1. Introduction
This Privacy Policy (the “Policy”) explains how HedgerX Exchange (“HedgerX”, “we”, “us”, or “our”) collects, processes, uses, and discloses your personal data when you access or use our products and services. As the data controller, HedgerX is responsible for ensuring that your personal information is handled in compliance with applicable data protection laws.
We are committed to safeguarding your privacy. If we request certain personal information that can identify you when using our platform, you can be assured that such data will only be used in accordance with this Policy.
To protect your personal data from unauthorized access, disclosure, alteration, or misuse, we implement appropriate physical, electronic, and administrative security measures. By submitting your information, registering an account, or using any HedgerX products or services, you acknowledge that you have read, understood, and agreed to the practices described in this Policy. You also consent to our collection, use, and disclosure of your personal data as outlined herein.
HedgerX reserves the right to modify, update, or amend this Policy at any time at our sole discretion. If you do not agree with any part of this Policy, you should immediately stop using our products and services and refrain from providing any personal data. Please note that if you decline to provide required information or withdraw your consent to our data processing activities, we may not be able to offer or continue providing certain services to you.
2. Objective
This Privacy Policy aims to:
1. Establish a clear set of standards governing the collection, use, disclosure, and protection of your personal data.
2. Demonstrate our ongoing commitment to protecting your privacy and addressing any related concerns.
3. Explain how your personal data is collected, processed, retained, and shared.
4. Ensure our compliance with the Personal Data Protection Act 2010 (“PDPA”).
5. Facilitate our continued adherence to evolving regulations and best practices in personal data protection.
3. Scope
This Privacy Policy explains:
The types of personal data we collect How we collect personal data How we use your personal data How and when we disclose personal data How we protect your personal data Cross-border data transfers Additional matters relating to personal data (e.g., retention, access rights)
4. Types of Personal Data
Some HedgerX products and services require us to identify you to provide proper support and comply with regulatory requirements. When you register, access our services, submit forms, or interact with us via email, phone, SMS, or other channels, we may request information that can identify you, or that can reasonably be used to identify you.
Personal data collected may include, but is not limited to:
Contact Information: name, NRIC/passport/ID number, phone number, address, email address, and any details submitted through forms or account opening documents.
Voluntary Information: any additional data you choose to provide, such as information shared via email or during communications.
Financial Information: payment details or transaction-related information.
Corporate Information: data provided by entities under lawful contracts.
Trading Activity: investment history, transaction volume, trading patterns, and behavioral analytics. Communication Records: email metadata, call logs, and other communication records.
Technical Data: device information, browser type, connection details, IP address, cookies, geolocation, analytics data, and Website usage statistics.
5. How We Collect Personal Data
We collect personal data through several methods, including:
Account Registration: when you create an account on our Website.
Customer Interaction: through product usage, customer surveys, participation in promotions, or during support interactions.
Transactional Activity: through analysis of your account activity, payments, transfers, and trading behavior.
Direct Communications: through forms, emails, letters, or phone calls. Calls may be recorded for quality assurance, training, and security.
Third Parties: including credit agencies, regulatory bodies, identity verification providers, and analytics services.
Technology-Based Collection: via cookies, geolocation tools, device analytics, and third-party tracking services.
Other Authorized Sources: where you have consented or where not otherwise restricted.
6. How We Use Personal Data
We may use your personal data for one or more of the following purposes:
To fulfill the specific purpose for which the data was provided. To verify your identity as required by applicable laws and regulatory authorities. To confirm investment eligibility where legally required. To comply with all regulatory, statutory, and governmental requirements. To maintain internal records as part of our normal business operations. To validate your eligibility to access our Website, products, and services. To process and respond to applications, inquiries, or requests. To conduct KYC (Know Your Customer) and AML/CFT (Anti-Money Laundering / Counter-Terrorist Financing) checks. To meet our legal and regulatory obligations. To inform you about updates, new products, or services you may be interested in (where consent is given). To notify you of changes to our services or platform operations. To analyze, improve, and maintain the performance of our Website and services. To comply with legal proceedings, enforcement actions, or to protect our legal rights. For any purpose that a reasonable person would consider appropriate under the circumstances, with notice provided to you as required.
7. Disclosure of Personal Data
To provide our services and comply with legal obligations, we may disclose your personal data to:
Agents, affiliates, service providers, and professional advisers acting on our behalf. Organizations assisting in processing or fulfilling your transactions. Law enforcement, regulatory bodies, and government authorities. Your authorized advisers (e.g., lawyers, accountants, auditors). Individuals authorized by you to operate or access your account.
Some of these parties may be located outside your jurisdiction. By using our services, you consent to cross-border transfers of personal data.
Outside of the above scenarios, we will not disclose your personal data except:
Where you have provided consent. Where required or permitted by law. Where ordered by a court or regulatory authority. Where needed to fulfill contractual obligations. Where required by relevant regulators inside or outside your country.
8. Security of Personal Data
Your personal data is stored securely in both electronic and physical formats. HedgerX maintains security safeguards designed to prevent unauthorized access, disclosure, alteration, or destruction of your personal data.
However, you acknowledge that:
Internet transmissions are not completely secure. Information sent to us is at your own risk. HedgerX cannot guarantee that unauthorized access will never occur.
In the event of a data breach, HedgerX will make reasonable efforts to notify affected individuals promptly.
Your password is encrypted and cannot be viewed by HedgerX staff. You are responsible for maintaining the confidentiality of your login credentials and for logging out after use.
If you suspect unauthorized account access, contact us immediately at support@hedgerx.com.
9. Global Company
Your personal data may be transferred, stored, or processed outside your home jurisdiction. These countries may have different data protection laws.
Processing may be carried out by HedgerX employees or approved third-party service providers, including for identity verification, payment processing, and customer support.
By submitting your personal data, you consent to international data transfers as described in this Policy.
10. Additional Matters Relating to Personal Data
Retention
We retain your personal data for the duration of your relationship with HedgerX and for as long as necessary thereafter to protect our interests, comply with legal obligations, and follow internal policies.
Incomplete Information
Where certain data is required (e.g., account opening), we may be unable to provide services if you decline to supply necessary information.
Access and Updates
You may request access to or correction of your personal data by contacting customer support. We may require identity verification and supporting documents before processing such requests.
Revisions to this Policy
We may revise this Policy from time to time. Material updates will be communicated via email or Website announcements.
Language
This Privacy Policy is issued in English.
A Korean version is available upon request.
In the event of any inconsistency, the English version prevails.
Contact Us
For questions about this Privacy Policy or for Korean-language requests, please contact HedgerX support.