Release Date: February 6 , 2023
Effective Date: February 6, 2023
Whereas
Tiger Fintech (Singapore) Pte. Ltd, TTMF Limited ("We" or "Tiger") takes the security of our users' personal information very seriously and makes commercially reasonable efforts to protect their personal information. We are committed to adopting a consistent and strict policy in all of our operations. Through our Privacy Policy (the "Policy"), we would like to explain to you our handling rules for collecting and using personal information in order to better protect your rights and those of the individuals involved.
This Policy applies to the website, PC terminal, Tiger Trade APP, applet and all products and services provided to you in new forms as technology develops (hereinafter collectively referred to as "Mobile Apps" or "Products/Services") operated, developed and managed by Tiger. If we and our domestic affiliates use products or services from the Mobile Apps (e.g., logging in with a Tiger account) in other products or services that do not have a separate privacy policy, then this Policy applies to those products or services as well. If we and our domestic affiliates provide you with other products or services that have separate privacy policy, then the corresponding privacy policy will apply to those products or services.
Please read this Policy carefully, especially the terms marked in bold/bold underline, to understand in detail how we collect and use information so that you can better understand our services and make appropriate choices. Please make sure you fully understand and agree to this Policy before you start using the mobile application. By clicking "Agree to this Policy" or checking a box with a similar meaning, or by actively logging in, confirming, agreeing, accepting, and using the Mobile Apps and related services provided by us, you agree to our collection, use, storage, sharing, transfer, and disclosure of personal information in accordance with this Policy (including updated versions).
If you have any questions about this Policy or related matters, please contact us by email (support@itiger.com) or through the contact information provided in the "How to Contact Us" section of this Policy.
Table of Contents
I. How we collect and use personal information
II. How we use cookies and similar technologies
III. The personal information we may share, transfer or disclose
IV. How we store and protect personal information
V. How to exercise your rights
VI. Third party websites and services
VII. Cross-border transfer of personal information
VIII. Special protection for minors
IX. Notices and amendments
X. How to contact us
I. How we collect and use personal information
A. The personal information we collect and use
Personal information is all kinds of information related to identified or identifiable natural persons recorded by electronic or other means, excluding information after anonymization processing. Sensitive personal information is personal information that, if leaked or used illegally, could easily lead to the infringement of a natural person's human dignity or endanger the safety of his or her person or property, including biological recognition, religious beliefs, specific identity, medical and health care, financial accounts, travel traces and other information, as well as personal information of minors under 14 years of age or the equivalent if applicable. (We will prominently identify sensitive personal information involved in this Policy by underlining it in bold).
In the course of your use of our Products/Services, we collect information that you provide voluntarily, authorize or provide at your request, as well as information generated based on your use of the Mobile Apps, in order to provide you with the service, optimize the service and secure your account. If you refuse to provide or consent to our collection of such information, you will not be able to access the corresponding services.
You can learn more about our collection and use of your personal information by clicking Personal Information Collection List.
1. When you register as our user, you need to provide us with your phone number or email address, and supplement relevant network identification information (such as profile photo, nickname and login password) in order to meet the requirement regarding network real name and other requirements under the relevant laws and regulations; We will use your phone number or email address to contact you, including marketing. If you only need to use browsing, searching and other functions, you do not need to register as our user and provide the above information. When you are not registered or logged in, we may collect your device ID（i.e. IMEI、IDFA、IDFV、Android ID）and IP address for statistical, advertising attribution, and marketing purposes.
2. You can use a third party account to login to your registered Tiger account, or you can use the "Share" button to share certain content to third parties. We need to access the mobile application installation list to determine whether you have installed the third party client applications, we will use the third party authorization service to obtain the profile photo and nickname of the third party account you use when logging in, and save this information to the server. This information will be used to manage your account, and we will not provide this information to the public or use it for purposes other than this function unless you choose to do so or required by relevant laws and regulations.
3. When you log in to your Tiger account with your cell phone number and password, we collect your browser type and settings, device type and settings, operating system, mobile network information (carrier name and phone number) and app version number information for human verification operations to prevent interference from malicious programs and protect your login security.
4. When you use the profile photo editing function and post posts, comments, photos, etc. in the community, we need you to authorize the camera/lens permission of your device if you choose to use the "take a picture" or "film" method; if you use the "Select from album" method, we need you to authorize to use the album permission of your device. When you save the pictures in the app to the album when you need, we need you to authorize to use the album permission of the device. The pictures and video information you upload will be stored in our server, as storage is necessary to achieve this function.
