PRIVACY POLICY

This policy, sets out the basis on which Modern Trade Technologies Pte. Ltd., a company incorporated under the laws of Singapore with its registered office address 100 Peck Seah Street, #08-14, PS100, Singapore 079333 and Unique Entity Number 202014408W, together with its subsidiaries, its holding company, subsidiaries of its holding company from time to time (collectively called "Modern Trade", “we”, “us”, or “our”), collects personal data from you and how we process such data.

By visiting our website https://www.moderntrade.co (our “Site”) or using our web or mobile application(s) or any other applications (collectively our "Apps"), software or services we provide from time to time (collectively our “”) or agreeing to our Standard Terms and Conditions (or Master Agreement, if different), you accept and consent to the practices set out below.

COLLECTION OF INFORMATION

1.1

For the purposes outlined in Clause 2, we may collect and process the following information about you and your clients and end-users:

(a)

Information you give us - information that you provide us (which may include your name, address, email address, telephone number, credit card information and other personal description) by filling in forms on our Site or our Apps, or by corresponding with us (by phone, email or otherwise), for example:

(i)

when you register for an account with us on our Site and in our Apps;

(ii)

when you report any problem to us;

(iii)

when you use certain features on our Site or our Apps;

(iv)

when you request any support from us; or

(v)

when you complete any survey or questionnaire we send you.

(b)

Information we collect about you - information automatically collected when you visit or use our Services, for example:

(i)

technical information, including the Internet protocol (IP) address used to connect your computer to the Internet and your log-in information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;

(ii)

details of any messages, transactions, purchases, payments (including but not limited to credit card information, if you have provided explicit consent for this) and/or any other form of data, information and/or communication you made, sent and/or received via our Services; and

(iii)

information about your visit, including the full Uniform Resource Locators (URLs), clickstream to, through and from our site (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call our customer service number.

(c)

Information about your clients and end-users

(i)

Information that you or your systems provide to us, which may include communications between you and your clients or end-users, and any other Customer Data as defined in our Standard Terms and Conditions ("Customer Data").

1.2

We will retain your personal data as long as it is required for business, legal and regulatory purposes. We may also retain your personal data as necessary for the uses in Clause 2.1 below. Your personal data may also be archived as long as the purpose for which the data was used still exists.

1.3

We will retain Customer Data for as long as necessary to fulfill the purposes outlined in this Privacy Policy and our Standard Terms and Conditions, unless a longer retention period is required or permitted by law. Upon termination of our services or upon your written request, we will delete or anonymise Customer Data in our possession, unless otherwise required by applicable law.

USES MADE OF THE INFORMATION

2.1

We use information held about you for the following purposes:

(a)

providing, improving and developing our services;

(b)

researching, designing and launching new features or products;

(c)

presenting content and information in our Site and our Apps in the most effective manner for you and for the device you use;

(d)

providing you with alerts, updates, materials or information about our services or other types of information that you requested or signed up to;

(e)

collecting overdue amounts;

(f)

complying with laws and regulations applicable to us in or outside of Singapore;

(g)

responding or taking part in legal proceedings, including seeking professional advice;

(h)

resolving disputes;

(i)

enforcing our agreements;

(j)

for direct marketing purposes (please see further details in Clause 2.2 below);

(k)

communicating with you and responding to your questions or requests; and

(l)

purposes directly related or incidental to the above.

(m)

collecting, processing and using Customer Data (including communications between you and your clients or end-users) for the purposes of providing and enhancing our Services, maintaining, improving, and developing our products and services, and training, developing, and improving our artificial intelligence (AI) models and algorithms.

2.2

We intend to use your personal data in direct marketing (i.e. offering or advertising products or services by sending the relevant information directly to you). We require your consent specifically for this purpose and you may opt out any time. For the purpose of this clause:

(a)

the personal data that may be used in direct marketing are those that you provide to us or we collect from you under Clause 1.1 above;

(b)

the type of services or products that may be offered or advertised will be our services or products, promotions, loyalty or reward programmes, events or activities and/or those of our affiliates or business partners;

(c)

the relevant information may be sent to you by email, direct mail, SMS, telephone call, mobile app notification, and other means of communication;

(d)

you may opt out any time by emailing us at hello@moderntrade.co. We will cease to send you marketing information without charge.

DISCLOSURE OF YOUR INFORMATION

We will keep your personal data we hold confidential but you agree we may provide information to:

(a)

any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in Section 5 of the Companies Act 1967;

(b)

personnel, agents, advisers, auditors, contractors, financial institutions, and service providers in connection with our operations or services (for example staff engaged in the fulfilment of your order, the processing of your payment and the provision of support services);

(c)

our overseas offices, affiliates, business partners and counterparts (on a need-to-know basis only);

(d)

persons under a duty of confidentiality to us;

(e)

persons to whom we are required to make disclosure under applicable laws and regulations in or outside of Singapore; or

(f)

actual or proposed transferees of our operations (or a substantial part thereof) in or outside of Singapore.

