Terms & Conditions

Terms and Conditions

Please read these terms and conditions of use (these “Conditions”) carefully. By accessing and using this web page and the other web pages owned or operated by us or accessing and using our online services (our “Website”) , you will be conclusively presumed to have notice of, and you acknowledge that you agree to comply with and be bound, by these Conditions, as amended from time to time. These Conditions govern our relationship with you in relation to our Website. If you disagree with any part of these Conditions, you must immediately discontinue your access or use of our Website .

Specific terms and conditions of use appearing on specific web pages or sections of our Website may be applicable to such web pages or sections of our Website. Such specific terms and conditions of use shall constitute a part of these Conditions. In the event of any conflict between such specific terms and conditions of use and these Conditions, the specific terms and conditions of use shall prevail to the extent of such conflict.

The term ‘HSSC’, ‘we’ or ‘us’ refers to HSSC-EX (Hang Seng Small Cap Index Exchange) and its affiliates (where applicable), and the term ‘our’ has a correlative meaning. The term ‘you’ refers to the viewer or user of our Website, and the term ‘your’ has a correlative meaning.

Headings are inserted for convenience and shall not affect the interpretation of these Conditions.

Proprietary rights

The information and materials located or hosted on, or linked to, our Website (the “Materials”) are protected by copyright, trademark and other forms of proprietary rights. Such Materials include, but are not limited to, any price information, data, photographs, graphics, illustrations, designs, trademarks, trade names, service marks, product names, logos, insignias or other devices, software programmes, downloadable files, software applications, interactive features, tools, services, articles, videos or other information or content made available on or through our Website and. The presentation and layout of the Materials is also protected by copyrights, trademarks, service marks, international treaties and other proprietary rights and laws of Singapore and other countries.

Unless otherwise stated, the rights, titles and interests to the Materials are owned by, licensed to or controlled by us.

You shall not use any of the names, marks, designs and logos owned or controlled by HSSC and/or HSSC’s affiliates (collectively, “HSSC Marks”, including the words “Singapore Exchange”, “HSSC”, HSSC’s logo and other service marks, trademarks, trade names, slogans, symbols, designs, insignia, emblems and other identifying characteristics associated with HSSC and/or its affiliates, whether used alone or in conjunction with any other name, words or marks) without HSSC’s prior written consent.

Any use and/or reproduction of any HSSC Mark shall be in accordance with these Conditions and HSSC’s and/or HSSC’s affiliates’ relevant branding guidelines. HSSC and/or any HSSC affiliate may in its sole discretion request you to modify or remove any HSSC Mark, including where such use or reproduction may affect HSSC’s and/or HSSC’s affiliates’ rights. HSSC and HSSC’s affiliates reserve all rights to take action against any misuse or infringement of any HSSC Mark and/or violations of applicable laws. In the event you enter into any definitive agreement with HSSC and/or any of HSSC’s affiliates relating to any HSSC Mark, the terms of such definitive agreement shall prevail in the event of conflict between such definitive agreement and any of these Conditions.

All other trademarks, trade names, service marks, product names and logos contained herein that are not owned by, licensed to or controlled by us are used in an editorial fashion only, and to the benefit of respective owners, with no intention of infringement of any trademark or any other intellectual property rights.

Access to our Website

You may access and view our Website and may save an electronic copy or print out a copy of the Materials, solely for your own personal and non-commercial use. If you make a copy of the Materials, you must ensure that such copy must be in the form as presented on our Website and must include all applicable copyright and other notices on our Website as the case may be.

Except with our prior written permission, you may not copy, store (either in hardcopy or in an electronic retrieval system), adapt, alter, translate, transmit, disseminate, distribute, perform, broadcast, publish, reproduce, publicly display, hyperlink, sell, license, rent, lease or otherwise transfer any of the Materials, or otherwise transfer any of the Materials to any other person (whether for direct commercial purpose or monetary gain or otherwise) or otherwise use in whole or in part in any manner.

Except with our prior written permission, you may not create a derivative work from the Materials, nor decompile, reverse-engineer or disassemble the Materials.

Any rights relating to the Materials and our Website not expressly granted herein are reserved and no licence or right is granted to you by implication, estoppel or otherwise.

