By accessing and reading this Website, the Viewer understands and agrees to the following statements:
No information contained herein is made for offer, marketing, advertisement or solicitation purposes, in any jurisdiction.
This Website and any information contained herein is made available by Xen Technologies Pte. Ltd. (hereafter “Xen”) for general information only and not for any other purpose. The Viewer agrees that this website shall be used solely as reference, or for informational use and not for any other purposes, commercial or otherwise. The information contained in this website is not intended and should not be used or construed as an offer to sell, or a solicitation of any offer to buy, securities of any fund or other investment product in any jurisdiction. The information in this web site is not intended and should not be construed as investment, tax, legal, financial or other advice. Xen holds exclusive and rightful ownership of the intellectual and proprietary rights to all opinions, concepts, ideas, work products, and the like, related to or as a result of the General Information and contents in this website.
The Viewer understands that no specific information on any investment is provided nor will be provided to the general public through this website. The Viewer understands and agrees that Xen has not makes any commitment or duty to provide any further information whatsoever. All information in this website should be treated as strictly confidential, and any reproduction of information contained herein, in whole or in part, is prohibited. The Viewer agrees that no part of this website or any information contained herein may be shared, copied, reproduced, or redistributed or passed on, directly or indirectly, to any other person in any manner or published, in whole or in part, for any purpose.
The Viewer understands and agrees that access to the Website or any information herein is made available to the Viewer solely under the discretion of Xen, its affiliates and representatives, and they are under no obligation to provide access to the website, except as they deem fit.
The Viewer understand and agrees that all information, statements, opinions and content made available through the website (hereafter “General Information”) shall be subject to the following disclaimers.
The Viewer understands and agrees that the General Information in this Website, is not intended to be complete or final and are qualified in their entirety by reference to the final agreements with any parties who are authorized to contract by their respective jurisdiction. In particular, the General Information may refer to certain events as having occurred which have not occurred on this date but are expected to occur on or prior to distribution of the final definitive agreements. Neither will the viewing of this website at any time will under any circumstances create a representation or an implication that the General Information contained therein as correct as of any time subsequent to the date hereof.
The Viewer understands and agrees that the General Information in the Website herein may express opinions of Xen, its affiliates and subsidiaries. These opinions may differ or be contrary to opinions expressed by any of the subsidiaries or affiliates of Xen, or by Xen itself, as a result of using different assumptions and criteria. Certain General Information and opinions herein are based and have been obtained from published sources and/or prepared by other parties. The General Information and opinions have been compiled or arrived at based on General Information obtained from sources believed to be reliable and in good faith. However, such General Information has not been independently verified, is provided on an ‘as is’ basis and no representation or warranty, either expressed or implied, is provided in relation to the accuracy, completeness, reliability, merchantability or fitness for a particular purpose of such General Information and opinions, except with respect to General Information concerning Xen, its subsidiaries and affiliates. All statements of opinion represent Xen’s own assessment and interpretation of General Information available to them currently. All such General Information and opinions are subject to change without notice, and neither Xen nor any of its subsidiaries or affiliates are under any obligation to update or keep current the General Information contained in the Website, or made through any other medium of communication.
The Viewer understands and agrees that the General Information in this Website may contain statements that are not purely historical in nature, but are “forward-looking” statements including without limitation, projections, forecasts and/or targets. These forward-looking statements are based upon certain assumptions. Actual events are difficult to predict and will be beyond the any person’s control. There can be no assurance that estimated returns or projections can be realized, that forward looking statements will materialize or that actual results will not be materially lower than those presented. Actual events may differ from those assumed. All forward-looking statements included are based on General Information available on the date hereof and Xen, its affiliates or subsidiaries assume any duty to update any forward-looking statements. Past performance is no assurance of future results. All forward-looking statements represent Xen's own assessment and interpretation of General Information available to them currently. These forward-looking statements are subject to change without notice, and neither Xen nor any of its subsidiaries or affiliates is under any obligation to update or keep current any forward-looking statements or General Information contained in the Website, or made through any other medium of communication.
The Viewer understands and agrees that the General Information contained herein has neither been approved or disapproved by any regulatory body of any jurisdiction, as such, no representation or warranty, express or implied, is made with respect to the material or views found herein as to its fairness, accuracy or completeness. Xen or any of its subsidiaries, affiliates, controlling persons, directors, officers or employees, or advisers shall not be in any way liable or responsible, directly or indirectly, whether expressly or by implication, in contract, tort, by statute or otherwise for the contents hereof or any loss howsoever arising.
