1.INTRODUCTION

1.1        Signal Capital (hereinafter referred to as the “Company”, “We” or “Our”), is incorporated under the laws of Saint Vincent and the Grenadines. Signal Capital a regulated broker through its partnership with Karios Markets with the Registration Number HA00824763 and an authorized investment dealer with license numbers BFX2024166 

1.2        We provide market access and trade execution services in Foreign Exchange, Contracts for Difference (CFDs), and exchange-based products commonly known as an “Instrument” to retail and institutional investors. Our Trading is provided via electronic trading Website Platform such as MetaTrader 4, MetaTrader 5. We allow retail and institutional Users to speculate on the global foreign exchange market, and what is known as margin forex Trading.

1.3         The privacy of Investors/Traders/Managers/Website and associated application vistor’s Personal Information/Data is vital to us. We adhere to the Global Privacy Laws, California Consumer Privacy Act (“CCPA”), Children’s Online Privacy Protection Act (“COPPA”), General Data Protection Regulation (“GDPR”), Australian Privacy Principles (“APPs”) contained in the Privacy Act 1988 (Cth) (“Privacy Act”), Personal Data Protection Act 2012 of Singapore (“PDPA”), the post-Brexit privacy law publicly known as the UK GDPR and Protection of Personal Information Act 4 of 2013, as amended, consolidated, or re-enacted from time to time, including all schedules and regulations thereto (“the POPI Act”).

1.4        This Privacy Policy explains to you how we collect, retain, process, share, transfer, and handle your Personal Data (as defined below) when you use our website, assoaied applications, downloads, product, or services (collectively, “Services”) and describes the sorts of Personal Information we collect, use, disclose, and our purposes for doing so.

1.5        Irrespective of which country you live in, you authorize us to transfer, store, and use your information publicly on our Website Platform in Saint Vincent and the Grenadines, the United States, Australia, European Union, the U.K., and the other country where we operate subject to applicable law.

1.6         “Personal Information” is information that can be used to reasonably identify you either directly or through your profile while connecting to any part of signalcapital.net and its related Applications and downloads available from time to time at our website. For example, your name, address, date of birth, incorporation number, gender, email address, and phone number are generally considered to be Personal/Entity Information. Personal Information that we collect can also consist of information about your individual preferences.

1.7         The Content and information you share on our Website Platform and its associated Applications may contain Personal Information, sensitive information, or a mixture of them.

1.8        This Privacy policy applies to your Personal Information once you use our Website Platform and its associated Applications but does not apply to Third-Party Sites. We aren’t responsible for the privacy policies or content of Third Party Sites.

1.9         For the avoidance of doubt, unless stated otherwise, this Privacy policy will govern our collection of your Personal Information.

1.10        This Privacy policy would be reviewed and updated from time to time. The current Privacy Policy with “last update” shall be published on our Website Platform. We encourage you to check our Website Platform periodically to make sure that you are aware of our current policy.

1.11 This Policy constitutes a legally binding agreement between you (“you” or “user”) and us. By visiting, accessing, or using the Website, or sending the information to us in any other form or manner, you agree and accept the terms of this Privacy Policy, as modified from time to time, and you consent to the collection and use of information in the manner described in this Policy. We advise you to carefully read this Policy and to periodically refer to it so that you are aware of any updates that may have been made. Only the last updated Policies shall be applicable.

IN CASE YOU DO NOT AGREE TO THE TERMS OF THIS PRIVACY POLICY, PLEASE IMMEDIATELY STOP USING THE SERVICE, AND WHEREVER APPLICABLE UNINSTALL IT.

2. COLLECTION OF PERSONAL DATA

The Company collects different types of Personal Data through the Company’s Platform from Users who visit the Platform or access, use, or request products and services offered by the Company.

For establishing a contractual relationship with the Company, you must provide certain Personal Data to the Company. Users who do not wish to furnish such Personal Data will not be able to register an account with the Company or be provided with other products and/or services of the Company.

Users have a responsibility to ensure that the Personal Data they provide to the Company and recorded in their personal account remains accurate and up to date throughout the period of their contractual relationship with the Company.

