GLX Privacy Policy

In this Privacy Policy, “GLX”, “we” or “us” refers to GLX Pte. Ltd (a company registered in Singapore), and GLX Digital Limited (a company registered in Australia) and their related bodies corporate.

GLX is committed to protecting your privacy. We understand your concerns with regard to how information about you is used and disclosed, and we appreciate your trust that we will do so sensibly and carefully. This notice (this Privacy Policy) describes what information we collect about you, how we collect it, how we use it, with whom we may share it, and what choices you have regarding it. This Privacy Policy is incorporated into and forms part of the Terms of Use and the Privacy Collection Statement on the GLX website found at www.glxdigital.com (Site). We encourage you to become familiar with the terms and conditions of this Privacy Policy, the Privacy Collection Statement and the Terms of Use. By accessing and using the Site, you agree that you have read and understand this Privacy Policy and you accept and consent to the privacy practices (and any uses and disclosures of information about you) that are described in this Privacy Policy.

We comply with the Australian Privacy Principles (APPs) under the Privacy Act 1988 (Cth), the Singapore Personal Data Protection Act (PDPA) and the European Union General Data Protection Regulations (GPDR), which regulate how we handle the information you supply when subscribing to a software licence agreement to use any of our trade management software or other services (Services).

Type of personal information that may be collected

We may collect certain personal information (as defined in the APPs) or personal data (for the purposes of the GDPR) including, but not limited to, (a) identification data (for example your name, e-mail address, mailing address, passport information, contact number, company details, position within company); (b) information about your connection and device capability in connection and interaction with our Site; (c) electronic identification data (for example internet protocol address and cookies); (d) your user profile (e) user subscription data (including company incorporation number and registered business address (with (a) to (e) collectively being, Personal Information) via our Site. The provision of such Personal Information by you is not mandatory, but may be required in order to use or access certain web pages and/or sections of our Site or our Services.

Use of personal information

The main purposes for which we collect, hold and use Personal Information are:

  • For subscription of our Customers to use the Services;
  • To provide our Services;
  • To respond to an individual’s request;
  • To operate, evaluate and improve our business;
  • To maintain contact with our users;
  • To keep subscribers and other users informed of the Services, updates to the Services, industry developments, and to notify them of relevant Service offerings;
  • For general management and reporting purposes, such as invoicing and account management as necessary; and
  • Other purposes related to our business.

If you choose not to provide us with Personal Information, we may be unable to do the above functions.

We may collect, hold and use Personal Information about individuals to market our Services, including by email. However, individuals always have the opportunity to elect not to receive further marketing information from us by writing to GLX at privacy@glxdigital.com

If we collect, hold or use Personal Information in ways other than as stated in this policy, we will ensure we do so pursuant to the requirements of the applicable privacy regulations.

Disclosing of personal information

We are committed to protecting your privacy. We do not sell, rent, distribute or otherwise make Personal Information commercially available to any third party, except as described in this Privacy Policy. We will not disclose your Personal Information to third parties unless you consent to such disclosure or in circumstances where such disclosure is required or authorised by law or to enforce our Terms of Use, to respond to claims from third parties, to protect the safety, interests, rights or property of ours or others or as permitted under this Privacy Policy.

You agree that we may disclose your Personal Information to third parties under any of the following circumstances:

  • When we have your consent to disclose the Personal Information;
  • When we disclose your Personal Information in accordance with this Privacy Policy;
  • We need to disclose your Personal Information to provide the Services that you have requested;
  • We need to disclose the Personal Information to third parties who on behalf of us provide Services to you or assist us in maintaining the quality and efficiency of our Services and our business operations (we will only provide such third parties the relevant information required for the provision of the Services, and the third parties are prohibited from keeping, using or disclosing such Personal Information for any unauthorised purpose); or
  • Such disclosure is otherwise required or permitted by law.

Transfer of personal information

GLX may exchange or store Personal Information with third party service providers who may be located overseas to process or back-up our information or to provide certain services to us. While these parties will be subject to confidentiality, they may not be required to comply with the data protection laws as the country in which you initially provided the personal data may have different disclosure requirements under their local laws. Although information is encrypted where possible and GLX will take reasonable efforts to protect your information, when you agree to this Privacy Policy you acknowledge that GLX will not be responsible for any overseas third party and you also acknowledge and agree to overseas storage, processing and transfer of your Personal Information.

