licensor(s) reserves and retains all rights (including copyrights, trademarks, patents as well as any other intellectual property right) in relation to the products, services and all content, information and data contained in or provided on or via the Site and/or the Exchange Materials (including all texts, graphics and logos). You may not do anything that will violate or infringe such intellectual property rights and, in particular, you shall not copy, download, publish, distribute, transmit, disseminate, sell, broadcast, circulate, exploit (whether for commercial benefit or otherwise) or reproduce any of the information or content contained in or provided on or via the Site or the Exchange Materials in any form without the prior written permission of the Exchange or its licensor(s). Further, no part or parts of the Site or any Exchange Materials may be reproduced, distributed, republished, displayed, broadcast, hyperlinked, mirrored, framed, transferred or transmitted in any manner or by any means or stored in an information retrieval system without the prior written permission of the Exchange or its licensor(s). Subject to other applicable terms, guidelines, notices, rules and policies, the Exchange grants you a non-transferable, non-exclusive, revocable, limited license to use and access the Site and the Exchange Materials solely for your own personal, informational and non-commercial use, provided that you do not modify the Exchange Materials and that you retain all copyright and other proprietary notices contained in the Exchange Materials.

Links to the Site or any Exchange Material are not permitted without the prior written consent of the Exchange.

Save as expressly provided otherwise in these General Terms, you acknowledge that you are not granted any licence, interest or right by virtue of your use of or access to the Site and/or Exchange Materials.


Privacy and cookie policy


We will manage any personal data that we collect through the Site or we otherwise obtain in connection with the Site and/or our products/services in accordance with our Privacy Policy, which shall form part of these General Terms. You can access our Privacy Policy here.

You can access our Cookie Policy here. Such Cookie Policy shall form part of these General Terms.


Indemnity


You will indemnify us against any liability, loss, damage, including solicitor and client costs and expenses (legal or otherwise) which we may sustain or incur, directly or indirectly, by reason of our having made available the Site and the Exchange Materials or having entered into these General Terms with you or enforcement of our rights under these General Terms or in acting upon any instructions which you may give in relation to the Site and/or the Exchange Materials or any negligence, fraud and/or misconduct on your part or your breach of these General Terms.


Termination


You agree that the Exchange may, at its absolute discretion, deny you access to the Site and/or the Exchange Materials for any reason, including without limitation, if the Exchange believes that you have violated or acted inconsistently with any terms or conditions set out herein, or if in the Exchange’s opinion or the opinion of any regulatory authority, it is not suitable to continue providing the services relating to the Site and/or the Exchange Materials.


General


Governing law: These General Terms shall be governed by and construed in accordance with Singapore law and you hereby submit to the exclusive jurisdiction of the Singapore courts.

Sub-contracting and delegation: We may delegate or sub-contract the performance of any of our functions in connection with the Site and/or the Exchange Materials.

Assignment: You may not assign your rights under these General Terms without our prior written consent. We may assign our rights under these General Terms to any third party.

Successors and assigns: These General Terms will bind you and us and our respective successors in title and assigns and will continue to bind you notwithstanding any change in our name or constitution or our merger, consolidation or amalgamation with or into any other entity (in which case these General Terms will bind you to our successor entity).

Severability: If any provision of these General Terms or part thereof is rendered void, invalid, illegal or unenforceable by any legislation to which it is subject, it shall be rendered void, invalid, illegal or unenforceable only to that extent and it shall in no way affect or prejudice the enforceability of the remainder of such provision or the other provisions of these General Termssuch provision shall be struck and severed from these General Terms and the remaining provisions of these General Terms shall not be affected thereby.

Waiver: No failure or delay to exercise our rights under these General Terms shall operate as a waiver thereof nor shall such failure or delay affect our right to enforce our rights under these General Terms.

Translation: If these Terms are translated into a language other than English, the English text shall prevail.

Rights of Third Parties: A person or entity who is not a party to these General Terms shall have no right under the Contracts (Rights of Third Parties) Act, Chapter 53B of Singapore or other similar laws to enforce any of these General Terms, regardless of whether such person or entity has been identified by name, as a member of a class or as answering a particular description. Our right to vary these General Terms may be exercised without the consent of any person or entity who is not a party to these General Terms. For the avoidance of doubt, nothing in this clause shall affect the rights of any permitted assignee or transferee of these General Terms.

No Internet access: You agree and acknowledge that these General Terms, the Site and the Exchange Materials do not include the provision of Internet access or other telecommunication services by the Exchange. Any Internet access or telecommunications services (such as mobile data connectivity) required by you to access and use the Site and/or the Exchange Materials shall be your sole responsibility and shall be separately obtained by you, at their own cost, from the appropriate telecommunications or internet access service provider.


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The iSTOX Platform is established and operated by ICHX Tech Pte. Ltd. in a regulatory sandbox, and has been exempted from compliance with some of the requirements under the Securities and Futures Act (Cap 289) (“SFA”) during the period of 1 May 2019 to 31 January 2020 (both dates inclusive), subject to such further extension as the Monetary Authority of Singapore (“MAS”) may approve (the “Sandbox Period”).