In addition to the information provided by Users, the Company also lawfully collects and processes Personal Data from publicly available sources (including, inter alia, the press, social media, and the internet) and third-party risk management software solutions in order to meet its regulatory obligations and for confirming the validity of the provided information.

The Personal Data received from the User, collected and processed by the Company is required for the communication, identification, verification, and assessment of the business relationship establishment with the User, contract performance, and legal compliance. The following Personal Data may be collected from Users depending on the product and/or service the Company provides to him:

• Contact details such as the User’s name, e-mail address, and phone number.
• Identification details such as the User’s identification or passport number.
• Biographical and demographic data such as gender, age, ethnicity, education, occupation, the User’s financial trading experience, and whether he has a prominent public function status (PEP).
• Financial information such as the User’s income status, bank account number and account details, tax information and other financial information.
• Information relevant to the services that the Company provides to the User such as the User’s transactions and communication records with the Company.
• Details of visitors’ and Users’ visits to the Company’s website and information collected through cookies and other tracking technologies including IP address and domain name, browser version, operating system, and geolocation.
• Information in relation to criminal convictions and offenses to the extent required and/or permitted by applicable law.
• Your marketing preferences.
• Trading knowledge and experience
• Usernames and passwords
• Information related to your trading account including your account history, activity, and orders
• National insurance number
• Transaction reporting reference
• Power of attorney/agent details
• Phone device type
• Operating system
• Device ID
• Cookie ID
• Google 360 ID
• GUID
• Information about your use of our services, products, and facilities (including information gained when you use our learning tools, demo accounts, and trading simulators)
• Sort code
• Usage data.

3. HOW THE PERSONAL INFORMATION IS COLLECTED BY US

The types of personal information we collect depend on how you use our services or how you interact with us as well as the requirement of applicable laws. We collect information that you simply provide to us, the information we obtain automatically once you use our Services, and personal information from other sources such as third-party services and organizations, as described below;

3.1        Information You Provide to Us Directly;

We may collect the subsequent personal information (KYC) that you provide to us.

Account Creation/Downloads: We may collect information once you create an account, download, register/ pre-registration with us, or log in, like name, email address, and/or username.

Your Communications with Us: We may collect personal information provided in onboarding forms, email address, telephone number, or address when you request information about our Services, register for our newsletter, podcasts, or guides, ask for customer or technical support, or otherwise contact us through blogs/comments.

Surveys: We may get in touch with you to participate in surveys. If you opt to participate, you’ll be asked to provide certain information which may include personal information with an option to get free gifts.

Interactive Features: We and other users of our Services may obtain personal information from you submitted or made available through our interactive features introduced from time to time (for example messaging and chat features, commenting options, forums, blogs, and social networking pages). Any information you provide through the general public sharing features of the Services (referred to herein as “User Content”) shall be regarded as “public,” unless otherwise required by applicable law, and isn’t subject to the privacy protections mentioned herein. Please be careful before providing any information which will identify you in the real world to other users.

Conferences, Trade Shows, and Other Events: We may collect personal information from individuals once you attend conferences, trade shows, and other events organized by Signal Capital from time to time.

Business Development and Strategic Partnerships: We may collect personal information from individuals and third parties to assess and pursue potential business/investment/trading/managing opportunities announced by Signal Capital from time to time.

3.2        Information Collected Automatically: Once you use our Services, we may automatically collect personal information:

Automatic Data Collection: We may collect certain information automatically once you use our Services, like your Internet protocol (IP) address, Internet service provider,  location information (including approximate location derived from IP address), user settings, MAC address, cookie identifiers, mobile carrier, mobile advertising, and other unique identifiers, browser or device information. We can also collect information about how you use our Services, such as pages you visited before, during, and after using our Services, the links you click, the types of content you interact with, the frequency and length of your activities, and other information.