No unlawful or prohibited use of our Website

You acknowledge and agree that, as a condition of your access and use of our Website , you will not use the Materials or our Website for any purpose that is unlawful or prohibited by these Conditions. You may not use our Website and/ in any manner that could damage, disable, overburden or impair any HSSC server, or the networks connected to any HSSC server, or interfere with any other party’s access and use of our Website . You may not attempt to gain unauthorised access to our Website , or any services provided via our Website , other accounts, computer systems or networks connected to any HSSC server or to any of the services provided via our Website , through hacking, password mining or any other means. You may not obtain, or attempt to obtain, any Materials or other information through any means not intentionally made available on or through our Website

Limited linking and framing of our Website

Unless otherwise stated, you may not link (including, but not limited to, hyperlink, in-line link or deep-link) (hereinafter collectively referred to as “Link”), mirror or frame our Website or any part thereof to any other web page, website, server or otherwise. Except with our prior written permission no trademark, trade name, service mark, product name or logo may be used as a Link or to mark any Link to our Website or any part thereof or any other web page or website.

Subject to the restrictions below, you are allowed to hyperlink to our home page at http://www.HSSC.com or to deep-link to certain of the web pages of our Website :

You may not deep-link to our Website or any part thereof which contains the following Materials: prices, documents of listed issuers or third parties (including, but not limited to, prospectuses, annual reports, circulars, corporate announcements), HSSCNET announcements and Catalouge.

You may not deep-link to our Website or any part thereof which was dynamically created by our system and customised for particular usage sessions.

You may not hyperlink or deep-link to our Website or any part thereof from any web page or website which contains materials or information which is inappropriate, profane, defamatory, infringing, obscene, indecent, vulgar, harassing, privacy invading, abusive, threatening, harmful, tortious, objectionable, unlawful or violates any applicable intellectual property or proprietary rights.

Notwithstanding anything to the contrary in these Conditions, HSSC reserves all rights to terminate any Link from any website to our Website for any reason. Upon our instructions, you must disable, remove and terminate any Link from any web page or website, or any mirroring or framing of our Website or any part thereof immediately.

We have no responsibility for the content available on any website which Links, mirrors or frames our Website or any part thereof. In no circumstances will we be considered to be associated or affiliated in whatever manner with any trademarks, trade names, service marks, logos, insignia or other devices used or appearing on websites that Links, mirrors or frames our Website or any part thereof.

Links to other websites

Any Links provided on our Website are provided for your convenience only. Should you leave our Website via such a Link, the content that you view in such linked web page or website owned or operated by third parties is not provided or controlled by us. We have not developed or reviewed, and are not responsible for the consequences of your accessing the linked web page or website, and/or the content at those web pages or websites. We make no guarantee, representation or warranty as to, and have no liability for, any content at those websites, including, but not limited to, guarantees, representations and warranties regarding truth, adequacy, originality, accuracy, timeliness, completeness, reasonableness, non-infringement, suitability, satisfactory quality, merchantability or fitness for any particular purpose or any representations or warranties arising from usage, custom or trade or by operation of law.

Any such Link to other linked web pages or websites on our Website does not constitute (a) an endorsement, authorisation, verification or representation that we are affiliated with the operators or owners of those linked websites; or (b) an endorsement, authorisation, verification, or representation of or as to the contents of such linked websites.

You agree that your access to and/or use of such linked web pages or websites is entirely at your own risk and subject to the terms and conditions of access and/or use contained therein (including without limitation their privacy and data processing policies and practices).

Third party advertising

We may allow third party advertisers to place or deliver advertisements on our Website or any part thereof. Such advertisements will be clearly identified as originating from third parties. These third party advertisers may collect, monitor and use information about your visit(s) to our Website and other websites in order to provide advertisements on our Website and other sites about goods and services that may be of interest to you (see below).

We do not endorse, and will not be responsible for, the contents of such advertisements or for your access, use, reliance, sale, purchase, or other action on your part with respect to the contents or subject matter of such advertisements. Terms in the section titled “Links to other websites” in these Conditions shall apply in respect of any Link contained in any such advertisement.