The Viewer understands and agrees that the General Information in this website and the website itself, is not intended to and does not constitute investment advice or recommendation, and is not audited, and does not constitute or form part of and should not be constructed as an offer to sell, or issue or solicitation of an offer to purchase or subscribe for any securities by Xen or any of its affiliates from any jurisdiction to any entity or person in any jurisdiction. Neither should it be taken as an inducement to enter into investment activity. None of the content and statements in this website should be taken by the person as a suggestion to invest, and that any investment decision must be made solely on the basis of person’s own due diligence. Xen and its subsidiaries, affiliates, controlling persons, directors, officers or employees, or advisers shall be considered free from liability whatsoever for any course of action taken by the any relevant party, Viewer, or User.
The Viewer understands and agrees that the securities or investments that may be described in the General Information may not be eligible for sale in all jurisdictions or to certain categories of investors. The securities or investments described in the General Information are not suitable for all investors and trading in these assets is considered risky. Past performance is not necessarily indicative of future results. The value of investments may fall as well as rise and the investor may not get back the amount initially invested.
The Viewer understands and agrees that the securities and investment that may be described in the General Information may not be readily realizable since the market in the securities is illiquid or there is no secondary market for the investor’s interest and therefore valuing the investment and identifying the risk to which the investor is exposed may be difficult to quantify. Investments in illiquid securities involve a high degree of risk and are suitable only for sophisticated investors who can tolerate such risk and do not require an investment easily and quickly converted into cash.
The Viewer understands and agrees that the securities and investment that may be described in the General Information may be subject to fluctuations in exchange rates that could have an adverse effect on the value or the price of, or income derived from, the investment. Other risk factors affecting the price, value or income of an investment include but are not necessarily limited to political risks, economic risks, credit risks, and market risks. Investing in the securities and investments that may be described in the General Information involve a high degree of risk and investors should perform their own due diligence before investing.
The Viewer understands and agrees that descriptions of any company or issuer or their securities or the markets or developments mentioned in the website or in any General Information are not intended to be complete. The General Information should not be regarded by the Viewer as a substitute for the exercise of their own judgment as the General Information has no regard to the specific investment objectives, financial situation or particular needs of any specific person.
The Viewer understands and agrees that any collective investment schemes described in this website or in the General Information (hereafter “Fund" or "Funds”) may not be approved or disapproved by any regulatory body of any jurisdiction, as such, no representation or warranty, express or implied, is made with respect to the material or views found regarding a Fund or Funds herein as to its fairness, accuracy or completeness..
The Viewer understands and agrees that there are substantial risks in investing in any Fund. Persons interested in investing in a fund should carefully note the following:
• A Fund represents a speculative investment and involves a high degree of risk. An investor could lose all or a substantial portion of his/her investment. An investor must have the financial ability, sophistication/experience and willingness to bear the risks of an investment in a Fund.
• An investment in a Fund should be discretionary capital set aside strictly for speculative purposes.
• An investment in a Fund is not suitable or desirable for all investors. Only certain persons meeting certain additional eligibility criteria may invest in a Fund.
• A Fund may employ leverage and other investment techniques, and such leverage and other investment techniques may result in increased volatility of the Fund’s performance and increased risk of loss.
• A Fund may trade in commodities, futures and other derivatives, which may increase the risk of loss of the Fund. Fund investments are illiquid and there are generally significant restrictions on transferring interests in a Fund. There will likely be no secondary market for the interests of a Fund.
• A Fund may have limited or no operating history.
• The investment manager of a Fund may have certain discretionary authority over the Fund’s assets.
• A Fund may invest in a limited number of securities or instruments, which could result in a limited degree of diversification and higher risk.
• A Fund generally involves a complex tax structure, which should be reviewed carefully. A fund’s investment strategy may cause delays in important tax information being sent to investors.
• The management fees of a fund’s investment manager may be substantial regardless of whether the Fund has a positive return, and will offset the fund’s profits.
• A Fund is not required by regulators to provide periodic pricing or valuation General Information to investors.
• There are likely to be a number of conflicts of interest or potential conflicts of interest in connection with an investment manager’s management of Fund assets.
The above items is not a complete list of the risks and other important disclosures involved in investing in Funds. Before making any investment in a fund, persons are advised to thoroughly and carefully review the relevant information, with their financial, legal and tax advisors to determine whether an investment is suitable or viable.