Cookies, Web Beacons/Pixel Tags, and Other Technologies: Third parties  provide content, advertising, or other functionality on our Products & Services. They may use technologies such as cookies, pixel tags, local storage, and other technologies to automatically collect information while you use our Products and Services. The utilization of such Technologies is subject to your consent. A pixel tag, also known as a web beacon, is a piece of code inherent in our Services that collects data about the usage of our Services. By utilizing pixel tags, we can track things like when a user has visited a particular website or clicked on a particular advertisement. Web beacons can also be included in e-mails to find out whether the messages have been opened, acted on, or forwarded.

3.3        Information Collected from Other Sources: We may collect information about you from other sources viz. third-party services and organizations. For example, if you access or use our Services through a third-party application (such as an app store, a social networking site, or a third-party login service), we may collect information from that third-party application that has been made available by you through your privacy settings.

4. USING OUR WEBSITE AND COOKIES:

We may collect Personal Information about you once you use and access our Website Platform and Sites. While we don’t use browsing information to identify you personally, we may collect anonymous Usage Information by utilizing cookies, pixel tags, and other tracking technologies (collectively “Cookies”). Cookies are small packets of knowledge that are downloaded onto your device when you access a website. Cookies hold specific information that helps an internet site ‘remember’ your actions and preferences over time. These are the kinds of Cookies that we may use to operate the Sites:

Strictly Necessary Cookies – These cookies are essential to make sure that the Sites work correctly, and record information that permits you to move around the Sites and navigate their features;

Performance Cookies – These cookies collect information about how you use the websites, such as how frequently you access them and whether you encounter any errors;  

Functionality Cookies – These cookies allow the Sites to recollect the choices you make to provide a more personalized experience;

Targeting/Advertising Cookies – These Cookies deliver targeted advertising to you supporting your interests and use of the Sites.

Cookies can also be used to collect data which may include Personal Information. For example, under the Privacy Act, a cookie that is connected to your account qualifies as Personal Information. We’ll handle the Personal Information collected through cookies in the same manner as any other Personal Information as described in this Privacy Policy. We can also utilize tracking technology such as Google Analytics and other analytics software (e.g. Appfigures) to collect information regarding usage patterns, preferences, location, and other data, including Google Analytics and other analytics software (e.g. Appfigures). Cookies can stay on your device temporarily (“Session Cookies”) or until you manually delete them (“Persistent Cookies”). You’ll adjust your browser settings at any time to block cookies, however, please note that doing so may limit our ability to supply the Services to you in a fully operational form.

5. DISCLOSURE AND SHARING OF PERSONAL INFORMATION

5.1        Your personal information is not sold, licensed, or otherwise disclosed to third parties for marketing purposes by Signal Capital. We do utilize the services of third-party service providers to send out our marketing, but they are allowed to use that information only if they have agreed to treat the information confidentially and to keep it secure. Signal Capital may be required to provide your personal information to the FSA and other regulatory and government bodies from time to time in St. Vincent & The Grenadines, the United States, the United Kingdom, and other countries. Signal Capital may also disclose your personal information to:

a.     Financial institutions and other similar organizations that it deals with in the course of its corporate activities or those that are nominated by you.

b.    External service providers and professional advisers (which may be located overseas) that provide services to Signal Capital.

c.   Any organization at your request or any persons acting on your behalf, including your financial adviser, broker, solicitor, or accountant.

d.    Any third parties where this is necessary to process a transaction or provide services which you have requested; or any authority to whom Signal Capital is required to disclose such information by law.

5.2        In the event that Signal Capital is subject to negotiations for the sale of its business (whole or part of), or sold to a third party or undergo a reorganization, you agree that any of your personal information which we hold may be disclosed to such party or its advisors as part of any due diligence process for the purpose of analyzing any proposed sale or reorganization or transferred to that re-organized entity or third party and used for the same purposes as you have agreed to under this Agreement.