Information about You

Personal Data

For information relating to how your personal data is collected and processed by us, please refer to our HSSC Privacy Policy

Non-Personal Data

We may, or may allow third party companies we work with to, automatically collect, monitor and store certain non-personal data and information about visitors to our Website (“Non-Personal Data”). “Non-Personal Data” means information that does not identify you as an individual. This includes, without limitation, information relating to site visitorship, our visitors’ “click path” (e.g. which pages they have viewed, the links or advertisements they have clicked on or viewed, the time spent per webpage, the search terms or categories they have entered, the website or advertisement that was linked to or from our Website ) and the type of browser or operating system used to access our Website . To do this, cookies and other similar technology may be used (see below). Such information will be used to improve and enhance our Website and user experience, and/or to manage online advertising (e.g. to deliver advertisements based on user interest and to measure advertising campaign effectiveness).

Use of Cookies

Our Website, and some services and advertisements on our Website , may contain or use cookies, web beacons, pixel tags or other similar technology (collectively, “Cookies”). Such Cookies enable (i) you to browse our Website and use certain features; and/or (ii) us or third party companies we work with to measure, research and analyse how our visitors use our Website , remember our visitors’ online preferences, and to manage online advertising (including delivering advertisements to our visitors); but do not capture any information that can be used to identify you personally.

Most browsers allow you to (i) adjust or change the settings on your browser so that it deletes the Cookies stored on your device, blocks acceptance of Cookies or notifies you before a Cookie is stored on your device; or (ii) activate a “do-not-track” function. Please refer to the help and support sections on your browser or device for instructions on how to do this. Please note, however, that by blocking, deleting or disabling Cookies or by disabling the tracking function, some features, services, functions or parts of our Website may not be accessible or available to you or may not function properly. Otherwise, by using our Website , you consent to the (a) aforesaid collection, monitoring, storage and use of Non-Personal Data; and (b) storing of Cookies on your device and consent to us (or third parties we work with) accessing such Cookies when you visit our Website in the future.

We do not control and are not responsible or liable for any Cookies which are (i) contained in third party advertisements or Links on our Website ; or (ii) used by third party advertisers or third party web pages or websites which are linked to or from our Website (“Third Party Cookies and Links”). You agree that your access to and/or use of such Third Parties Cookies and Links is entirely at your own risk and subject to such third parties’ terms and conditions of access and/or use (including without limitation their privacy and data processing policies and practices). You should check such third parties’ privacy and data processing policies and practices to determine how they will handle any information and data (including personal data) they collect from you or which you provide to them.

Identification key and password

Certain web pages and/or sections of our Website may only be used or accessed through an identification key and password.

Identification key and/or password may either be assigned to you or selected by you. Where they have been selected or changed by you, we have the discretion to reject any selection or change without assigning any reason. We recommend that you change your passwords often, use a combination of letters and numbers, and ensure that you use a secure browser.

You will be solely responsible to keep the identification key and password confidential, secret and secure. You must not disclose it, or allow it to be disclosed, to any other person.

If you believe that the security or confidentiality of your identification key or password has been compromised, you have the responsibility to change your identification key or password. You will be liable for any unauthorised use or access of such web pages and/or sections of our Website with your identification key and/or password. We are not liable for any damages resulting from any security breaches, unauthorised and/or fraudulent use or access of such web pages and/or sections of our Website with your identification key and/or password.

Disclaimers and exclusion of liability

The Materials are of a general nature which have not been verified, considered or assessed by us and are provided to you on an “as is” and “as available” basis without warranties of any kind. Your use of the Materials is at your own risk. We hereby disclaim all liability and responsibility to update the Materials. We do not make any representations, and hereby disclaim all warranties, express or implied, statutory or otherwise to the extent permitted by law, in respect of our Website or the Materials, including, but not limited to, guarantees, representations and warranties regarding truth, adequacy, originality, accuracy, timeliness, completeness, reasonableness, non-infringement, suitability, satisfactory quality, merchantability or fitness for any particular purpose, or any representations or warranties arising from usage, custom or trade or by operation of law.

