Privacy Policy & Terms of Use

Last updated June 30, 2024.

Adroit Investment Technologies Pte. Ltd. and its Delegates (including its products Entrevue, collectively referred to as "we" or "us" in this Privacy Policy) operate this online platform at www.adroitinvest.com (the "Platform") and the Services (as defined below) provided therein. We are committed to respecting and protecting your personal data collected through or in connection with our Platform.

INTRODUCTION

We take our responsibilities under the Singapore Personal Data Protection Act 2012 seriously. We also recognise the importance of the personal data you have entrusted to us and believe that it is our responsibility to properly manage, protect and process your personal data.

This Privacy Policy is designed to assist you in understanding how we collect, use, disclose and/or process the personal data you have provided to us, as well as to assist you in making an informed decision before providing us with any of your personal data. By accessing or otherwise using the Platform, using our services or entered to get early access with us, you represent and undertake, and are deemed to have read, accepted, and agreed to be bound by the terms of this Privacy Policy.

PERSONAL DATA

As used in this Privacy Policy:

“customer” means an individual who (a) has contacted us through any means to find out more about any goods or services we provide, or (b) may, or has, entered into a contract with us for the supply of any goods or services by us; and

“personal data” means data, whether true or not, about a customer who can be identified: (a) from that data; or (b) from that data and other information to which we have or are likely to have access.

Depending on the nature of your interaction with us, some examples of personal data which we may collect from you include email address.
Other terms used in this Privacy Policy shall have the meanings given to them in the Personal Data Protection Act ("PDPA") (where the context so permits).

COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA

We generally do not collect your personal data unless (a) it is provided to us voluntarily by you directly or via a third party who has been duly authorised by you to disclose your personal data to us (your “authorised representative”) after (i) you (or your authorised representative) have been notified of the purposes for which the data is collected, and (ii) you (or your authorised representative) have provided written consent to the collection and usage of your personal data for those purposes, or (b) collection and use of personal data without consent is permitted or required by the PDPA or other laws. We shall seek your consent before collecting any additional personal data and before using your personal data for a purpose which has not been notified to you (except where permitted or authorised by law).
We may collect and use your personal data for any or all of the following purposes:

- performing obligations in the course of or in connection with our provision of the goods and/or services requested by you;
- verifying your identity;
- responding to, handling, and processing queries, requests, applications, complaints, and feedback from you;
- managing your relationship with us;
- processing payment or credit transactions;
- complying with any applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority;
- any other purposes for which you have provided the information;
- transmitting to any unaffiliated third parties including our third party service providers and agents, and relevant governmental and/or regulatory authorities, whether in Singapore or abroad, for the aforementioned purposes; and
- any other incidental business purposes related to or in connection with the above.

We may disclose your personal data:

- where such disclosure is required for performing obligations in the course of or in connection with our provision of the goods and services requested by you; or
- to third party service providers, agents and other organisations we have engaged to perform any of the functions with reference to the above mentioned purposes.

The purposes listed in the above clauses may continue to apply even in situations where your relationship with us (for example, pursuant to a contract) has been terminated or altered in any way, for a reasonable period thereafter (including, where applicable, a period to enable us to enforce our rights under a contract with you).

WITHDRAWING YOUR CONSENT

The consent that you provide for the collection, use and disclosure of your personal data will remain valid until such time it is being withdrawn by you in writing. You may withdraw consent and request us to stop collecting, using and/or disclosing your personal data for any or all of the purposes listed above by submitting your request in writing or via email to our Data Protection Officer at the contact details provided below.
Upon receipt of your written request to withdraw your consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us. In general, we shall seek to process your request within thirty (30) business days of receiving it.
Whilst we respect your decision to withdraw your consent, please note that depending on the nature and scope of your request, we may not be in a position to continue providing our goods or services to you and we shall, in such circumstances, notify you before completing the processing of your request. Should you decide to cancel your withdrawal of consent, please inform us in writing in the manner described in clause 8
Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclose without consent is permitted or required under applicable laws.