6. USE OF PERSONAL INFORMATION

6.1        Signal Capital may keep and use such information to comply with any legal requirements or if it is necessary for our legitimate interest or for any one or more of the following purposes:

• To provide the services to you that you have requested including processing transactions.
• To confirm your identity.
• To maintain your personal profile.
• To manage your account.
• To keep you updated whilst you are a customer in relation to matters such as contracts you have traded and activities of Signal Capital.
• To manage and administer the products and services provided to you.
• To provide you with information regarding the products and services offered by Signal Capital.
• To develop an understanding of the products and services that you may be interested in obtaining from Signal Capital.
• To create anonymised statistical data.
• Considering any of your applications.
• Carrying out risk assessments.
• Complying with our legal and regulatory obligations.
• Performing our obligations under any contract we have with you.
• Administering our relationship with you including resolving queries or issues.
• Establishing and managing your account.
• Reviewing your ongoing needs.
• Checking your instructions to us.
• Investigating any complaint you may make.
• Providing evidence in any dispute or anticipated dispute between you and us.
• Recovering amounts payable.
• Training our staff.
• Undertaking product development and analysis.
• Detecting or preventing fraud or other crimes.
• Analytics, inter alia, with the help of the following services of Google Inc. and Facebook Inc.:

a.        Google Ads conversion tracking (Place of processing: U.S. – Privacy Policy)

b.        Google Analytics (Place of processing: U.S. – Privacy Policy)

c.        Google Tag Manager (Place of processing: U.S. – Privacy Policy)

d.        Facebook Ads conversion tracking (Place of processing: U.S. – Privacy Policy)

e.        Display Advertising extension for Google Analytics (Place of processing: U.S. – Privacy Policy)

• Contacting you—we may send you marketing material from time to time by post, email, telephone, SMS, mobile push notifications, web push notifications, messengers (Viber, Telegram, Facebook messenger, and other), or other electronic messaging services.
• Handling payments, inter alia, with the help of the following service providers:

a.        Neteller (Paysafe Group PLC)—Place of processing: Isle of Man – Privacy Policy

b.        Skrill (Skrill Ltd.)—Place of processing: U.K. – Privacy Policy

c.        2Checkout (2Checkout.com, Inc.)—Place of processing: U.S. – Privacy Policy

• Interaction with helpdesk platforms, inter alia, with the help of the following service providers:

a.        Zendesk (Zendesk Inc.)—Data storage location: U.S., Asia Pacific, or European Union – Privacy Policy

b.        SimpleSat (Duoventures Limited)—Place of processing: Hong Kong – Privacy Policy

• Managing contacts and sending messages, inter alia, with the help of the following service providers:

a.        Mandrill (The Rocket Science Group, LLC.)—Place of processing: U.S. – Privacy Policy

b.        Mailchimp (The Rocket Science Group, LLC.)—Place of processing: U.S. – Privacy Policy

c.        Bloomreach (Bloomreach, Inc.)–Place of processing: U.S. – Privacy Policy

• Remarketing and behavioural targeting, inter alia, with the help of the following service providers:

a.        Remarketing with Google Analytics (Google Inc.)—Place of processing: U.S. – Privacy Policy

b.        Facebook Remarketing (Facebook, Inc.)—Place of processing: U.S. – Privacy Policy

c.        Twitter Remarketing (Twitter, Inc.)—Place of processing: U.S. – Privacy Policy

d.        Facebook Custom Audience (Facebook, Inc.)—Place of processing: U.S. – Privacy Policy

e.        Twitter Tailored Audiences (Twitter, Inc.)—Place of processing: U.S. – Privacy Policy

f.        Google Ads Remarketing (Google Inc.)—Place of processing: U.S. – Privacy Policy.

6.2        You consent to Signal Capital using your personal information for the above-stated purposes.

6.3        Where we use your personal information for marketing purposes to inform you about Signal Capital’s products and services that might be of interest to you, you always have the right to ‘opt out’ of receiving such communication.

6.4        You can exercise the right at any time by contacting us using the details provided at the start of this policy. If we send you any marketing emails, we will always provide an unsubscribe option to allow you to opt out of any further marketing emails. If you “opt-out” of our marketing materials you will be added to our ‘suppression list’ to ensure we do not accidentally send you further marketing. When you unsubscribe from any postal marketing, you may initially still receive some content which has already been printed or sent, but we will remove you from any future campaigns. We may still need to contact your administrator for operational purposes, but we will make sure that those communications do not include direct marketing.

