Partners, Clients & Suppliers

If you enter into an agreement with Clearisk, we will collect information from you in relation to your company and your clients as required to execute the contract and set up to provide better services to all our users across our services including Client Portal, Client Onboarding and Backoffice Processing. The information collected is for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purpose. The information collected:

• include sensitive and non-sensitive personally identifiable information such as contact information, address, ID documentation, email address, bank/payment details, credit card details, financial information, date of birth, gender, signature, trading related information (eg subscriptions, market data, account numbers), which will be used for our legitimate interest of managing our internal administration for delivering products and services as agreed, and for complying with our legal obligations to ensure the prevention of fraud, money laundering, financing illegal activity and suspicious transactions. We use data for undertaking checks such as Know-Your-Client, Anti-Money Laundering and compliance with Futures & Options Regulations
• including data about you and your clients use of our products such as log in details, information shared with us as part of doing business including questions, queries and comments.
• the personal data we process for suppliers is generally limited to contact information (name, name of supplier, phone, email, and other contact details) and financial information (payment-related information).

Therefore, before you enter an agreement to become one of our Partners or Suppliers and during the term of the contract you will be responsible and consent to any disclosures, to notify and obtain any consents necessary under any applicable privacy or data protection laws from your clients/personnel for Clearisk to collect and process data to provide the required products and services such as:

• Verify the identity of you and your clients
• Monitor the behaviour of you and your clients transactions across Clearisk solutions
• Provide our products and services as intended

Ground for collecting and processing data of Suppliers, Partners and your clients are:

• Performance of a contract - Article 6.1.b GDPR
• Compliance with a legal or regulatory obligation, including know-your-client, anti-money laundering and taxation obligations - Article 6.1.c GDPR
• Our legitimate interest in providing you with our goods and services and securing prompt payment of any fees, costs and debts in respect of our services - Article 6.1.f GDPR

• Our legitimate interest in responding to questions, queries, comments and complaints you send or share with us - Article 6.1.f
• Our legitimate interest in safeguarding Clearisk against inadvertently dealing with the proceeds of criminal activities or assisting in any other unlawful or fraudulent activities (for example, terrorism) - Article 6.1.f GDPR

Workforce, Contractors and Suppliers

As an employee, contractor or supplier, personal data is collected and processed in the context of an individual working relationship with us. The primary controller of Clearisk workforce personal data is Clearisk Tech Pte Ltd.

Workforce personal data that is considered as “sensitive personal data” (dependent on jurisdictions and under applicable laws) is collected as required or permitted by local law to ensure compliance with the jurisdictions local tax requirement or as deemed necessary for the purposes of legitimate interests pursued by Clearisk.  As a current of future employee you consent to provide and having your personal identifiable and sensitive personal data processed.

As an employee, if authorised to access Personal Data, you have committed to confidentiality and are under appropriate statutory obligation of confidentiality. You will take reasonable steps to ensure Personal Data is only Processed after authorisation.

• Indonesia - Indonesian Privacy Law, the Personal Data Protection (PDP) - Notify, consent (with record), Purpose Limitation
• Singapore - Data Protection Obligations under the Personal Data Protection Act (PDPA) Singapore - Notify, Consent, Purpose Limitation
• India - Digital Personal Data Protection (DPDP) Act, 2023 - Notify, Consent, Purpose Limitation
• Australia - Privacy Act 1988 - Notify, Consent, Purpose Limitation

‍Retention

We will retain personal data 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, tax, or accounting requirements).

When we have no ongoing legitimate business need to process your personal data, we will either delete or anonymize it, or, if this is not possible, for example, because your personal data has been stored in backup archives, we will securely store your personal data and isolate it from any further processing until deletion is possible.

Security

We have appropriate measures in place to protect the personal data we collect and process about you. They are designed to provide a level of security appropriate to the risk of processing your personal data.

In addition to the steps we take, it is important you take steps to protect your personal data as well. Do not share personal data with others unless you clearly understand the purpose and its use and do not share personal data via email for voicemail.

While we take precautions to protect your personal data from loss, theft, alteration, or misuse, no system or security measure is completely secure. Any transmission of your personal data is at your own risk, and we expect you will use appropriate measures to protect your personal data as well.

Who we share your data with

We disclose and share your personal data to the following recipients:

• Companies belonging to Clearisk and Contractors and Suppliers
• Support Providers who are engaged by us to support our ancillary processes eg Accounting, Financing, IT functions, HR Functions including payroll, training; compliance providers,
• Business Partners
• Other third party recipients eg professional advisors (tax, law, auditors), insurers, banks, travel agents,

Where we process your data

Clearisk is headquartered in Singapore and most of the data we process, transfer and access are stored here. Data is also transferred, accessed from and can be stored in our workforce locations, and where our Partners, clients, and other third-parties operate.

Cookie Notification

Clearisk uses cookies to track new and returning visits to our website, and activity of our Partners and Clients (users) whilst using our Processing System. This enables us to collect information to improve our delivery of our products and services to you. Some cookies on the website and on our Processing System are strictly necessary and cannot be disabled, as this can impact the functionality and alter your experience.

When you visit our sites, we collect certain personal data automatically from your device. Specifically, the data we collect automatically includes information, such as your IP address, pixel ID, device type, unique device identification number, browser type, operating system, broad geographic location (e.g., country or city-level location), name and other technical information. We also collect information about how your device has interacted with our sites, including the pages accessed, current URL, time you visited the site, and links clicked. Collecting this information enables us to better understand the visitors and clients who come to our sites, where they come from and what content on our site is of interest to them. We use this information for our internal analytics purposes and to improve the quality and relevance of our sites and services to our visitors and clients.

Data subject rights
Individuals can request access, correction, updates or deletion of their personal data to object to our processing of the personal data. You may exercise your rights by contacting us.

Effective Date: February 2, 2024