ACCESS TO AND CORRECTION OF PERSONAL DATA

If you wish to make (a) an access request for access to a copy of the personal data which we hold about you or information about the ways in which we use or disclose your personal data, or (b) a correction request to correct or update any of your personal data which we hold about you, you may submit your request in writing or via email to our Data Protection Officer at the contact details provided below.
Please note that a reasonable fee may be charged for an access request. If so, we will inform you of the fee before processing your request.
We will respond to your request as soon as reasonably possible. In general, our response will be within thirty (30) business days. Should we not be able to respond to your request within thirty (30) days after receiving your request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to your request. If we are unable to provide you with any personal data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the PDPA).

PROTECTION OF PERSONAL DATA

To safeguard your personal data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, we have introduced appropriate administrative, physical and technical measures such as minimised collection of personal data, and authentication and access controls (such as good password practices, need-to-basis for data disclosure, etc.).
You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.

ACCURACY OF PERSONAL DATA

We generally rely on personal data provided by you (or your authorised representative). In order to ensure that your personal data is current, complete and accurate, please update us if there are changes to your personal data by informing our Data Protection Officer in writing or via email at the contact details provided below.

RETENTION OF PERSONAL DATA

We may retain your personal data for as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws.
We will cease to retain your personal data, or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purpose for which the personal data was collected, and is no longer necessary for legal or business purposes.

TRANSFERS OF PERSONAL DATA OUTSIDE OF SINGAPORE

We generally do not transfer your personal data to countries outside of Singapore. However, if we do so, we will obtain your consent for the transfer to be made and we will take steps to ensure that your personal data continues to receive a standard of protection that is at least comparable to that provided under the PDPA.

DATA PROTECTION OFFICER

You may contact our Data Protection Officer if you have any enquiries or feedback on our personal data protection policies and procedures, or if you wish to make any request, in the following manner:

Email Address: hello@adroitinvest.com

EFFECT OF PRIVACY POLICY AND CHANGES TO PRIVACY POLICY

This Privacy Policy applies in conjunction with any other notices, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your personal data by us.
We may revise this Privacy Policy from time to time without any prior notice. You may determine if any such revision has taken place by referring to the date on which this Privacy Policy was last updated. Your continued use of our services constitutes your acknowledgement and acceptance of such changes.

Welcome to the Terms & Conditions (these “Terms“) for Adroit Investments (the “Platform“) operated by ADROIT INVESTMENT PTE. LTD. (“Adroit“, “we“, “our” or “us“). Adroit is a company incorporated in Singapore, whose principal place of business is at 71 Ayer Rajah Crescent, #04-01, Singapore 139951. Please read these Terms carefully before you start to use the Platform.

In order to become a User (“User” or “you“) of the Platform and to enjoy the service provided and features available on the Platform, you must read and accept all these Terms. By using our Platform, you accept and agree to be legally bound by these Terms. If you do not agree to be bound by these Terms, please refrain from using our Platform.

Access to the Platform

Access to our Platform is permitted on a temporary basis, and we reserve the right to withdraw or amend access to or use of our Platform for any reason without notice. We will not be liable to you or any third party if for any reason our Platform is unavailable at any time or for any period.

Your use of our Platform

You warrant that all information you provide on registration and contained as part of your account on this Platform is true, complete and accurate and that you will promptly inform us of any changes to such information by updating the details in your account.

It is your responsibility to ensure that any services, content or information available through the Platform meet your specific requirements.

You agree to act in a responsible and legal manner when using the Platform. You shall comply with all applicable laws, regulations and rules and undertake not to use the Platform for any unlawful purpose, for the commission of any offence or crime under the laws of any jurisdiction to which access is obtained through the Platform or in a manner which is likely to cause harm, offence or nuisance to any other Internet user.