6.5        If you are an existing customer or are acting as a business we use your contact details as necessary for our legitimate interests in marketing to you and maintaining a list of potential customers.

6.6        If you are not an existing customer, and are not acting as a business, we will only contact you for marketing purposes with your consent (whether we have collected your details directly from you, or through a third party).

6.7        Signal Capital will only use your personal information for the purposes for which it collected it as set out in this policy unless Signal Capital reasonably considers a need to use it for another reason and that reason is compatible with the original purpose. If Signal Capital needs to use your personal information for an unrelated purpose, Signal Capital will notify you and will explain the legal basis which allows it to do so.

7. HOW SHALL WE PROTECT YOUR PERSONAL INFORMATION

7.1        We treat your Personal Information in strict confidentiality, and the server in which this data is to be stored includes the necessary industry-standard security measures to prevent accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access. We also take all reasonable steps to secure our physical premises and the digital storage media; use computer safeguards to ensure that your information is encrypted and sent across the web securely; and take back-ups of electronic systems regularly.

7.2  Notwithstanding that we will take all reasonable steps to keep your Personal Information secure, however, data transmission over the web is never guaranteed to be completely secure. We don’t and cannot completely guarantee the security and safety of any information you transmit to us or from any online services and it should be emphasized that you share this information at your own risk.

8. UPDATING YOUR INFORMATION 

8.1         You may inform Signal Capital at any time that your personal details have changed or that you wish Signal Capital to review, verify, correct or request the erasure of your personal information, withdraw your consent to the processing, or request that we transfer a copy of your personal information to another party. Please contact us via email at support@signalcapital.net

9. DELETING YOUR INFORMATION

9.1  Signal Capital will change or delete your personal information as per your instructions, unless we are required to hold it for regulatory or legal reasons, or  to deliver the services you have requested, or to maintain the requisite business records.

10. HOW DOES SIGNAL CAPITAL TREAT INTERNATIONAL DATA TRANSFERS?

It is possible that your personal information may be transferred outside of the country in which you currently reside and processed there. These other jurisdictions may have different data protection laws than the laws of the one in which you currently reside (and, in some situations, not as protective).

Signal Capital is a multinational group. It is possible that our servers might be  situated outside of the jurisdiction where the data was collected. We may store your personal information on servers outside your jurisdiction in order to provide quick access, reliability, and protection against server failure.

When we collect your personal information, we reserve the right to transfer it to or from any of the countries where we conduct the business. We may share your personal information with our company, affiliated companies, organizations that facilitate your access to our products or services, service providers, product content providers, and business partners located in various jurisdictions around the world. The principal jurisdictions where personal information is hosted by or on behalf of Signal Capital are the United States of America, Canada, the United Kingdom, Australia, UAE, Malaysia, South Africa, India, and Singapore.

Where your personal information is shifted or transferred by us or on our behalf, we put in place the necessary precautions to protect your personal information according to this Policy. These safeguards include implementation of applicable standard contractual clauses for transfers between our group companies, which require these companies to protect personal information they shift from the jurisdiction in which it was collected according to the applicable data protection law.

International transfers occur only when there is sufficient level of protection for the fundamental data protection rights of individuals, as required by applicable law. In some cases, we may decide to rely upon an adequacy decision to transfer personal information legally. We may depend on standard contractual clauses for transfer to and from, our affiliates, vendors, and business partners, personal information across jurisdictional borders, where applicable. Additional security measures may also be put in place where personal information is transferred.

11. EU CITIZENS’ PRIVACY RIGHTS

11.1 If you’re a user in the European Economic Area or the United Kingdom, you have certain rights under the respective European and UK General Data Protection Regulations (“GDPR”).  

These include the right to;

• be informed about our collection and use of your personal data. If you wish to seek information about your data collection, please contact us at support@signalcapital.net.
• access your personal data which we hold about you.
• have your personal data rectified in case you feel that the personal data collected by us is inaccurate or incomplete.
• request for the erasure or deletion of any of your personal data which we have.
• object to or restrict the processing of your personal data.
• object to us for using your personal data for a particular purpose.
• portability of your personal data.
• withdraw your consent at any time.