You also acknowledge and agree that information that you provide may be stored or processed in, or transferred to, servers of our affiliates and of our service providers.

While we will take reasonable care in preventing the loss, misuse or alteration of your Personal Information, you acknowledge that the security of data transmitted over the Internet cannot be guaranteed.

We may sell or buy subsidiaries or business units. In such transactions as well as in the event that all or substantially all of our assets are acquired by a third party, your Personal Information will generally be one of the transferred business assets. We reserve the right to include your Personal Information, collected as an asset, in any such transfer to a third party.

Managing personal information

GLX takes reasonable steps to protect Personal Information it holds from misuse, interference and loss and from unauthorised access, modification or disclosure.

The time period for which we keep Personal Information depends on the purpose for which we collected it. Where Personal Information is no longer required for the purpose for which it was collected, reasonable steps will be taken to destroy or permanently de-identify the information, unless we are legally required to retain it. Unsolicited Personal Information received from third parties that does not serve an appropriate purpose will be destroyed.

Your rights

We will ensure that your Personal Information is accurate and up to date. Therefore, please advise us of any changes to your information. You are entitled to request details of the information we hold about you, except in certain circumstances set out in the applicable data protection law and regulations, and to have it rectified or deleted as required by applicable data protection legislation. If we deny you access to your Personal Information, we will provide you with reasons as to why. We may charge you an access fee to cover our costs of gathering and providing the information.

In addition to your rights to access and correct your personal data and lodge a complaint relating to how we handle your personal data as set out in this policy, if the GDPR or other jurisdiction’s data and privacy law applies, you may, under certain conditions, have the following rights available:

  1. to object to any processing of your personal data that we process on the lawful basis of legitimate interests, unless our reasons for the underlying processing outweighs your interests, rights and freedoms;
  2. to withdraw your consent where we have processed any of your personal data based on consent;
  3. to object to direct marketing (including any profiling) at any time;
  4. to ask us to delete personal data that we no longer have lawful grounds to process; and
  5. to object to the use of automated decision making.

If you wish to have your Personal Information deleted or would like to exercise any of the above rights (to the extent applicable to you), please contact GLX at privacy@glxdigital.com:

Post: Attention
The Privacy Officer
GLX Digital Ltd
Level 3, 435 Roberts Road Subiaco
PERTH WA 6008

If you wish to know what Personal Information we hold about your or think that any of the information we hold about you is inaccurate, you can contact GLX at privacy@glxdigital.com and we will take reasonable steps to ensure that it is corrected.

Cookies

Certain web pages and/or sections of our Site may use “cookies”, which are small data files sent to your computer, to store and track information about you when you access such web pages and/or sections of our Site. The cookies track information such as users’ profiles, the number of users, their frequency of use and their preferred websites.

The majority of Internet browsers will allow you to configure the settings used for cookies. If you disable the use of cookies on your web browser, or remove or block specific cookies from our Site, then you may not be able to gain access to all of the materials, facilities and Services provided on our Site.

We allow certain third party companies to collect certain anonymous information when you visit our Site. These companies may use non-personally identifiable information during your visits to our Site and other websites in order to provide advertisements about goods and services likely to be of greater interest to you. These companies typically use a cookie or a third party web beacon to collect this information.

Links to other sites

GLX is not responsible for the privacy practices or the content of web sites that are linked on the GLX Site. Please refer to the Terms of Use.

Changes to Privacy Policy

GLX operates in a dynamic business environment. Over time, aspects of our business may change as we respond to changing market conditions. This may require our policies to reviewed and revised. We reserve the right to change this Privacy Policy at any time and notify you by posting an updated version of the Privacy Policy on the Site.

Acknowledgement

BY ACCESSING OR USING THE SITE, YOU ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTAND, AND CONSENT TO THE PRIVACY PRACTICES, AND TO THE USES AND DISCLOSURES OF INFORMATION WE OBTAIN ABOUT YOU, THAT ARE DESCRIBED IN THIS PRIVACY POLICY, AND YOU AGREE TO BE BOUND BY THE TERMS OF USE REFERENCED ABOVE.

This Privacy Policy was last updated on 28 March 2023.

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