5. When you visit and use the community, you can view, search, click the contents you are interested in, and upvote, comment, share and save the posts you are interested in, you can also post, upload (pictures, audio or video) by yourself. In order to facilitate your communication and interaction with other users, we will collect the information generated in the process of using the above mentioned functions, and your community nickname, UUID, friend relationship, note information.
6. When you redeem your rewards in our Rewards Center, we will collect your contact information (delivery name, address, phone number) for the purpose of distributing our event gifts.
7. Your clipboard function may be invoked to facilitate copying information, sharing or receiving shared information. Clipboard information will only be processed on your device and we will not store the information contained in your clipboard and will not use it for any other purpose.
8. When you use our market data, company actions or major events forecasting function, after you authorize to enable the permission to read/write your calendar, we will read/record the date of your concern market data, company actions or major events into the system calendar according to your operation in order to provide you with timely reminder service. If access is denied, you will not be able to use the reminder function, but it will not affect your access to other services.
9. If you wish to use the related services provided by international brokers, you can access the service platform and pages of the international brokerage firm through our Mobile Apps. The account opening and related functions are provided to you by our affiliate broker-dealer at different jurisdictions (“ Tiger Brokers”). You will first need to go to the service platform and pages of Tiger Brokers in the relevant country or region. Depending on the regulatory, legal requirements and account opening rules of specific broker-dealer, you may need to provide your identity information, identification information, contact information and biometric information directly to Tiger Brokers; when assessing your investment suitability, you may need to provide your professional status and asset information directly to Tiger Brokers; during the account opening process, you may need to turn on the device's camera and camera microphone permissions. The above information is collected by Tiger Brokers and is subject to the Tiger Brokers personal information processing rules, which you can further review in the Tiger Brokers Privacy Policy. If you do not want to provide the above information or refuse to provide the above permissions, you may not be able to complete the account opening process normally and will not be able to use the corresponding services and functions provided by Tiger Brokers, but will not affect your use of our Mobile Apps and our Products/Services under this Policy.
10. The default Mobile Apps only accesses the storage space in the application sandbox/this application directory assigned by the Android system. After you authorize to open the permission to read/write your device storage, we will read or write pictures, files, crash logs and other necessary information to the storage space of your device for providing you with information release or recording crash logs to ensure the stable operation of the Mobile Apps.
11. In order to meet the basic requirements set by laws and regulations and provision of services, to protect your account security and system operation security, to find out the causes when the failure of system by analysis of the collected information and to achieve the development and upgrade of the product and optimize the quality of service,, we will collect your device information and operation log information, which include:
(1) Device information: we will receive and record information about the device you are using according to the specific permissions you grant in the installation and use of Mobile Apps, including: device name, device model, unique device identifier (e.g. IMEI, IDFA, IDFV, android ID), operating system, IP address, device MAC address, software installation list, resolution, mobile application download channel, current mobile application version number, mobile application language setting information. In addition, we will use your unique device identifier，IP address，mobile application download channel, current mobile application version number, mobile application language setting information for advertising attribution and marketing.
(2) Operation log information: when you use our Mobile Apps, we automatically collect details of your use of our Mobile Apps, which are kept as relevant web logs. We are required to collect your log information, including: account status, login time, browsing history, which also includes your IP address, browser type, language used, operating system version, date and time of access, network requests, etc. We will obtain storage access to your device for the purpose of saving the aforementioned log information.
12. Customer service: when you contact us or propose dispute handling or apply for account-related business operations, in order to protect your account and system security, we need you to provide the necessary personal information to verify your identity. In order to contact and help you to solve your problem as soon as possible or record the solution and result of the relevant problem, we may keep your correspondence/call records with us and related contents (including account information, other information you provide to prove the relevant facts, or the contact information you leave). We may also use your other information that is reasonably necessary to provide and improve the quality of our services, including information provided in the process of customer service and questionnaire survey.
B. Our rules on the use of personal information
1. We will use your authorized personal information to implement the functions of the APP based on the intents and purposes set forth in this Policy. Please note that the Products/Services we provide to you are subject to change from time to time. Please note that if we want to use personal information for purposes other than those set forth in this Policy or to collect additional personal information not described herein, we will provide you with a detailed explanation of the purposes, methods, types of information collected and obtain your consent separately through page prompts, interactive processes, website announcements or other means. Once you agree, such additional information or use purpose will be considered part of this Policy and apply to this Policy.
2. When we collect various types of sensitive personal information from you, we will obtain your consent again through page prompts, interactive processes, website announcements, or other means as required by applicable law, and will keep the impact on your personal rights to a minimum. If we want to collect sensitive personal information that is not described in this Policy, or use sensitive personal information that is described for other purposes that are not described, we will also provide you with a detailed explanation of the necessity, manner, type, and impact on your personal rights and interests of the information collected in the manner described above.