11.2        No fee is normally required

 You will not have to pay any fee to access your personal data or to exercise any other rights. However, if your request is excessive or unfounded, either we may charge a reasonable fee or refuse to comply with your request depending upon the circumstances.

11.3        Time Period to reply to the legitimate request 

As per GDPR Act, the statutory period to reply to a legitimate request is one month which may be extended by a further two months depending upon the complexity and number of the requests received from an individual.

For further information about your rights, you may contact the Information Commissioner’s Office or your local data protection authority in the European Economic Area (EEA). In case you have any complaint about our use of your personal data, you have the right to file a complaint with the Information Commissioner’s Office.

12. CALIFORNIA PRIVACY RIGHTS

12.1        California “Shine the Light” law – California Civil Code Section 1798.83, also referred to as California’s “Shine the Light” law permits residents of  California to request certain details about Personal Information we may confide in third parties for direct marketing purposes. If you’re a California resident and would like to request this information, please contact us at support@signalcapital.net. 

12.2        CALIFORNIA CONSUMER PRIVACY ACT – California residents have certain rights as are enshrined in the California Consumer Privacy Act of 2018.

Rights Of The California Residents;

California residents may request us to disclose to you what personal information we have collected, used, shared, or sold about you, and why we collected, used, shared, or sold that information. Specifically, you may request us to disclose the following for the period covering 12 months preceding the request of the user:

●         The categories of personal information collected by us.

●         Specific pieces of personal information collected by us.

●         The categories of sources from which the business collected personal information about the user.

●         The purpose for which we use the personal information of the user.

●        The categories of third parties with whom we shared the personal information of the user.

●         The categories of information that we sell or disclose to the third party.

Right To Opt-Out of Sale

California residents may request us to stop selling their personal information (“opt-out”). With some exceptions, we shall not sell the personal information after receiving your opt-out request unless you later provide authorization allowing us to do so again.  

For DO NOT SELL MY PERSONAL INFORMATION users are requested to send us an email at support@signalcapital.net with a request for confirmation of receipt of the email.

Request To Delete Personal Information  

California Customers can request us for deletion of their personal information which is available with us subject to certain exceptions.

Non-Discrimination

We shall not deny any services, charge a different price, or provide a different level of services just because the user exercised the rights under the CCPA.

However, if you refuse to provide us with your personal information or ask to delete or stop selling your personal information, we may not be able to complete the transaction as the information is necessary for providing the services.

If the user asks us to delete or stop selling the personal information, the user may not be able to continue participating in the special deals which we may offer.

Requests

All requests should be sent to us via email at support@SignalCapital.net with a request for confirmation of receipt of the email.

Time Frame

The time frame for responding to requests shall be 45 days from the date of receiving requests which shall be exclusive of the first and last day. If the end day falls on a weekend, then the time shall be extended to the next working day. Signal Capital shall have a right to extend the time frame for a further period of 45 days if required.

NOTE: If you would like to exercise your rights under the GDPR, CCPA, or other applicable data protection or privacy laws, please contact us at support@signalcapital.net with a request for confirmation of receipt of the email, specify your request, and reference the applicable law. We may ask you to verify your identity or invite more information about your request. We’ll consider and act upon any above request in accordance with applicable law. We’ll not discriminate against you for exercising any of those rights.

13. CANADA RESIDENTS’ PRIVACY RIGHTS

How and why we use personal information:

According to Canadian privacy laws we should take your permission or consent  before collection, use, and disclosure of your personal information. You agree and give your permission or consent to the collection, use, and disclosure of your personal information according to the terms of this Privacy Policy (as amended from time to time). If you have given your approval for us to use your information, you can revoke it through the privacy preferences.

International transfer of personal information:

Your personal information may be collected, used, or disclosed anywhere outside of Canada, including, but not limited to the locations of Signal Capital companies and affiliates as well as those of third-party partners, including affiliates and service providers. We shall make sure that entities acting on our behalf to which we have transferred your personal information are subject to technical and contractual restrictions. Please take note that when your personal information is moved to another country, it may be accessed by law enforcement and/or national security officials of that jurisdiction.

