Welcome to InvestaX's Digital Securities Investment Platform.
The term “you” or “User” as used herein refers to any member, user or viewer of our Site, including, but not limited to, any real estate developer, owner, agent, sponsor, operating company seeking funding for its real estate project, or company issuing tokens for its real estate project (collectively, the “Offering Companies”).
TYPES OF PERSONAL DATA COLLECTED
We collect personal and financial information from you while you use the Site. Most of this collection occurs during registration.
We collect several types of information from you. This includes:
- Personal Data required to verify your identity, such as your name
- Personal Data such as home address, telephone number, country of citizenship, date of birth, and gender
- Personal and financial data necessary to assess your eligibility to invest on the InvestaX platform. Specifically, Users who are accredited investors will need to provide financial information supporting their accredited investor status
- Information about your visits to and use of this Site to help us maintain the appropriate features, functionality and user experience
In addition, we gather names and email addresses of Users who contact us through the Site with questions about our company or our platform. We collect this information for the sole purpose of responding to such inquiries and do not store the contact information unless requested by these people (e.g. applicants who submit resumes).
To create an account with InvestaX, you must provide us with your name and a valid email address. Users may also create an account using social media credentials as provided for on the Site, such as Facebook or LinkedIn. These services will verify your identity, and you may choose to provide certain Personal Data to us to pre-populate our sign-up form. In doing so, you expressly consent to InvestaX collecting your Personal Data that may be available through such social media networks.
We do not collect more Personal Data than is necessary for the purposes for which they are collected.
WEB-RELATED INFORMATION COLLECTION
When you visit the Site, we may send one or more cookies to your computer. “Cookies” are small text files containing a string of alphanumeric characters that may be placed on your web browser when you visit our Site that may convey anonymous information about your preferences and how you browse the Site to us. However, it does not collect Personal Data about you.
The Site uses Google Analytics, a web traffic analysis service provided by Google Inc. (“Google”).
Please refer to http://www.google.com/policies/privacy/partnersto find out more about how Google uses data when you use our Site and how to control the information sent to Google. You may prevent Google’ s collection and processing of data by using the Google Ads Settings page or downloading and installing their browser plug-in (https://tools.google.com/dlpage/gaoptout).
In addition, we (or our service providers, such as Google Analytics) may also collect technical information related to your use of our services. This may include (but is not limited to):
- information regarding which of our web pages you access
- the frequency of such access
- your product and service preferences
- your Internet Protocol (IP) address
- your browser type
- your internet service provider (ISP)
- your operating system
- referring or exit pages
- the dates and times that you visit the Site.
Such technical data may be used for administrative purposes, to assess the usage, value and performance of our online products and services, and to improve your experience with our services. As with cookies, the web surfing information collected is aggregated, anonymous "click stream" and transactional data, and is not associated with any Users as individuals.
PURPOSES OF COLLECTING PERSONAL DATA
The Personal Data we collect is required for legal, compliance or security purposes. Where possible, we will inform you of the specific purpose for which such Personal Data is being collected.
The Personal Data collected on the Site maybe used by InvestaX for the following purposes:
- for the specific purpose for which the information was volunteered;
- to establish your ability to view offering materials and to make investments through the Site ;
- to provide you with alerts, newsletters, education materials or information that you have specifically requested;
- promoting and marketing services and products subject to your exercise of the opt-out right;
- to communicate with you and respond to your queries;
- to process your application, inquiry or request;
- to verify your identity, conduct Know Your Customer and other due diligence check as may be required;
- to guard against potential fraud and other illegal activities;
- to maintain regular communications with you as may be necessary to inform you of upcoming investment opportunities and other company updates;
- to conduct surveys, research and statistical analysis with the aim of helping us monitor or improve our Services to you;
- to comply with applicable laws, proceedings or inquiries from regulatory authorities and enforcement agencies in or outside of Singapore or similar purposes;
- for any other purposes permitted by applicable law.
Our services are not directed at persons under the age of 16. If you are a parent or guardian and you become aware that your child has provided us with personal data without your consent, please contact us. We will only process personal data of a child under the age 16 only where consent is given or authorized by the child’s parent or guardian. If we become aware that a child under the age of 16 has provided us with personal data without consent, we will delete such information from our files, including any accounts that may have been created.
HOW WE SHARE YOUR INFORMATION
InvestaX does not sell or rent personal information about its Users to third parties. We do, however, work with a number of trusted partners who perform vital functions as part of our operations.
In addition to Hubspot and MailChimp, we work with (among others) providers of hosting services for the Site, electronic signature providers, and electronic payment service providers, and other service providers who provide information technology and system administration services to us. We may engage third parties to help us to carry out certain other internal functions such as account processing, client services or other data collection relevant to our business; examples of such companies might include companies that perform data processing, reporting, tax or legal documentation, custody or escrow services. Personal Data is shared with these third parties, including Offering Companies, only to the extent necessary for us to process the transactions you initiate or perform other specific services, like collections. Our partners are legally required to keep your information private and secure.
If you use our blog or other public forums on the Site, please note that any Personal Data you submit there is available to other Users. We are not responsible for the Personal Data you choose to submit.
We may share your personal data with law enforcement or other government agencies as required by law or for the purposes of limiting fraud. We reserve the right to disclose your personally identifiable information when we believe that disclosure is necessary to protect our rights or to comply with a judicial proceeding, court order or legal process. We further reserve the right to disclose any of your personal information that we believe, in good faith, appropriate or necessary to take precautions against liability, to investigate and defend against any third-party claims or allegations, to assist government enforcement agencies, to protect the security or integrity of the Site or our Services, or to protect the rights, property or personal safety of InvestaX, its Users, Offering Companies, or any other person.