3. Please note that if you provide information that contains personal information of another person, you need to ensure that you have the legal authorization of that person before providing such personal information to us.
C. Exceptions with your authorized consent
1. We may also collect and use your personal information in the following cases, but please be fully aware that your authorized consent is not required to collect your information in the following cases:
(1) those related to the fulfillment of laws, regulations and supervisory rules;
(2) those directly related to national security and national defense security;
(3) those directly related to public safety, public health and significant public interests;
(4) those directly related to criminal investigation, prosecution, trial and execution of judgments;
(5) those directly related to the protection of your own life, property and other significant legitimate rights and interests or those of other individuals but for which it is difficult to obtain your consent.
(6) the information collected is disclosed by you to the public on your own;
(7) information collected from legal public disclosure, such as legal news reports, government information disclosure and other channels;
(8) necessary for signing or performing contracts at your request;
(9) necessary for maintaining the Mobile Apps or other network platforms; and
(10) other circumstances as stipulated by laws and regulations.
2. You acknowledge and agree that after collecting personal information, we may de-identify the information through technical means, and the de-identified information will not identify you personally, in which case we may use the de-identified information to analyze and commercially exploit the database without obtaining your consent. All personal information provided by you when using the Mobile Apps will continue to be authorized for our use unless you delete it or refuse to allow us to continue collecting it through your device's system settings.
Ⅱ How we use cookies and similar technologies
A. Cookie
Cookies are pieces of information stored directly on the computer that you are using. Cookies allow us to collect information such as browser type, time spent on the services, pages visited, language preferences and other traffic data. We and our service providers use the information for security purposes, to facilitate navigation, to display information more effectively, and to personalize your experience. We also gather statistical information about use of the services in order to continually improve our design and functionality. Cookies further allow us to select which of our advertisements or offers are most likely to appeal to you and display them while you are on the services. We may also use cookies or other technologies in online advertising to track responses to our ads. If you do not want information collected through the use of cookies, most browsers allow you to automatically decline cookies or be given the choice of declining or accepting a particular cookie (or cookies) from a particular website. If, however, you do not accept cookies, you may experience some inconvenience in your use of the services. You also may not receive advertising or other offers from us that are relevant to your interests and needs.
B. Using pixel tags and other similar technologies
A Pixel tag (also known as a web beacon and clear GIF) is an invisible tag placed on certain pages of our website but not on your computer. Pixel tags are usually used in conjunction with cookies and may be used to, among other things, track the actions of users of the services measure the success of our marketing campaigns, and compile statistics about usage of the services and response rates. You have the choice to set up your web browser to block cookies which will in turn disable the pixel tags from monitoring your website visit. You may also remove cookies stored from your computer or mobile device. However, do note that when you enable blocking of cookies and pixel tags, it may limit certain features and functions in your use of our websites or applications.
III. The personal information we may share, transfer or disclose
A. Sharing of personal information
1. We will not share your personal information with any third party without your consent, except for the following conditions:
(1) Sharing with your consent: With your explicit consent, we will share your personal information with a third party.
(2) Sharing under legal circumstances: We may share your personal information with external parties as required by laws and regulations, litigation dispute resolution or administrative or judicial authorities, etc.
(3) Sharing with authorized partners: In order to achieve the purposes stated in this Policy, some of our Services will be provided by our partners. Therefore, we may share the personal information you provide to our partners in order to ensure the provision of relevant Services to you and to improve your user experience. For example, when you participate in a reward program offered by us, we must share your personal information with our partners in order to arrange for the issuance of the reward or to arrange for the partner to provide the service; in order to contact our users to handle disputes, to handle business operations related to personal accounts, or when special business situations require urgent bulk notifications to users, we need to cooperate with outbound calling platforms to share your contact information and notification content to provide customer service to you.
(4) Necessary sharing with our affiliates: In order to facilitate our provision of consistent Services and personalized recommendations to you, we may share personal information among companies that we directly or indirectly control or other affiliates. However, such sharing will be subject to the purposes stated in this Policy. We will share your personal information with our affiliates only as necessary and subject to the purposes stated in this Policy. If our affiliates need to change the purposes for which personal information is used, they will seek your authorized consent separately.
(5) When you have questions that we need to answer, complain about us, complain about others or are complained about by others, in order to protect your and those of others’ legitimate rights and interests, we may save your name and contact information, complaints and related communication content in the customer service system provided by the third-party provider and may provide related information to the consumer rights protection department and other regulatory authorities in order to resolve complains and disputes in time, except for the information explicitly prohibited to provide by laws and regulations.