The Viewer understands and agrees that the application of taxation laws depends on a given individual’s circumstances and, accordingly, each individual should seek independent professional advice on taxation implications before making any independent investment decision or action based on any General Information.
This website and the General Information contained in is not designed, nor should be the basis of an investment decision. Any investment decision should be based on thorough due diligence procedures, which should include, but not be limited to, a thorough review of all relevant term sheets and other offering documents as well as consolation with legal, tax and regulatory experts. Any person subscribing for an investment must be able to bear the risks involved and must meet a particular Fund’s suitability requirements.
The Viewer understands and agrees that any decision to purchase securities should be made solely and independently by any person on the basis of the General Information to be contained in a specific and definitive document specifically provided and addressed to that person, and the General Information in this website should not be treated as an offer, marketing or solicitation for investment, nor as an inducement to enter into any agreement with any party in any capacity under any jurisdiction.
The Viewer understands and agrees that any General Information in this website does not form a fiduciary relationship or constitute advice and is not and should not be construed as an offer or a solicitation of an offer of securities or related financial instruments, or an invitation or inducement to engage in investment activity. The website and the General Information is not intended to represent the rendering of accounting, tax, legal or regulatory advice. A change in the facts or circumstances of any transaction could materially affect the accounting, tax, legal or regulatory treatment for that transaction. The ultimate responsibility for the decision on the appropriate application of accounting, tax, legal and regulatory treatment rests with a particular investor and his or her accountants, tax and regulatory counsel. An investor should consult, and must rely on their own professional tax, legal and investment advisors as to matters concerning the Fund and their investments in the Fund. An investor should inform themselves as to the legal requirements within their own jurisdictions for any transaction, applicable foreign exchange restrictions, and any income and other taxes which may apply to any transaction.
REGISTRATION AND ACCOUNTS
Account Responsibilities. You are responsible for maintaining the confidentiality of your Account login information and are fully responsible for all activities that occur under your Account. You agree to immediately notify Company of any unauthorized use, or suspected unauthorized use of your Account or any other breach of security. Company cannot and will not be liable for any loss or damage arising from your failure to comply with the above requirements.
ACCESS TO THE WEBSITE
License. Subject to these Terms, Xen grants you a non-transferable, non-exclusive, revocable, limited license to use and access the Site solely for your own personal, informational and non-commercial use.
Certain Restrictions. The rights granted to you in these Terms are subject to the following restrictions: (a) you shall not license, sell, rent, lease, transfer, assign, distribute, host, or otherwise commercially exploit the Site, whether in whole or in part, or any content displayed on the Site; (b) you shall not modify, make derivative works of, disassemble, reverse compile or reverse engineer any part of the Site; (c) you shall not access the Site in order to build a similar or competitive website, product, or service; (d) you shall not use our Services in any manner that could interfere with, disrupt, negatively affect or inhibit other users from fully enjoying our Services, or that could damage, disable, overburden or impair the functioning of our Services in any manner; (e) you shall not use our Services to pay for, support or otherwise engage in any illegal gambling activities, fraud, money-laundering, or terrorist activities, or other illegal activities; (f) you shall not use any robot, spider, crawler, scraper or other automated means or interface not provided by us to access our Services or to extract data; (g) you shall not use or attempt to use another user's account without authorization; (h) you shall not attempt to circumvent any content filtering techniques we employ, or attempt to access any service or area of our Services that you are not authorized to access; (i) you shall not develop any third-party applications that interact with our Services without our prior written consent; (j) you shall not provide false, inaccurate, or misleading information; (k) you shall not encourage or induce any third party to engage in any of the activities prohibited under these Terms; and (l) except as expressly stated herein, no part of the Site may be copied, reproduced, distributed, republished, downloaded, displayed, posted or transmitted in any form or by any means. Unless otherwise indicated, any future release, update, or other addition to functionality of the Site shall be subject to these Terms. All copyright and other proprietary notices on the Site (or on any content displayed on the Site) must be retained on all copies thereof.
Modification. Company reserves the right, at any time, to modify, suspend, or discontinue the Site (in whole or in part) with or without notice to you. You agree that Company will not be liable to you or to any third party for any modification, suspension, or discontinuation of the Site or any part thereof.
No Support or Maintenance. You acknowledge and agree that Company will have no obligation to provide you with any support or maintenance in connection with the Site.