NOTIFICATIONS AND COMMUNICATIONS FROM OUR SITE
We will send you email notifications from time to time. These will typically relate to your activities on our Site. In other cases, these notifications involve changes to various legal agreements or Site policies. By using our services, you consent to receiving such service-related emails.
From time to time, we may also send user surveys, requests for user feedback regarding user experience and Site operations or marketing offers from us or on behalf of the Offering Companies. Completing these surveys or requests for feedback or acceptance of any offer is strictly voluntary. If you do not wish to receive these offers, surveys or user feedback emails, please opt out in any offer email you receive from us.
LINKS TO OTHER SITES
TRANSFERRING INFORMATION OVERSEAS
The entity responsible for the management and use of the Site and Personal Data collected from them is IC SG Pte Ltd, a Singapore private limited company. However, InvestaX operates worldwide and may transfer personal information across national borders. Personal data collected through this Site may be stored and processed outside of Singapore or any other country in which InvestaX or its agents maintain offices. By providing your personal data and using the Site, you consent to any such transfer of information outside of your country.
Where the third-party recipient of Personal Data is located in a country which has not been deemed by the European Commission to have adequate laws in place to protect it, we may transfer such Personal Data using one of the following measures:
- Any such third parties whom we engage will be bound contractually to keep all information confidential; or
- We will seek to put in place standard contractual clauses approved by the European Commission, which give personal data the same protection it has within the EEA.
We limit access to your Personal Data to those employees or third parties who have a legitimate business need to access such information. We conform to industry standards and practices and maintain appropriate physical, electronic and procedural safeguards and controls to protect your information. This includes partnerships with Amazon Web Services, which allows us to rely on ISO 27001 security certification and extended validation SSL Plus certificate provided by Digicert. The Site is built upon a secure infrastructure with multiple layers of protection and we use industry standard encryption technologies to safeguard your information.
InvestaX takes the protection of your Personal Data seriously but, unfortunately, 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 Personal Data transmitted through the Site; any transmission is at your own risk.
If your Personal Data is compromised as a result of breach of our security measures, we will promptly notify you of such a breach.
InvestaX will never send you an email asking you for your login information. In general, you can protect yourself against phishing by never providing personal or login information via a link contained in an email; instead, go to the Site directly.
Access to information:
The GDPR gives you the right to find out whether we are processing your Personal Data and, where that is the case, to receive a copy of the Personal Data we process. We will endeavor to provide you with an account of your Personal Data in our possession or control within a reasonable time. Such account shall be in respect of how your Personal Data has been or may have been generally used or disclosed.
We reserve the right to charge you a reasonable administrative fee for carrying out such request. Where your personal data is inseparable from the Personal Data of others, we reserve the right to withhold your Personal Data if permitted by applicable law.
Right to request rectification or erasure of Personal Data:
You have the right to request the amendment of your Personal Data at any time if it is inaccurate. If it is incomplete, you have the right to have such Personal Data rectified. You also have the right to require us to delete your Personal Data as soon as possible by emailing delete@investaX.io where one of the following applies:
- the Personal Data is no longer necessary for which they were collected or otherwise processed
- the Personal Data has been unlawfully processed
- the Personal Data must be erased for compliance with a UK or EU legal obligation on us
- the Personal Data relates to a child under the age of 16
- you withdraw your consent to us processing your Personal Data and we have no other legal grounds for processing it
Please not that it may take up to 30 working days for any request for consent withdrawal to be reflected in our systems.
Right to restrict personal data:
You have the right to request the restriction of processing of Personal Data if you think that is inaccurate, that we are processing it illegally, or that we no longer need it for the purposes for which it was collected. While we consider your request, we will stop processing your Personal Data within a reasonable time from the date we receive your request. We will notify you of our decision and any justifications for continuing to process your Personal Data as soon as we can.
Right to withdraw:
If we process your Personal Data with your consent, you have the right to withdraw your consent at any time. This will not affect the legality of our processing of your Personal Data up until the point at which you withdraw your consent. Please also note that we may still need to process your Personal Data on other grounds, for example to fulfil a contract with you or as required by law.
Right to object:
You have the right to object, at any time, on grounds relating to your particular situation, to the processing of Personal Data. If we cannot demonstrate compelling legitimate grounds to continue processing the Personal Data, processing of such data will cease.
DATA PROTECTION OFFICER AND ACCESSING YOUR RIGHTS
If you wish to withdraw your consent to any or all use of your Personal Data, or request amendment, restriction or erasure of such Personal Data, or exercise any other of your rights, please contact firstname.lastname@example.org.
Do note that if you withdraw your consent to any or all use of your Personal Data or request for erasure of your Personal Data, depending on the nature of your request, we may not be in a position to continue to provide services to you, or administer any contractual relationship already in place. Any withdrawal of consent or request to erase your Personal Data may also result in the termination of any agreements you have with us. Our legal rights and remedies in such event are expressly reserved.
Questions? Please email us at email@example.com
Last updated: October 11, 2019
Copyright © 2019 InvestaX. All Rights Reserved.
 U.S. investors must be “accredited investors” as that term is defined in Rule 501 of Regulation D of the Securities Act of 1933 and complete a further accreditation form. Singapore investors must either be (i) “accredited investors” as that term is defined in Section 4A(1) of the Securities and Futures Act, Chapter 2899 and complete a further accreditation form, or (ii) “qualified investors” who have completed the Know Your Customer form.