Privacy Policy

The Monex Group ("we", "our" or "us") comprises multiple legal entities, including but not limited to, MonFX Pte. Ltd. Members of the Monex Group may process certain personal data about you, depending on the scope of your specific relationship with us. Depending on the jurisdiction, processing of personal data is regulated under the Personal Data Protection Act 2012 of Singapore (PDPA), General Data Protection Regulation (2016/679) (the GDPR) and the e-Privacy Directive (2002/58/EC) (collectively referred to as the Data Protection Laws). We are responsible as 'controller' of your personal data for the purposes of those laws.

This Privacy Notice applies to the following three circumstances:

1. personal data processed when you visit and use our website;
2. any natural person that has been contacted through our direct marketing strategy, either via phone or email; and
3. personal data processed to service our potential and existing clients.

We will comply with the principles set out in the Data Protection Laws, which state that the personal data we hold about you must be:

• used lawfully, fairly and in a transparent way;
• collected only for valid purposes that we have clearly explained to you;
• relevant to the purposes we have told you about and limited only to those purposes;
• accurate and kept up to date;
• kept only as long as necessary for the purposes we have told you about; and
• kept securely.

Personal data means any information about an individual from which that person can be identified. It does not include data where your identity has been removed, such as anonymous data.

4.1 Personal data gathered from you

4.1.1 Website — When you visit our website, we acquire minimum personal data: information about your computer or device (browser type and settings); log data (webpage visited before, pages visited, time spent, IP address, access times, etc.); history of interaction with our webpages; and other personal data that does not directly identify you.

4.1.2 Marketing — We collect personal data you provide directly if you respond to our marketing campaigns, including call logs and email exchanges with our staff.

4.1.3 Client — At onboarding we collect: name, email address, telephone number, address, nationality, date of birth, identification documents, and signature. Throughout the business relationship we collect account activity (including payment instructions), communications with our staff, and usage of online portals.

4.2 Personal data from other sources — For marketing we may collect name, date of birth, country of residence, corporate email/telephone, and occupation from third parties via publicly accessible sources including LinkedIn, ACRA BizFile+, and news sources. For clients we may receive credit information, credit references, information from business partners/introducers/service providers, and legal and compliance checks.

4.3 Cookies and similar technologies — See our Cookie Policy.

5.1 Website — to interact with you, provide support services, make it easy to navigate our website, improve our website and products, and offer you content and services of interest. We also use data to comply with legal obligations.

5.2 Marketing — to directly market services that we legitimately believe will be of interest to you. Communications may be monitored and recorded for quality assurance, training, fraud prevention, statistical analysis, and compliance with relevant laws.

5.3 Client — for onboarding, identification and account management, sending contract notes, regulatory record keeping, processing trades, and statistical/behavioural analysis.

We may share your personal information with other group companies, affiliates and third parties to help us process it for the purposes set out in this Privacy Notice, including:

• members of the Monex Group depending on requested products and services;
• contractors, sub-contractors, business partners, introducers, suppliers and service providers;
• credit reference agents in accordance with our credit checking policy;
• law enforcement agencies in connection with investigations to help prevent unlawful activity;
• legal representatives and consultants where expert advice and legal opinions are required; and
• processors that maintain our IT systems.

Your personal data is never sold and any personal data that is shared is in line with the Data Protection Laws. We collect and use personal data to provide you with a service or product that you have requested, to comply with a legal obligation, pursuant to the Monex Group's legitimate interest (as long as these interests are not overridden by your data protection rights), or where you have given consent. Where the Monex Group asks for consent, you are free to withhold or revoke your consent by opting out.

We will keep your personal data in line with our Data Retention Policy. We may need to keep your data longer to comply with legal or regulatory requirements, respond to complaints, or prevent fraud and financial crime. If we are not required to retain the personal data, we will destroy, delete or anonymise it at the point it is no longer required.

We store your personal data in a secure environment. We have appropriate security measures in place, including encryption and other forms of security. We limit access to those with a genuine business need to know. We have procedures in place to deal with any suspected data security breach and will notify you and any applicable regulator where legally required.

Your personal data may be transferred to and stored in locations outside of Singapore. When we do this, we ensure the recipient entity has an appropriate level of protection and that the transfer is lawful through controls such as Standard Contractual Clauses.

We would like to send you information about products, services and our business which may be of interest, by post, email, or telephone.

11.1 Client — We will ask whether you would like us to send you marketing messages on the first occasion that you provide relevant contact information. If you opt in, you can opt out at any time.

11.2 Potential client — Marketing information may be sent based on personal data collected and processed in line with sections 4.1.2, 4.2.2 and 5.2.

We may do a credit check on you to make credit decisions and prevent financial crime. Any such search will be recorded on the files of the credit reference agency. We may also disclose personal data about how you conduct your account to credit reference agencies and your personal data may be linked to records relating to other people living at the same address with whom you are financially linked.

You have the following data protection rights:

• The right to access — request copies of your personal data and how we process it.
• The right to rectification — request correction or completion of inaccurate or incomplete data.
• The right to erasure — request erasure of your personal data, under certain conditions.
• The right to restrict processing — under certain conditions.
• The right to object to processing — if you do not wish to be contacted for the purposes set out in this notice.
• The right to data portability — request transfer of data to another organisation or to you, under certain conditions.

If you make a request, we have one month to respond to you.

This Privacy Notice was published on 1st January 2018. The last update was on 12th July 2021. We may update or amend this Privacy Notice from time to time. You should check this Privacy Notice frequently to ensure you are aware of the most recent version.

If you have any questions about this Privacy Notice or the personal data we hold about you, please contact our Data Protection Officer (DPO):

Email — dpo@monfx.com
Post — DPO of MonFX Pte. Ltd., c/o Monex Europe Limited, 1 Bartholomew Lane, London, EC2N 2AX.

If you have any complaints about this Privacy Notice or the personal data we hold about you, please contact us using the above contact information. If you are unsatisfied by our response you can contact the Personal Data Protection Commission:

Contact number: +65 6377 3131
Website: https://www.pdpc.gov.sg/Complaints-and-Reviews