You agree to indemnify, defend, and hold Company (and its officers, directors, members, employees, affiliates and agents) harmless, including costs and attorneys’ fees, from any claim, action, damage, loss, cost, expenses or demand made by any third party due to or arising out of (a) your use of the Site, (b) your violation of these Terms, (c) your violation of applicable laws or regulations, or (d) your violation of any rights of any other person or entity. Company reserves the right, at your expense, to assume the exclusive defense and control of any matter for which you are required to indemnify us, and you agree to cooperate with our defense of these claims. You agree not to settle any matter without the prior written consent of Company. Company will use reasonable efforts to notify you of any such claim, action or proceeding upon becoming aware of it.
THIRD-PARTY LINKS AND ADS
General. In using our Services, you will view content provided by third parties, including articles, reviews, comments, insights, analysis and links to web pages of such parties, including but not limited to blogs, forums, communities and social networks. We do not control or approve any Third-Party Content and shall have no responsibility for Third-Party Content, including without limitation material that may be misleading, incomplete, erroneous, offensive, indecent or otherwise objectionable. We are not responsible or liable for any loss or damage of any sort incurred as the result of any such dealings, and you understand that your use of Third-Party Content, and your interactions with third parties that are linked to our Service, is at your own risk.
Third-Party Links & Ads. The Site may contain links to third-party websites and services, and/or display advertisements for third parties (collectively, “Third-Party Links & Ads”). Such Third-Party Links & Ads are not under the control of Company, and Company is not responsible for any Third-Party Links & Ads. Company provides access to these Third-Party Links & Ads only as a convenience to you, and does not review, approve, monitor, endorse, warrant, or make any representations with respect to Third-Party Links & Ads. You use all Third-Party Links & Ads at your own risk, and should apply a suitable level of caution and discretion in doing so. When you click on any of the Third-Party Links & Ads, the applicable third party’s terms and policies apply, including the third party’s privacy and data gathering practices. You should make whatever investigation you feel necessary or appropriate before proceeding with any transaction in connection with such Third-Party Links & Ads.
Other Users. Your interactions with other Site users are solely between you and such users. You agree that Company will not be responsible for any loss or damage incurred as the result of any such interactions. If there is a dispute between you and any Site user, we are under no obligation to become involved.
Release. You hereby release and forever discharge the Company (and our officers, employees, agents, successors, and assigns) from, and hereby waive and relinquish, each and every past, present and future dispute, claim, controversy, demand, right, obligation, liability, action and cause of action of every kind and nature (including personal injuries, death, and property damage), that has arisen or arises directly or indirectly out of, or that relates directly or indirectly to, the Site (including any interactions with, or act or omission of, other Site users or any Third-Party Links & Ads).
Please refer to the Legal Notice, Disclosure and Disclaimer page of this website.
LIMITATION ON LIABILITY
To the maximum extent permitted by the applicable law, and except where prohibited by law, in no event shall the Company be liable to you for any indirect, consequential, exemplary, incidental, special or punitive damages, including lost profits, arising from or relating to these terms or your use of the website, even if the Company has been advised of the possibility of such damages. You access this website at your own discretion and risk, and you will be solely responsible for any damage to your device or computer system or loss of data resulting therefrom.
If, notwithstanding these Terms, the Company is found to be liable for any damages arising from or related to the use of this website, the liability shall be limited to USD 1,000, covering any and all claims regardless of the number of claims or accounts.
DISCONTINUANCE OF SERVICES
We may, in our sole discretion and without liability to you, with or without prior notice and at any time, modify or discontinue, temporarily or permanently, any portion of our Services.
If for any reason the Company is holding cash, funds, any form of asset, or digital tokens in your Account on your behalf, and the Company is unable to return your cash, funds, any form of asset, or digital tokens to your designated external account after a period of inactivity, then the Company may report and remit such unclaimed property in accordance with applicable unclaimed property laws.
TERM, SUSPENSION AND TERMINATION
These Terms will remain in full force and effect while you use the Site. We may suspend or terminate your rights, and not necessarily these Terms, to use the Site (including your Account) at any time for any reason at our sole discretion, including for any use of the Site in violation of these Terms. Upon termination of your rights under these Terms, your Account and right to access and use the Site will terminate immediately. The Company will not have any liability whatsoever to you for any termination of your rights under these Terms, including for termination of your Account.