Your rights:

In case you have any questions concerning our use of your personal information, you should first contact us. Under some conditions, you may have the right to:

• Obtain information about our use of your personal information;
• Obtain a copy of the personal information that you have provided to Signal Capital or that has been collected about you by Signal Capital and is in the Signal Capital’s custody or control;
• Obtain information about your personal information that has been shared with or transferred to third parties or other Signal Capital entities;
• Request for correction and updation of the personal information held about you by Signal Capital;
• Request for deletion of any personal information that is no longer required to be maintained for a business or legal reason;
• Withdraw your consent, where the processing is based on consent so that we stop that particular processing;
• Request that we stop direct marketing to you;
• File a complaint with your supervisory authority (contact details given below) in case you believe that any of your rights have been infringed or that the  collection, use, and/or disclosure of your personal information has not been according to the applicable Canadian privacy legislation

Access to Information and Enquiries:

On receipt of a written request and identity verification, Signal Capital will give you access to your personal information that is in its custody or control, information about how your personal information is being used and information about  individuals or organizations to whom your personal information has been shared or transferred. A written request to access personal information should be forwarded to Signal Capital’s Office address mentioned in the “Contact Us” section of the Policy.

Upon receipt of a written access to personal information request, Signal Capital may charge a reasonable fee for providing personal information and the details of the fee shall be provided to you. Signal Capital may ask for a deposit of the fee.

Signal Capital will give personal information within 30 days and if not possible,  shall seek additional time if required. In some situations, Signal Capital might not be able to provide access to certain personal information or might be prevented by law from providing access to certain personal information.

Where an access request is partially or completely refused, Signal Capital will notify you in writing, providing the reason for refusal and outlining further courses of action available to you.

Enquiries and complaints:

If Signal Capital is unable to address your concerns or complaints, you may also get in touch with one or more of the following Canadian supervisory entities:

Office of the Privacy Commissioner of Canada
30, Victoria Street
Gatineau, Quebec
K1A 1H3
Toll-free: 1-800-282-1376
www.priv.gc.ca

Office of the Information and Privacy Commissioner of Alberta
Suite 2460, 801 6 Avenue SW
Calgary, Alberta
T2P 3W2
Toll-free:1-888-878-4044
generalinfo@oipc.ab.ca
https://www.oipc.ab.ca
Office of the Information and Privacy Commissioner for British Columbia
4th Floor, 947 Fort Street, Victoria BC
V8V 3K3
1-250-387-5629
info@oipc.bc.ca
https://www.oipc.bc.ca

14. SINGAPORE RESIDENTS’ PRIVACY RIGHTS

We are committed according to the due level of care  to Personal Data as presented in our Privacy Policy, and consistent with the Personal Data Protection Act 2012 of Singapore (“PDPA”).

This section applies if you give us personal information which is subject to the requirements of the PDPA.

By accessing this website, providing any information through this website, or continuing using our services, you accept all the terms of this Privacy Policy as modified from time to time.

International transfer of personal information:

By furnishing us your personal information, you expressly agree to the transfer of data containing your personal information outside of Singapore for the reasons described in this Privacy Policy.

Your rights:

According to Singapore law, you have the right to access, correct, or update your personal information. In case you want to exercise any of these rights, you can do so at any time by contacting us at the address mentioned in the “Contact Us” section.

Your exercise of these rights is subject to a few exceptions, such as when we are convinced on reasonable grounds that the correction should not be made (when you have made a correction request) or when providing your personal information might reveal personal information about another person (where you have made an access request).

15.  SUPPLEMENTAL NOTICE FOR NEVADA RESIDENTS

If you’re a resident of Nevada, you’ve got the right to opt-out of the sale of certain Personal Information to third parties who intend to license or sell that Personal Information. You’ll exercise this right by contacting us at support@signal capital.net with a request for confirmation of receipt of the email and with the topic line “Nevada Do Not Sell Request” and providing us with your name and the email address associated with your account. Please note that we don’t currently sell your Personal Information as sales are defined in Nevada Revised Statutes Chapter 603A. If you’ve got any questions, please contact us as set forth below.