Due to the inherent defects of electronic distribution, there may be errors, delays, omissions, interruption, breach of security, corruption, unavailability of access in connection with or inaccuracies in the Materials or our Website (“Defects”). We do not guarantee, represent or warrant that access and use of our Website will be uninterrupted. We assume no responsibility for consequences of any such Defects even if either of us had been advised as to the possibility.

We do not guarantee, represent or warrant that our Website is free of malicious software, including, but not limited to, viruses, computer worms, Trojan horses, spyware or other harmful components (“Malicious Software”). We accept no liability for any loss, damage, claim liability, expense or costs that may result from any transmission of such Malicious Software via our Website (including, but not limited to, files downloaded from our Website ).

You should not take any action, or omit to take any action, in reliance on the Materials or our Website without independent verification or advice.

We will not be liable to you or anyone for any loss, damage, claim, liability, expense or costs, whether in contract, tort (including negligence) or otherwise, arising out of or in relation to:

anything done or omitted to be done in relation to the Materials or any delay, inaccuracies or omissions in the Materials or any interruption to the supply of Materials;

the use of the Materials; or

the use or access of our Website.

We will not be liable for any direct, indirect, consequential, incidental, special or punitive loss, damage, claim, or liability including, but not limited to, loss of data, profits, business contracts or business opportunities, whether in contract, tort (including negligence) or otherwise.

You hereby agree to indemnify and hold us harmless against all loss, damage, claim, liability, expense or costs suffered or incurred by you in connection with or arising from:

your access and/or use of our Website ;

any other party’s access of this website and/or use of the online services using your username and/or login password;

your breach of any of these Conditions; and/or

any other party’s breach of any of these Conditions where such party was able to access and/or our Website and/ by using your identification key and/or your password.

Not investment recommendation or advice

The Materials are not intended for distribution to or for use by or to be acted on by any person or entity located in any jurisdiction where such distribution, use or action would be contrary to applicable laws or regulations or would subject us to any registration or licensing requirement.

Our Website provide only general information on certain investment products. HSSC does not provide, and the provision of such information must not be construed as HSSC providing, financial advice or recommendation for any investment product. The Materials are subject to change without notice.

The availability of any Materials on, or the grant of access or use of, our Website should not be taken in any way as an inducement to trade or a solicitation for orders or entry into any legal relations, nor taken as intended in any way to prompt any action or decision on your part whether to undertake or consider undertaking any investment decision or otherwise.

THE MATERIALS RELATING TO INVESTMENT PRODUCTS ARE AND SHOULD BE TAKEN AS PREPARED FOR GENERAL CIRCULATION AND NONE WAS PREPARED WITH REGARD TO THE SPECIFIC INVESTMENT OBJECTIVES, FINANCIAL SITUATION OR PARTICULAR NEEDS OF ANY PARTICULAR PERSON (INCLUDING YOU) WHO MAY RECEIVE OR HAVE ACCESS TO THE SAME. ANY RECOMMENDATION OR ADVICE THAT MAY BE EXPRESSED IN OR INFERRED FROM THE MATERIALS AVAILABLE THROUGH OUR WEBSITE THEREFORE DOES NOT, SHOULD NOT BE TAKEN AS TAKING INTO ACCOUNT, AND MAY NOT BE SUITABLE FOR, YOUR INVESTMENT OBJECTIVES, FINANCIAL SITUATION AND PARTICULAR NEEDS, AND BEARING IN MIND THE POSSIBILITY OF MARKET VOLATILITY AND CHANGES, MAY NOT EVEN COMPRISE CURRENT INFORMATION, CONTENT, RECOMMENDATION OR ADVICE.