In the event of any Force Majeure, breach of these Terms, or any other event that would make provision of the Services commercially unreasonable for the Company, we may, in our discretion and without liability to you, with or without prior notice, suspend your access to all or a portion of our Services. We may terminate your access to the the Site and the Services in our sole discretion, immediately and without prior notice, and delete or deactivate your Account and all related information and files in such account without liability to you, including, for instance, in the event that you breach any term of these Terms. In the event of termination, the Company will attempt to return any Funds stored in your Account not otherwise owed to the Company, unless the Company believes you have committed fraud, negligence or other misconduct.
APPLICABLE LAW and ARBITRATION
GENERAL AND MISCELLANEOUS PROVISIONS
Entire Agreement; Order of Precedence; Waiver; Severability. These Terms contain the entire agreement, and supersede all prior and contemporaneous understandings between the parties regarding the Services. Our failure to exercise or enforce any right or provision of these Terms shall not operate as a waiver of such right or provision. These Terms do not alter the terms or conditions of any other electronic or written agreement you may have with the Company for the Services or for any other the Company product or service or otherwise. In the event of any conflict between these Terms and any other agreement you may have with the Company, the terms of that other agreement will control only if these Terms are specifically identified and declared to be overridden by such other agreement. If any provision of these Terms is, for any reason, held to be invalid or unenforceable, the other provisions of these Terms will be unimpaired and the invalid or unenforceable provision will be deemed modified so that it is valid and enforceable to the maximum extent permitted by law.
Amendment. We reserve the right to make changes or modifications to these Terms from time to time, in our sole discretion. If we make changes to these Terms, we will provide you with notice of such changes, such as by sending an email, providing notice on the homepage of the Company and/or by posting the amended Terms via the applicable website and mobile applications and updating the "Last Updated" date at the top of these Terms. The amended Terms will be deemed effective immediately upon posting for any users of the Services.
Assignment. These Terms, and your rights and obligations herein, may not be assigned, subcontracted, delegated, or otherwise transferred by you without Company’s prior written consent, and any attempted assignment, subcontract, delegation, or transfer in violation of the foregoing will be null and void. Company may freely assign these Terms. The terms and conditions set forth in these Terms shall be binding upon assignees.
Intellectual Property. All rights reserved. You acknowledge that all the intellectual property rights, including copyrights, patents, trademarks, and trade secrets, in the Site and its content are owned by Company or Company’s suppliers. Neither these Terms (nor your access to the Site) transfers to you or any third party any rights, title or interest in or to such intellectual property rights, except for the limited access rights expressly set forth above. Company and its suppliers reserve all rights not granted in these Terms. There are no implied licenses granted under these Terms.
WHAT WE COLLECT AND HOW WE PROCESS YOUR PERSONAL INFORMATION
The Company collects only what we need and will not share your personal information with any third parties other than we identity verification partner. We get information about you in a range of ways. We may collect your name, email address, and other information when you give it directly to us on our site, from other sources, and through automatically logged information about you, your computer, mobile device, or any access device upon visiting out site. This may include IP address, device information, name, type, operating system, network information, web log information, browser, and the pages accessed on our website. It may also include geographical location data to determine your location.
We do not collect any sensitive data such as: race or ethnic origin, political opinions, religious or philosophical beliefs, trade union memberships, genetic of biometric data, health or mortality, sex life or sexual orientation, unless required by law. However, you may be required to provide us with additional information and documents that we deem required to comply or maintain compliance with the law. These documents include, but are not limited to, passports, driver’s licenses, utility bills, photographs, government identification cards and such other documents that may be requested by the Company.
The Company may refuse your access to the Site should you fail to submit any or all of the required documents and information, or should the Company have any doubt on the validity, veracity, accuracy, authenticity and genuineness of the documents and information.
We collect Personal Data about you, subject to applicable law, from a variety of sources as follows:
• We obtain your Personal Data when you provide it to us (e.g., where you contact us via email or telephone, or by any other means).
• We collect your Personal Data in the ordinary course of our relationship with you (e.g., in the course of communication with you or any other relevant and related activity).
• We collect Personal Data that you manifestly choose to make public, including via social media (e.g., we may collect information from your social media profile(s), to the extent that you choose to make your profile publicly visible).
• We receive your Personal Data from third parties who provide it to us (e.g., your employer; our customers; credit reference agencies; law enforcement authorities; etc.).
• We receive your Personal Data from third parties, where you purchase any of our products or services through such third parties.