16.  SOUTH AFRICA RESIDENTS’ PRIVACY PROTECTION RIGHTS

In South Africa, Signal Capital is deemed to be a responsible party in terms of the Protection of Personal Information Act 4 of 2013, as amended, consolidated, or re-enacted from time to time, including all schedules and regulations thereto (“the POPI Act”), and Signal Capital is obliged to comply with the provisions of the POPI Act. Use of the Website and any electronic transaction concluded with Signal Capital are governed by the laws of the Republic of South Africa. If the User accesses this Website from a location outside of the Republic of South Africa, the User is accountable to adhering to all the local laws.

17.  THE CHILDREN’S ONLINE PRIVACY PROTECTION ACT(COPPA)

The COPPA Act protects the privacy of children who are under the age of 13 years. Signal Capital respects the privacy of children and is committed to complying with the COPPA Act. Signal Capital does not collect any information from children who are under the age of  13 years. The parents or legal guardians are advised to contact us at support@signalcapital.net with a request for confirmation of receipt of the email if at any point it comes to their knowledge that their child who is under the age of 13 years has provided any kind of personal information to us. If we become aware that we have collected personal information from the child without parental consent, then we will delete the information at the earliest.

18.  USERS OUTSIDE AUSTRALIA, U.S., THE EU, AND UK

If you are a User of our Services from outside Australia, the US, the UK, and the European Union, by visiting the Service and providing us with data, you acknowledge and agree that your Personal Data could also be processed for the purposes identified in the Privacy Policy. In addition, your Personal Data could also be processed in the country in which it was collected and in other countries, where laws regarding the processing of Private Data may be less stringent than the laws in your country. By providing your Personal Data, you consent to such transfer.

19.  CHANGES TO PRIVACY POLICY

19.1        We may amend this Privacy policy from time to time at our sole discretion, particularly where we’d like to take into account and cater to any:

a.     business developments; or

b.     legal or regulatory developments.

19.2         If we make any changes, we’ll notify you by revising the date at the top of the Privacy policy and, in some cases, may provide you with additional notice (such as adding a statement to the Website Platform or sending you a notification). We recommend you to regularly review our Privacy Policy whenever you access the Services or otherwise interact with us to remain informed about our information practices and the ways you can help us to protect your privacy.

20.  RETENTION OF INFORMATION

General retention policy:

20.1 To decide the suitable retention period for personal information, we take into account a number of factors such as the amount, nature, and sensitivity of the personal information, the probable risk of harm from illegal/unauthorized access or disclosure of your personal information, the purposes for which we process your personal information and whether those purposes can be achieved through other means, and the applicable legal requirements.

20.2 Generally, Signal Capital will retain your information for five (5) years. In some circumstances, it may be essential to retain your information for a longer period of time to fulfill the purposes for which we collected it or for the purposes of meeting any legal, accounting, or reporting requirements.

Legal Claims:

20.3 Where Signal Capital considers there to be a risk to defend or bring legal claims, Signal Capital may retain your personal information as necessary for a legitimate interest in ensuring that Signal Capital can properly bring or defend legal claims. Signal Capital may also need to share this information with insurers or legal advisers. How long Signal Capital keeps this information will depend on the nature of the claim and how long Signal Capital considers there to be a risk that we will need to defend or bring a claim.

20.4 In some circumstances Signal Capital may anonymize your personal information so that it can no longer be associated with you, in which case Signal Capital may use such information without further notice to you.

21.  DATA BREACH REPORTING

       Subject to St. Vincent & the Grenadines Privacy Freedom of Information Act 2003 (‘Privacy Act’), Signal Capital is required to comply with the data breaches, and where the GDPR is applicable, the data breach notification provisions in the GDPR. In case you believe that there has been a breach of Privacy Laws, we invite you to contact us as soon as possible at support@signalcapital.net with a request for confirmation of receipt of the email.

22.  CONTACT US

     In case you have any questions or queries about this Privacy Policy, or to exercise your rights as detailed in this Privacy Policy, please contact us at support@signalcapital.net with a request for confirmation of receipt of the email.

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