You may use our Platform only for lawful purposes. You may not use our Platform:

to send, knowingly receive, upload, download, use or re-use any material which:
1. is defamatory, obscene, hateful, discriminatory or inflammatory;
2. promotes violence, discrimination or illegal activity; or
3. infringes any Intellectual Property Rights (as defined below), right of confidentiality or right to privacy;

to transmit, or procure the sending of, any unsolicited or unauthorised advertising or promotional material or any other form of similar solicitation (spam);

to generate and/or cause congestion to our network traffic in excess of reasonable and normal usage;

to cause any disruption, interference, interruption or degradation in our network and/or our Platform; or

to knowingly transmit any data, send or upload any material that contains any viruses, trojan horses, worms, keystroke loggers, spyware, adware or any other technologically harmful programs, data or code.

You also agree:

not to reproduce, duplicate, copy or re-sell the entire or any part of our Platform in contravention of these Terms; and

not to access with authority, interfere with, damage or disrupt:

any part of our Platform;
any equipment or network on which our Platform is stored;
any software used in the provision of our Platform; or
any equipment, network or software owned or used by any third party in connection with your use of our Platform

Adroit reserves the right to investigate and take appropriate legal action against anyone who, in our opinion, violates this provision, including, without limitation, reporting you to appropriate law enforcement authorities

From time to time, we may without penalty or liability, restrict access to some parts of our Platform, or our entire Platform, to users who have registered with us, at our sole discretion and without providing any reasons

We reserve the right to remove or suspend any material posted which is, in our sole discretion, in breach of this clause, or which we suspect to be in breach of this clause at our absolute discretion. Adroit shall be entitled to terminate your registration for breach of this clause.

Intellectual Property Rights in our Platform

The Platform contains intellectual property, which is the proprietary property of Adroit (“Adroit IP”). This includes, but is not limited to, copyrights, trademarks, information about technology, and other proprietary rights, and may be provided in the form of text, graphic, audio and video downloads, links or source codes. Adroit retains the rights to the Adroit IP and reserves all rights in respect of same.

Subject to these Terms, we grant you a non-exclusive, non-transferable, limited, revocable and non-sublicensable right to access and use the Platform and the material displayed thereon. However, no right, title or interest in any such materials will be granted or transferred to you as a result of any permitted use of such materials.

All materials incorporated in or accessible through the Platform, including, without limitation, text, photographs, images, graphics, illustrations, logos, button icons, software and other content, and the compilation, collection, arrangement and assembly thereof (including the look and feel of the Platform), are owned, controlled or licensed by Adroit, or by the original creators of such materials or their permitted licensors. Such materials may be used only for viewing the Platform in the ordinary course. Any other use of such materials, including any copying, reproduction, modification, sale, distribution, extraction, re-use, transmission, republication, downloading, display, posting, performance or other exploitation thereof by any means or medium without the prior written permission of the copyright owner is strictly prohibited.

In respect of all content or material that you submit or post on the Platform:
1. you grant us a worldwide, irrevocable royalty-free, transferable licence to use, reproduce, adapt, publish, translate and distribute such material in any media, together with the right to sub-licence such rights; and

you confirm that you have obtained the consent of any individual identified in such material to the posting of the material on the Platform.

In the event that your contributions to the Platform infringe any rights of any third party, you shall, at your own expense and at our discretion, either obtain the right to use such contribution or render such contribution free from infringement.

Reliance on Information

Commentary and other materials or information posted on or otherwise made available via our Platform are not intended to amount to advice on which reliance should be placed. We do not warrant the accuracy or completeness of any information or materials on our Platform or the reliability of any statement or other information displayed or distributed through our Platform. We, therefore, exclude all liability and responsibility arising from any reliance placed on such materials or information by you, or by anyone who may be informed of any of its contents, and you acknowledge that any reliance on any such statement or information shall be at your sole risk.

You acknowledge that you have not relied on any statement, promise, warranty or representation made or given by or on behalf of us which is not set out in these Terms, the Privacy Policy or any documents referred to in them. Nothing in this clause shall exclude or limit any liability for fraud or fraudulent misrepresentation.