• We collect or obtain Personal Data when you visit our Site or use any features or resources available on or through a Site. When you visit a Site, your device and browser may automatically disclose certain information (such as device type, operating system, browser type, browser settings, IP address, language settings, dates and times of connecting to a Site and other technical communications information), some of which may constitute Personal Data.
Creation of Personal Data: We may also create Personal Data about you, such as records of your interactions with us, and details of your accounts, subject to applicable law.
Relevant Personal and Sensitive Personal Data: The categories of Personal Data about you that we may Process, subject to applicable law, are as follows:
• Personal details: given name(s); preferred name; nickname(s), gender; date of birth / age; marital status; Social Security Number; Passport number(s); other Government(s) issued numbers (tax identification number, Green Card(s) number(s) including Driving Licence number); nationality; lifestyle and social circumstances; images of Passports; images of Driving Licences and other identification cards; images of Gun Licence(s); images of signatures; authentication data (passwords, mother maiden name, challenge/response questions and answers, PINs, face recognition, voice recognition) and photograph, visual images, personal appearance and behaviour.
• Family details: names and contact details of family members and dependents.
• Contact details: address; telephone number; fax number; email address; and social media profile details.
• Employment details: industry; role; business activities; names of current and former employers; work address; work telephone number; work fax number; work email address; and work-related social media profile details.
• Education history: details of your education and qualifications.
• Financial details: bank account numbers; credit card numbers; cardholder or account-holder name and details; instruction records; transaction details; and counterparty details.
• Views and opinions: any views and opinions that you choose to send to us, or publish about us on (including on social media platforms).
Processing your Sensitive Personal Data: We do not seek to collect or otherwise Process your Sensitive Personal Data, except where:
• the Processing is necessary for compliance with a legal obligation (e.g., to comply with our diversity reporting obligations);
• the Processing is necessary for the detection or prevention of crime (including the prevention of fraud) to the extent permitted by applicable law;
• you have manifestly made those Sensitive Personal Data public;
• the Processing is necessary for the establishment, exercise or defence of legal rights;
• we have, in accordance with applicable law, obtained your prior explicit consent prior to Processing your Sensitive Personal Data (as above, this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way); or
• Processing is necessary for reasons of substantial public interest and occurs on the basis of an applicable law that is proportionate to the aim pursued and provides for suitable and specific measures to safeguard your fundamental rights and interests.
We only Process Criminal Offenses Data, and national identification numbers, to the extent required or permitted by applicable law.
Purposes for which we may Process your Personal Data, and legal bases for Processing: The purposes for which we may Process Personal Data, subject to applicable law, and the legal bases on which we may perform such Processing, are:
USE OF PERSONAL INFORMATION
We use your personal to understand, process and meet your needs and preferences in using our services. These personal information can also be used to develop new, or improve on our existing services, and develop our business and operations.
We use your personal information to communicate via newsletter or email, for processing of your data, to determine your eligibility or authority to participate in certain activities or actions, and for compliance with the different requirements of the laws. We will not release your personally-identifying information to any third party without your consent, except as herein set forth.
The purposes for which we may Process Personal Data, subject to applicable law, and the legal bases on which we may perform such Processing, are:
AML/KYC: fulfilling our regulatory compliance obligations, including ‘Know Your Client’ checks; and confirming and verifying your identity (including by using credit reference agencies); and screening against government, supranational bodies (including but not limited to the European Union and the United Nations Security Council) and/ or law enforcement agency sanctions lists as well as internal sanctions lists and other legal restrictions. The Processing is necessary for compliance with a legal obligation; or The Processing is necessary in connection with any contract that you may enter into with us, or to take steps prior to entering into a contract with us; or We have a legitimate interest in carrying out the Processing for the purpose of protecting against fraud (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or the Company have obtained your prior consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way).
Client on-boarding: on-boarding new clients; and compliance with our internal compliance requirements, policies and procedures. The Processing is necessary in connection with any contract that you may enter into with us, or to take steps prior to entering into a contract with us; or We have a legitimate interest in carrying out the Processing for the purpose of on-boarding new clients (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms).
Credit worthiness: conducting credit reference checks and other financial due diligence. We have a legitimate interest in carrying out the Processing for the purpose of conducting financial due diligence (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or We have obtained your prior consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way).
Provision of products and services to you: administering relationships and related services; performance of tasks necessary for the provision of the requested services; communicating with you in relation to those services. The Processing is necessary in connection with any contract or agreement of whatever nature that you may enter into with us whether currently ort in the future, or to take steps prior to entering into a contract with us; or We have a legitimate interest in carrying out the Processing for the purpose of providing services to you (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or We have obtained your prior consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way).