THE MATERIALS AVAILABLE THROUGH OUR WEBSITE SHOULD THEREFORE NOT BE RELIED UPON IN RELATION TO ANY INVESTMENT DECISION, TRADING ACTIVITY OR ORDER PLACED BY YOU AND YOU SHALL, AT ALL TIMES, RELY ON YOUR OWN INDEPENDENT ASSESSMENT AND JUDGMENT IN RESPECT OF ANY INVESTMENT DECISION OR PROPOSED TRANSACTION AND SEEK INDEPENDENT ADVICE AS NECESSARY FROM YOUR OWN FINANCIAL, LEGAL, TAX OR OTHER PROFESSIONAL ADVISERS, INCLUDING BUT NOT LIMITED TO, ADVICE FROM A FINANCIAL ADVISER AS TO THE SUITABILITY OF THE INVESTMENT PRODUCTS (AS MAY BE REFERRED TO IN THE MATERIALS AVAILABLE THROUGH OUR WEBSITE ), TAKING INTO ACCOUNT YOUR SPECIFIC INVESTMENT OBJECTIVES, FINANCIAL SITUATION OR PARTICULAR NEEDS, BEFORE MAKING ANY COMMITMENT TO ACQUIRE, TRADE OR DEAL IN ANY SUCH INVESTMENT PRODUCTS.

We may collect certain personal information including, but not limited to, (a) identification data (for example your name, e-mail address, mailing address, contact number, birth date, age, occupation, educational level, income level, gender, industry of work); (b) information about your usage of and interaction with our Website (for example computer and connection information, device capability, bandwidth, statistics on page views, frequency of use and traffic to and from our Website ); (c) electronic identification data (for example internet protocol address and cookies); and (d) your user profile (for example identification key and password) ((a) to (d) collectively, “Personal Information”) via our Website . 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 Website or our services, or to purchase our products or services.

We are committed to protecting your privacy. We do not disclose specific information about our users to any third parties unless required by law or any government agencies, to comply with legal process, where necessary to enforce these Conditions, to respond to claims from third parties, to protect the safety, interests, rights or property of ours or others or as permitted under these Conditions.

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 these Conditions;

we need to disclose your Personal Information to provide the services that you have requested; and

we need to disclose the Personal Information to third parties who on behalf of us provide services to you (we will only provide such third parties the relevant information required for the provision of the services, and the third parties are prohibited from using such Personal Information for any other purpose).

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.

In the event that you participate in promotional programmes on our Website sponsored or organised by third parties, or purchase goods and services offered by third parties, or offer goods and services to third parties on our Website , your information may be disclosed to and used by such third parties. From time to time, we receive Personal Information from business partners and third parties. We only use such information if it has been collected in accordance with acceptable privacy practices consistent with these Conditions and applicable laws. We are not responsible for removing your Personal Information from the lists of any third party who has previously been provided your information in accordance with these Conditions.

Certain web pages and/or sections of our Website 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 Website . 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 Website , then you may not be able to gain access to all of the Materials, facilities and services provided on our Website as the case may be.

Information that we collect may be stored or processed in any country and may be transferred between countries. Some of these countries may have data protection laws that are less stringent that those in the country in which you are using or accessing our Website . You acknowledge and agree to such storage, processing and transfer.

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

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

We allow certain third party companies (including AddThis) to collect certain anonymous information when you visit our Website . These companies may use non-personally identifiable information during your visits to our Website 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.

We use the independent company Nielsen/NetRatings to measure and analyse the Internet usage across our Website. Aggregate, non-personal information is collated by Nielsen/NetRatings and provided to us to assist in analysing the usage of our Website . The Nielsen/NetRatings data is also accessible by media organisations and research companies, for the purpose of conducting industry comparisons with other Internet portal.

Violations of these Conditions

We reserve the right, in our absolute discretion, to monitor any and all access and use of our Website .

We reserve our right to terminate your access and/or use of our Website and/or any part thereof and we may block access from a particular internet protocol address to our Website or any part thereof in the event of any violation of these Conditions. In addition, we reserve the right to seek all remedies available under these Conditions, at law and in equity for violations of these Conditions. These may include, without limitation, take-down requests to online locations, network service providers, search engines and/or app stores and/or notification to domain registration service providers.

Changes to these Conditions

We may, from time to time and at any time, update or revise these Conditions. Such update or revision is effective upon publication on our Website and/ . You are responsible for ensuring that you have read the most current version of these Conditions. Your continued access and/or use of our Website will be deemed to constitute your conclusive acceptance of the updated or revised Conditions. The Materials are subject to change including, without limitation, modification, deletion or replacement thereof without notice.