Investment Advice

Adroit is not regulated by the Monetary Authority of Singapore (“MAS”) and does not offer any regulated financial services. The content, commentary and materials posted on the Platform are strictly for public information, distribution and educational purposes only and are not intended to address your particular requirements. We disclaim all liability and responsibility arising from any reliance placed on commentary or materials by any user of this Platform, or by anyone who may be informed of any of its contents.

You understand and agree that the Platform does not constitute any form of advice, recommendation, endorsement or arrangement. The information published on the Platform should not be interpreted as a recommendation for you to buy, sell, or hold that or any other security, financial product or investment. The opinions expressed on the Platform do not constitute investment advice.

The Platform does not provide tax, legal or investment advice or opinion regarding the suitability, value or profitability of any particular security, portfolio or investment strategy. Independent advice should be obtained before making any such decision from your financial adviser, tax adviser or solicitor.

In using the Platform you acknowledge that:

the Platform, and the commentary, material and content displayed on the Platform, are provided for information purposes only and are not intended for trading purposes;
the Platform may include certain information taken from stock exchanges and other sources from around the world; and
you expressly agree that your use of the Platform is at your sole risk

Adroit and its members, officers, directors, and employees (or a member of their household) may have positions in or may buy or sell any of the securities, derivative instruments, or other investments mentioned or described in content, either as agent or principal for their own account.

Use of your personal data

We will collect, use, disclose and/or process any personal data we may collect from you in connection with this Platform in accordance with our Privacy Policy on the Platform. You acknowledge that you have accessed and read the Privacy Policy and agree to the terms set out in it.

Our liability

This Platform and the information and content contained on it are provided "as is" without any representation or endorsement made and, to the maximum extent permitted by law, without warranty, representation, guarantee, condition or assurance of any kind whether express or implied (including without limitation any warranty that our Platform will be uninterrupted, available, defect-free or error-free, that the information and content contained on it are accurate, complete or of satisfactory quality, and/or that the content contained on our Platform does not infringe the Intellectual Property Rights of any third party).

To the maximum extent permitted by law, we, any of our group companies, officers, directors, employees, shareholders and agents hereby expressly exclude any and all liability for:

any loss, damage or costs, whether direct or indirect, incurred or suffered by you or any third party in connection with our Platform or in connection with the use, inability to use, or results of the use of our Platform, including but not limited to any pure economic loss; or any loss of or damage to your hardware, data or information;

the content, information and material posted or made available on our Platform;

any loss or damage due to any interruption or cessation of transmission of our Platform;

any loss or damage due to any bugs, viruses, trojan horses or similar malware which may be transmitted to or through our Platform and the information and content contained on it by any third party;

any platforms, websites or resources linked to our Platform; and

any loss of any business of yours, including but not limited to loss of income or revenue, loss of business, loss of profits or contracts, loss of anticipated savings, loss of data or waste of management or office time.

This clause does not affect our liability for death or personal injury nor any other liability which cannot be excluded or limited under applicable law.

The security of communications sent over the internet (including by e-mail) is subject to many factors outside of our control. We do not guarantee the security or confidentiality of any electronic communications and shall not be responsible to you for any loss or damage that you may suffer as a result of the transmission of any such communications.

We shall have no liability for your inability to connect to or to access our Platform which may result from any faults, errors or problems relating to your mobile hardware, software, network or security, your internet service provider or any other similar problem.

Suspension and termination

We will determine, in our discretion, whether there has been a breach of these Terms through your use of our Platform. When a breach of these Terms has occurred, we may take such action as we deem appropriate.

Failure to comply with these Terms may result in our taking all or any of the following actions:

(a) immediate, temporary or permanent withdrawal of your right to use or access our Platform or any part of it;

(b) issue of a warning to you;

(c) legal proceedings against you for reimbursement of all costs on an indemnity basis (including, but not limited to, reasonable administrative and legal costs) incurred or suffered by us resulting from your breach of these Terms;

(d) further legal action against you; and/or

(e) disclosure of such information to law enforcement or regulatory authorities as we reasonably feel is necessary or as required under applicable law.

We exclude liability for actions taken in response to breaches of these Terms. The responses described in these Terms are not limited, and we may take any other action we reasonably deem appropriate.