Communicating with you via any means (including via the Site, email, telephone, text message, social media, post or in person) subject to ensuring that such communications are provided to you in compliance with applicable law; and maintaining and updating your contact information where appropriate. We have a legitimate interest in carrying out the Processing for the purpose of conducting marketing and prospecting (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or We have obtained your prior consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way).
Operation of our Site; operation and management of our Sites; providing content to you; displaying advertising and other information to you; and communicating and interacting with you via our Sites. The Processing is necessary in connection with any communication we are requested to provide you upon your inquiry, or contract that you may enter into with us of whatever nature, or to take steps prior to entering into a contract with us; or We have a legitimate interest in carrying out the Processing for the purpose of providing our Sites to you (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or We have obtained your prior consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way).
IT operations: management of our communications systems; operation of IT security; and IT security audits. The Processing is necessary for compliance with a legal obligation; or We have a legitimate interest in carrying out the Processing for the purpose of managing and operating our IT systems and ensuring the security of those systems (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms).
Health and safety: health and safety assessments and record keeping; and compliance with related legal obligations. The Processing is necessary for compliance with a legal obligation; or We have a legitimate interest in carrying out the Processing for the purpose of providing a safe and secure environment at our premises (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or The Processing is necessary to protect the vital interests of any individual.
Financial management: sales; finance; corporate audit; and vendor management. We have a legitimate interest in carrying out the Processing for the purpose of managing and operating the financial affairs of our business (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or We have obtained your prior consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way).
Research: conducting market or customer satisfaction research; and engaging with you for the purposes of obtaining your views on our products and services. We have a legitimate interest in carrying out the Processing for the purpose of conducting research and producing analysis (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or We have obtained your prior consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way).
Security: physical security of our premises (including records of visits to our premises and CCTV recordings); and electronic security (including login records and access details, where you access our electronic systems). The Processing is necessary for compliance with a legal obligation; or We have a legitimate interest in carrying out the Processing for the purpose of ensuring the physical and electronic security of our business and our premises (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms).
Investigations: detecting, investigating and preventing breaches of policy, and criminal offences, in accordance with applicable law. The Processing is necessary for compliance with a legal obligation; or We have a legitimate interest in carrying out the Processing for the purpose of detecting, and protecting against, breaches of our policies and applicable laws (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms).
Legal compliance: compliance with our legal and regulatory obligations under applicable law. The Processing is necessary for compliance with a legal obligation.
Legal proceedings: establishing, exercising and defending legal rights. The Processing is necessary for compliance with a legal obligation; or We have a legitimate interest in carrying out the Processing for the purpose of establishing, exercising or defending our legal rights (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms).
Improving our products and services: identifying issues with existing products and services; planning improvements to existing products and services; and creating new products and services. We have a legitimate interest in carrying out the Processing for the purpose of improving our products or services (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or We have obtained your prior consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way).
Risk Management: Audit, compliance, controls and other risk management. The Processing is necessary for compliance with a legal obligation; or We have a legitimate interest in carrying out the Processing for the purpose of managing the levels of risk to which our business is exposed (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms).
Fraud prevention: Detecting, preventing and investigating fraud. The Processing is necessary for compliance with a legal obligation; or We have a legitimate interest in carrying out the Processing for the purpose of detecting, and protecting against, fraud (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms).
SHARING AND DISCLOSURE OF PERSONAL INFORMATION
In addition, we may disclose your Personal Data to:
• you and, where appropriate, your family, your associates and your representatives;
• clients and customers of our businesses;
• credit reference agencies;
• anti-fraud services;
• Governmental, legal, tax and regulatory, or similar authorities, ombudsmen, and central and/or local government agencies, upon request or where required, including for the purposes of reporting any actual or suspected breach of applicable law or regulation;
• accountants, auditors, financial and tax advisors, lawyers, notaries and other outside professional advisors, subject to binding contractual obligations of confidentiality in accordance with applicable law;
• banks, non-bank lenders, company administrators, trade and corporate registries and depositaries;
• general partners of funds related to the Company;
• debt-collection agencies and tracing agencies;
• data aggregation services;
• accreditation bodies;
• any relevant party, claimant, complainant, enquirer, law enforcement agency or court, to the extent necessary for the establishment, exercise or defence of legal rights in accordance with applicable law;
• any relevant party for the purposes of prevention, investigation, detection or prosecution of criminal offences or the execution of criminal penalties, including safeguarding against and the prevention of threats to public security in accordance with applicable law;
• to any relevant party in connection with AML/KYC requirements; any relevant third party acquirer(s), in the event that we sell or transfer all or any relevant portion of our business or assets (including in the event of a reorganization, dissolution or liquidation) or the assets or business of our funds;
If we engage a third-party Processor to Process your Personal Data, the Processor will be subject to binding contractual obligations to: (i) only Process the Personal Data in accordance with our prior written instructions; and (ii) use measures to protect the confidentiality and security of the Personal Data; together with any additional requirements under applicable law.