Severability

If any provision of these Conditions, in whole or in part, is held to be illegal, invalid or unenforceable under any enactment or rule of law or by any court in any jurisdiction: (i) such provision or part will, to that extent, be deemed not to form part of these Conditions, but the legality, validity and enforceability of the remainder of these Conditions is not affected; and (ii) the legality, validity and enforceability of that or any other provision or part under any other jurisdiction will not be affected.

Governing law and jurisdiction

These Conditions shall be governed by, and construed in accordance with, the laws of Singapore. You agree to submit to the non-exclusive jurisdiction of the Singapore courts.

English version to prevail

The Materials, our Website, our Mobile App and these Conditions are also available and reproduced in Chinese. In the event of any discrepancy between the Chinese and English versions of the Materials, our Website, our Mobile App or these Conditions, the English version will prevail.

HSSC Privacy Policy

HSSC is committed to protecting its stakeholders’ and customers’ personal data in accordance with the Singapore Personal Data Protection Act (“PDPA”) and other applicable data protection laws.

“Personal data” means any data about an individual who can be identified from that data, as more specifically defined under the PDPA and other applicable data protection laws.

The HSSC Privacy Policy (“Privacy Policy”) describes how HSSC collects, uses, stores and protects personal data. The Privacy Policy also describes how you can control the personal data that HSSC holds on you, and your rights on your personal data, where applicable.

The data protection laws that apply to HSSC varies depending on where an HSSC entity operates, where HSSC’s products and services are provided and/or where HSSC’s customers are located. Where it is stated in this Privacy Policy that a provision applies “to the extent required by [the applicable law],” such provision will be applicable only to the extent that HSSC is subject to the relevant law.

HSSC may from time to time update this Privacy Policy to ensure that it is consistent with future developments, industry trends and/or any changes in legal or regulatory requirements. Please check regularly for updated information.

This Privacy Policy, together with the Cookie Policy, forms part of the General Terms of Use.

Information that HSSC collects

HSSC collects information about how to contact you and your interest and relationship with HSSC, including the products and services which are relevant to you.

Personal data that HSSC may collect (depending on the nature of your interaction with HSSC) include:

(a) your name, NRIC, passport or other identification number, telephone number, mailing address, email address and any other information relating to you which you have provided HSSC in your interaction with HSSC;

(b) your payment related information, such as your bank accounts;

(d) information about your use of HSSC’s website and services, including cookies, IP address, subscription account details and membership details, but only to the extent that HSSC may identify you from such information.

Such information is collected:

(a) from you or HSSC’s related corporations, affiliates, partners and/or representatives with your permission and consent, or HSSC may receive your personal information from third parties who you have given consent to pass this information on to HSSC;

(b) through contracts or other legal arrangements you have with HSSC or HSSC’s related corporations, affiliates, partners and/or representatives on behalf of HSSC, so that HSSC may fulfil the contractual/legal obligations thereunder; or

for example:

(a) when you use some of HSSC’s services;

(b) when you submit forms relating to any of HSSC’s products or services;

(c) when you register for or use any of HSSC’s services on websites owned or operated by HSSC or when you register as a member of websites owned and/or operated by HSSC, or use services on such websites;

(d) when you interact with HSSC’s personnel such as customer service officers, marketing representatives and agents;

(e) when you request that HSSC contact you;

(f) when you ask to be included in an email or other mailing list;

(g) when you respond to HSSC’s promotions and other initiatives;

(h) when you enter into agreements with HSSC;

(i) when HSSC receive references from business partners and third parties, for example, where you have been referred by them; and

(j) when you submit a job application or a scholarship application to HSSC;

(k) when you submit your personal data to HSSC for any other reason.