Viruses, hacking and other offences

You must not misuse our Platform by knowingly introducing viruses, trojans, worms, logic bombs or other material which is malicious or technologically harmful. You further agree not to upload or launch any automated systems or software onto or within our Platform, such as “robots” or “spiders”. You must not attempt to gain unauthorised access to our Platform, the server on which our Platform is stored or any server, computer or database connected to our Platform. You must not attack our Platform via a denial-of-service attack or a distributed denial-of-service attack.

We will report any such breach to the relevant law enforcement authorities and we will co-operate with those authorities by disclosing your identity to them. In the event of any such breach, your right to use our Platform will cease immediately.

We will not be liable for any loss or damage caused by a distributed denial-of-service attack, viruses or other technologically harmful material that may infect or affect your computer equipment, computer programs, data or other proprietary material due to your use of our Platform or to your downloading of any material posted or otherwise made available on it, or on any Platform linked to it.

Links

This Platform may contain links or references to other websites, these are provided for your convenience only. If you use these links, you leave the Platform. Adroit has no control over third party websites and accepts no responsibility for any content, material, information intellectual property rights, accuracy or opinions expressed on such websites. Inclusion of any linked website on the Platform does not imply approval or endorsement of the linked website by Adroit. When you access these third-party sites, you do so at your own risk, your use of such third party sites may be governed by the terms and conditions of that third party site.

Linking to the Website

You may link to the website homepage provided you do so in a way that is fair and legal and does not damage our reputation or take advantage of it, but you must not establish a link in any way so as to suggest any form of association, approval or endorsement on our part where none exists.

You may not mirror, screen scrape or otherwise reproduce all or any part of the website on any other site. Unless otherwise authorised in writing by us, you may not suggest any form of association, approval or endorsement of any website on our part.

Severability

In the event that any of these provisions are found to be or become unlawful, invalid or otherwise unenforceable, that provision is to be deemed severed from these Terms and shall not affect the legality, validity and enforceability of the remaining provisions of these Terms. These Terms shall continue in force as if such unlawful, invalid or unenforceable provision was severed from these Terms.

No Waiver

Any failure or delay by yourself or us in exercising or enforcing any right or remedy contained in these Terms does not constitute a waiver by the party responsible for such delay or failure. It shall also not constitute a bar to the exercise or enforcement at any subsequent time or times.

Entire Agreement

The Terms supersede any previous agreement between the parties in relation to the matters dealt with herein and represents the entire understanding between the parties in relation thereto.

Rights of Third Parties

A person who is not a party to these Terms has no right to enforce any term of these Terms under the Contracts (Rights of Third Parties) Act Cap. 53B to enforce any of its terms.

Governing Law

All questions pertaining to the construction and interpretation of these Terms and relating to the performance of any of the obligations or duties set forth herein by either of the parties hereto shall be determined in accordance with the laws of the Republic of Singapore.

Any dispute arising out of or in connection with the use of our Platform and these Terms, including any question regarding its existence, validity or termination, shall be referred to and finally resolved by arbitration in Singapore and in the English language, in accordance with the Arbitration Rules of the Singapore International Arbitration Centre for the time being in force, which rules are deemed to be incorporated by reference in this clause. The arbitration tribunal will consist of one arbitrator to be appointed by the Chairman of the Singapore International Arbitration Centre. The parties understand that any party's right to appeal or seek a modification of rulings in arbitration is severely limited. Any award rendered by the arbitrator(s) will be final and binding and judgment may be entered upon it in any court of competent jurisdiction in the country and state of the principal office of the parties at the time such award is rendered.

Changes to these Terms

We may revise these Terms at any time by amending this page. You are expected to check this page from time to time to take notice of any changes we have made, as they are binding on you. Some of the provisions contained in these Terms may also be superseded by provisions or notices published elsewhere on our Platform. Your continued access and/or use of the Platform following any amendment of

these Terms will signify your assent to and acceptance of its revised terms.

Privacy Policy & Terms of Use

Execute with Excellence.