INTERNATIONAL TRANSFER OF PERSONAL DATA
Because of the international nature of the activities of the Site and the Company, we may need to transfer your Personal Data to our partners, affiliates and subsidiaries, and to third parties as noted in Section 3 above, in connection with the purposes set out in this Policy. For this reason, we may transfer your Personal Data to other countries that may have different laws and data protection compliance requirements, including data protection laws of a lower standard, to those that apply in the country in which you are located.
Where we transfer your Personal Data to other countries, we do so on the basis of:
• European Commission’s adequacy decisions;
• our binding corporate rules;
• suitable standard contractual clauses; or
• other valid transfer mechanisms.
We retain personal information we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal requirements). When we have no ongoing business need to process your information, we will delete it, or if this is not possible (for example, because your personal information has been archived), then we will securely store your personal information until deletion is possible.
It is possible that personal information may be stored in a secure blockchain, which are by nature, immutable. The Company does not and cannot control, the use, access, decryption, and storage of the data. The Company does not and cannot guarantee the privacy of the data stored in the blockchain.
We have implemented appropriate technical and organizational security measures designed to protect your Personal Data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, unauthorised access, and other unlawful or unauthorised forms of Processing, in accordance with applicable law.
We endeavor to take all reasonable steps to protect your personal information, but cannot guarantee the security of any data you disclose online. Please note that email is not a secure medium and should not be used to send confidential or sensitive information. You accept the inherent security risks of providing information over the Internet and will not hold us responsible for any breach of security, unless this is due to our negligence or willful default.
You are responsible for ensuring that any Personal Data that you send to us are sent securely.
INFORMATION CHOICES AND CHANGES
Our marketing emails may tell you how to “opt-out” or unsubscribe. If you opt out, we may still send you non-marketing emails. Non-marketing emails include emails about your accounts and our business dealings with you.
You may send requests about personal information to our Contact Information. You can request to change contact choices, opt-out of our sharing with others, and update your personal information.
You may send requests about personal information to our Contact Information. You can request to change contact choices, opt-out of our sharing with others, and update or delete your personal information. You can also ask to review any of the personal information that we have retained, how we have used it, and to whom we have disclosed it at any time by contacting us. Subject to certain exceptions prescribed by law, and provided we can authenticate your identity, you will be given reasonable access to your personal information and will be entitled to challenge the accuracy and completeness of the information and have it amended as appropriate.
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Xen Technologies Pte. Ltd.
5 Temasek Boulevard #04-03A Suntec Tower Five, Singapore (038985)
Email: [email protected]
RIGHTS SPECIFIC TO THE GDPR
If you are a data subject for purposes of the GDPR, you have a number of important rights, including rights to:
Fair processing of information and transparency over how we use your use personal information;
● Access to your personal information and to certain other supplementary information that this Policy is already designed to address;
● Require the correction of any mistake in the personal information that we hold about you;
● Require the erasure of personal information concerning you in certain situations;
● Receive the personal information concerning you that you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit that data to a third party in certain situations;
● Object at any time to the processing of your personal information for direct marketing;
● Object to decisions being taken by automated means that produce legal effects concerning you or similarly significantly affect you;
● Object in certain other situations to our continued processing of your personal information; and
● Otherwise restrict our processing of your personal information in certain circumstances.
● For further information on each of these rights, including the circumstances in which they apply, guidance is available from applicable data protection authorities.
By continuing to access this site and using the Services, you signify your agreement to this Policy. The Company reserves the right to change this Policy at any time. If we make any material changes to this Policy, the revised Policy will be posted here and notified to our users at least 30 days prior to the changes taking effect, so that you are always aware of what information we collect, how we use it and under what circumstances we disclose it. Please check this page frequently to see any updates or changes to this Policy.
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