Purposes for the Collection, Use and Disclosure of Personal Data

Generally, HSSC collects, uses and discloses your personal data for the following purposes:

(a) to provide products and services to you;

(b) to communicate with you on matters relevant to your relationship with or interest in HSSC;

(d) to selectively send you information about our products, services, activities and/or events that may be relevant to you;

(e) to fulfil the contractual/legal obligations under the contracts or other legal arrangements entered into between HSSC and you, or entered into between HSSC’s related corporations, affiliates, partners and/or representatives and you;

(f) to protect and enforce HSSC’s contractual and legal rights and obligations;

(g) to verify your identity;

(h) to prevent, detect and investigate crime, including fraud and money-laundering, and analyze and manage other commercial risks;

(i) to conduct audits, reviews and analysis of HSSC’s internal processes, for action planning and managing commercial risks;

(j) to prevent, detect and investigate crime and manage the safety and security of HSSC’s premises and services (including but not limited to carrying out CCTV surveillance and conducting security clearances);

(k) to comply with any applicable rules, laws and regulations, codes of practice or guidelines or to assist in law enforcement and investigations by relevant authorities; and/or

(l) any other purpose relating to any of the above.

HSSC may share your personal data to third parties with your consent for the purpose for which the information was collected or to be used, and any other reasonable ancillary purposes, for legal reasons, or where permitted under the PDPA and other applicable laws, such as in response to law enforcement agencies.

If HSSC transfers your personal data to countries outside Singapore, it will be done in accordance with the relevant provisions under Singapore laws and regulations. HSSC will also comply with the relevant laws and regulations in relation to transfers of personal data outside countries where the personal data is collected.

Marketing Communications

It is in HSSC’s legitimate interests to process your personal data to selectively contact you and/or send you information about HSSC’s products, services, activities and/or events that may be relevant to you (“Marketing Communications”). To the extent that HSSC’s processing of your personal data for Marketing Communications is subject to the European General Data Protection Regulation, you have the right to object to such processing by HSSC.

You may opt-out of receiving Marketing Communications by using the unsubscribe link contained in the email communications.

When you browse HSSC’s websites, HSSC uses cookies to store information about how you use these websites in order to improve the quality of service provided to you. To understand what type of cookies we use and how these work when you use our websites.

Retention of your personal data

HSSC shall retain your personal data for as long as is necessary for the purposes stated in Section 2 above, and take reasonable measures to destroy any personal data that is no longer necessary to meet those purposes.

HSSC security measures

All your personal data is kept confidential and HSSC takes all reasonable measures to protect it from unauthorized or accidental access, processing or loss, by implementing appropriate physical, electronic and supervisory controls.

How you can control your information

If you do not want HSSC to contact you by telephone or SMS – You may register with the Personal Data Protection Commission’s national Do-Not-Call register. HSSC complies with the PDPA’s requirements on screening telephone communications with the Do-Not-Call register.

If you do not want HSSC to contact you via electronic messaging – You may select the “unsubscribe” option in all HSSC electronic communications with you. HSSC also complies with the Singapore Spam Control Act.

If you want to be removed from HSSC’s customer database – You may email HSSC.

If you believe HSSC has inaccurate information about you and you want to correct such data, you may email HSSC.

If you wish to know what personal data HSSC have on you in connection with your relationship with HSSC and how your personal data has been used – You may email HSSC

If you have any questions about this Privacy Policy, or HSSC’s handling of your personal data – You may email HSSC.

It is important to note that HSSC uses your personal information to provide you with the products and services you wish to use. HSSC also complies with various regulatory requirements in doing so, including the requirements for customer due diligence. Withdrawal of consent for HSSC to collect, use or disclose personal information means that HSSC will stop these activities. The absence of certain key personal information, including but not limited to your name, address, email and/or telephone contacts, personal identification numbers or banking information, may cause HSSC to be unable to continue providing the relevant products and services to you.

Your rights regarding your personal data

To the extent that HSSC’s processing of your personal data is subject to the European General Data Protection Regulation, you may have the following rights:

access to your personal data

rectification of your personal data

erasure of your personal data

restrict processing of your personal data

object to processing (including object to receiving marketing) of your personal data

data portability

lodge a complaint with a EU supervisory authority

If you wish to exercise these rights, or have any questions about these rights, you may email HSSC

Contacting us

If you have any questions about this Privacy Policy, or HSSC’s handling of your personal data, please email our Data Protection Officer

General Disclaimer and Jurisdiction Specific

General Disclaimers

This document/material is not intended for distribution to, or for use by or to be acted on by any person or entity located in any jurisdiction where such distribution, use or action would be contrary to applicable laws or regulations or would subject Singapore Exchange Limited (“HSSC”) and/or its affiliates (collectively with HSSC, the “HSSC Group Companies”) to any registration or licensing requirement.