(g)

third-party service providers, including providers of large language models (LLMs) and other AI technologies, for the purposes stated in Clause 2.1(m). We will ensure that such third parties are bound by appropriate confidentiality and data protection obligations.

We may amend these terms from time to time by posting the updated terms on our Platform. If we make material changes, we will notify you of the changes before they become effective. By continuing to use our Platform and our services after the changes come into effect means that you agree to be bound by the revised policy.

4.1

Our Site uses cookies to distinguish you from other users of the Site. This helps us to provide you with a good experience when you browse our Site and also allows us to improve our Site.

4.2

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree to the use of cookies. Cookies contain information that is transferred to your computer's hard drive.

4.3

We use persistent cookies and session cookies. A persistent cookie stays in your browser and will be read by us when you return to our Site or a partner site that uses our services. Session cookies only last for as long as the session (usually the current visit to a website or a browser session).

4.4

We use the following cookies:

(a)

Strictly necessary cookies - These are cookies that are required for the operation of our Site. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.

(b)

Analytical/performance cookies - They allow us to recognise and count the number of visitors and to see how visitors move around our Site when they are using it. This helps us to improve the way our Site works, for example, by ensuring that users are finding what they are looking for easily.

(c)

Functionality cookies - These are used to recognise you when you return to our Site. This enables us to personalise our content for you, greet you by your name and remember your preferences (for example, your choice of language or region).

(d)

Targeting cookies - These cookies record your visit to our Site, the pages you have visited and the links you have followed. We will use this information to make our Site and the information displayed on it more relevant to your interests.

4.5

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you do so, you may not be able to access all or parts of our Site.

4.6

We may use third-party web services on our Site. The service providers that administer these services use technologies such as cookies (which are likely to be analytical/performance cookies or targeting cookies), web server logs and web beacons to help us analyse how visitors use our Site and make the information displayed on it more relevant to your interests. The information collected through these means (including IP addresses) is disclosed to these service providers. These analytics services may use the data collected to contextualise and personalise the marketing materials of their own advertising network.

4.7

We may use third party services (e.g. Calendly) where non-session (persistent) cookies may be stored on your browser for purposes such as authentication, functionality and operations. Specifically for Calendly, after booking a meeting, you can opt-out of cookies by deleting cookies within your web browser. By browsing or using our website, you consent to the use of any and all cookies by third party services we use (e.g. Calendly).

THIRD-PARTY SITES

Our Site, our Apps or our communication with you may from time to time contain links to third-party websites over which we have no control. If you follow a link to any of these websites, please note that they have their own practices and policies. We encourage you to read the privacy policies or statements of these websites to understand your rights. We accept no responsibility or liability for any practices of third-party websites.

SECURITY

6.1

All information you provide to us is stored on our secure servers.

6.2

Any payment transactions will be encrypted using TLS/SSL technology.

6.3

Where we have given you (or where you have chosen) a password that enables you to access certain parts of the Site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

6.4

Please note, however, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Site; any transmission is at your own risk.

6.5

Data Breach Notification: In the event of any unauthorised access to or disclosure of Customer Data ("Data Breach"), we will:
(a) Promptly investigate the Data Breach and take reasonable steps to mitigate its effects and minimize any damage resulting from it.
(b) Notify you without undue delay after becoming aware of the Data Breach, providing sufficient information to allow you to meet any obligations to report or inform individuals or regulators.
(c) Cooperate with you and provide reasonable assistance as necessary to facilitate your compliance with applicable data protection laws in relation to the Data Breach.

DATA TRANSFER

7.1

The data that we collect from you (including but not limited to Customer Data) may be transferred to, and stored at, a destination outside Singapore. It may also be processed by persons referred to in Clause 3 above who operate outside Singapore.

7.2

By submitting your personal data you agree to this transfer, storing or processing of data outside Singapore. We will take all steps reasonably necessary to ensure that your data is treated securely in accordance with this privacy policy.

YOUR RIGHTS & RESPONSIBILITIES

8.1

Under the Personal Data Protection Act (the “PDPA“), you have the right to:

(a)

check whether we hold personal data about you;

(b)

access any personal data we hold about you; and

(c)

require us to correct any inaccuracy or error in any personal data we hold about you.

8.2

Any request under Clause 8.1 may be subject to a small administrative fee to meet our cost in processing your request.

8.3

You are responsible for obtaining and maintaining all necessary consents and authorizations from your clients or end-users to allow us to collect, process, use, and share Customer Data as described in this Privacy Policy and our Standard Terms. You will inform your clients and end-users, as required by applicable laws, about the processing of their data by us.

8.4

Assistance with Data Subject Requests: We will reasonably assist you in responding to any request from individuals exercising their rights under applicable data protection laws (e.g. rights to access, correct or delete their personal data), provided that you are responsible for verifying the individual's identity and the legitimacy of the request.

CHANGES TO OUR PRIVACY POLICY

We may amend this policy from time to time by posting the updated policy on our Site. By continuing to use our Site and our Apps after the changes come into effect means that you agree to be bound by the revised policy.

10.

If you have any questions, comments or requests regarding personal data, please address them to:

contracts@moderntrade.co

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