This document/material is not an offer or solicitation to buy or sell, nor financial advice or recommendation for any investment product. This document/material has been published for general circulation only. It does not address the specific investment objectives, financial situation or particular needs of any person. Advice should be sought from a financial adviser regarding the suitability of any investment product before investing or adopting any investment strategies. Use of and/or reliance on this document/material is entirely at the reader’s own risk.

Investment products are subject to significant investment risks, including the possible loss of the principal amount invested. Past performance of investment products is not indicative of their future performance. Any forecast, prediction or projection in this document/material is not necessarily indicative of the future or likely performance of the product. Examples (if any) provided are for illustrative purposes only.

While each of the HSSC Group Companies have taken reasonable care to ensure the accuracy and completeness of the information provided, each of the HSSC Group Companies disclaims any and all guarantees, representations and warranties, expressed or implied, in relation to this document/material and shall not be responsible or liable (whether under contract, tort (including negligence) or otherwise) for any loss or damage of any kind (whether direct, indirect or consequential losses or other economic loss of any kind, including without limitation loss of profit, loss of reputation and loss of opportunity) suffered or incurred by any person due to any omission, error, inaccuracy, incompleteness, or otherwise, any reliance on such information, or arising from and/or in connection with this document/material.

The information in this document/material may have been obtained via third party sources and which have not been independently verified by any HSSC Group Company. No HSSC Group Company endorses or shall be liable for the content of information provided by third parties (if any).

The HSSC Group Companies may deal in investment products in the usual course of their business, and may be on the opposite side of any trades. Each of HSSC, Singapore Exchange Securities Trading Limited and Singapore Exchange Bond Trading Pte. Ltd. is an exempt financial adviser under the Financial Advisers Act (Cap. 110) of Singapore.

The information in this document/material is subject to change without notice. This document/material shall not be reproduced, republished, uploaded, linked, posted, transmitted, adapted, copied, translated, modified, edited or otherwise displayed or distributed in any manner without HSSC’s prior written consent.

Jurisdiction Specific Disclaimers

In addition to the general disclaimers set out in Section A above, the following specific disclaimers shall apply if the recipient of the document/material is governed by the laws and regulations of the relevant jurisdictions set out below:

Jurisdiction

Specific Disclaimer

Australia

This document/material is intended for the recipient’s information only and must not be made available to any retail client in Australia.

British Virgin Islands

HSSC is not licensed to carry on business in the British Virgin Islands. The document/material is for information only. The information therein should not be construed as a solicitation or offer, or recommendation, to acquire or dispose of any investment, to enter into any contract or to engage in any other transaction.

Canada

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Cayman Islands

HSSC is not licensed to carry on business in the Cayman Islands. The document/material is for information only. The information therein should not be construed as a solicitation or offer, or recommendation, to acquire or dispose of any investment, to enter into any contract or to engage in any other transaction.

Dubai International Financial Centre

This document/material is solely for the information of the recipient or persons meeting the criteria of a professional client (as specified by the Dubai Financial Services Authority) in the Dubai International Financial Centre.

Thailand

Investments in financial products are subject to investment risks. Investors are advised to study relevant information carefully before making an investment. This document/material is only used for promoting a better understanding in relation to HSSC products. The contents of this document are intended to give a general explanation only. HSSC does not intend to conduct any investment advisory, offering activities or any securities business in Thailand.

United Kingdom

This document/material is being distributed only to and directed only at (a) persons who are outside the United Kingdom; (b) persons who have professional experience in matters relating to investments falling within Article 19(5) of the Financial Services and Markets Act 2000 (Financial Promotion) Order 2005; or (c) those persons to whom it may otherwise lawfully be distributed (all such persons together being referred to as “relevant persons“). This document/material is directed only at relevant persons and must not be acted on or relied on by persons who are not relevant persons. Any investment or investment activity to which this document/material relates is available only to relevant persons and will be engaged in only with relevant persons. The document/material may only be communicated to persons in the United Kingdom in circumstances where Section 21(1) of the Financial Services and Markets Act 2000 does not apply.