(6) We may share your personal information with our accountants, auditors, legal counsels or similar advisors when we need to obtain professional advice.
(7) Other agreements between you and us regarding the sharing of personal information.
2. We will only share personal information for lawful, legitimate, necessary, specific, and explicit purposes. For companies, organizations and individuals with whom we share personal information, we will require them to handle the information in accordance with our instructions, this Policy and any other relevant confidentiality and security measures. At the same time, we will fulfill our legal obligations in accordance with applicable laws and regulations. For example, we will inform you of the name and contact information of the recipient, the purpose and manner of sharing and the type of personal information shared through page prompts, interactive processes, website announcements, or other means when we share your personal information and obtain your explicit consent; we will also re-solicit your consent if the foregoing information changes.
B. Transfer of personal information
We will not transfer your personal information to any company, organization or individual except for the following circumstances:
1. Obtain your consent in advance;
2. Required by laws, regulations or mandatory administrative or judicial requirements;
3. If the transfer of personal information is involved in the circumstances of transfer of assets, acquisition, merger, reorganization or bankruptcy liquidation, we will inform you of the relevant situation, and require the new companies and organizations holding your personal information to continue to be bound by this Policy. If the purpose for the use of personal information is changed, we will request the companies or organizations to obtain your explicit consent.
C. Disclosure of personal information
We will disclose personal information only in the following circumstances and subject to security measures that meet industry standards:
1. We will disclose designated information in your expressly specified manner according to your request.
2. We will display the winner's cell phone number or user nickname after desensitize when announcing the list of certain prize winning activities.
3. We may publicly disclose your personal information in accordance with the scope and manner in which we are required to provide your personal information by law, regulation, justice, legal proceedings, or mandatory administrative enforcement requirements of governmental authorities.
4. When we receive a request for disclosure of your personal information based on laws, regulations, judicial, legal procedures, or mandatory administrative enforcement requirements of governmental authorities, we will request reasonable documentation from the relevant authorities making the request to ensure that such requests have a legitimate basis and that the relevant enforcement authorities have a legitimate right and reasonable purpose to obtain your personal information.
D. Exceptions for prior consent when sharing, transferring, or disclosing personal information
In the cases mentioned in "I. C. Exceptions with your authorized consent" in this Policy, we are not required to obtain your consent for the sharing, transfer, or disclosure of personal information.
We may share, transfer or disclose personal information that has been de-identified or anonymized in accordance with relevant laws, regulations and regulatory requirements and our business needs. Please be aware that the sharing, transfer or disclosure of anonymized or de-identified personal information and ensuring that the recipient of the information cannot recover and re-identify the subject of the information is not an external sharing, transfer or disclosure of personal information, and that the retention and processing of such information will not require separate notification to you and your consent.
IV. How we store and protect personal information
A. Storage of personal information
1. Storage Territory: Personal information collected and generated by us for operating Mobile Apps and Products/Services under this Policy will be stored in the country where we have facilities or in which we engage service providers. If we need to store your personal information collected and processed under this Policy, we will strictly comply with applicable laws and regulations and ensure the security of your personal information. Please refer to "VII. Cross-border Transfer of Personal Information" in this Policy for details.
2. Storage Period: We will retain your personal information as long as necessary to achieve the purposes described in this Policy, unless the storage of such information is required or permitted by law, regulations or regulatory documents for a longer period, such as the following:
(1) To comply with relevant requirements of applicable laws and regulations;
(2) To comply with a court judgment, ruling or other legal process;
(3) To comply with the requirements of the relevant authorities or legally authorized organizations;
Upon the expiration of retention period, we will delete your personal information or anonymize it in accordance with the requirements of applicable law.
3. Termination of Operation: If we terminate our service or operation, we will notify you at least thirty days in advance and delete or anonymize your personal information after the termination of the service or operation.
B. Protection of personal information
We attach great importance to information security and take reasonable precautions to protect personal information:
1. We have taken reasonable and practical security measures in line with industry standards to protect your personal information against unauthorized access, public disclosure, use, modification, destruction or loss of data. We will take all reasonable and feasible measures to protect your personal information. We take physical, technical and administrative security measures to mitigate the risks of loss, misuse, unauthorized access, disclosure and alteration, including but not limited to, transport-level data encryption, firewall and encrypted storage, physical access controls, and information access authorization controls. We've set up a security program to protect your information from unauthorized access. For example, all of network communications between you and us is protected with encryption (SSL). Your personal information is encrypted and stored on our server with high strength encryption. We will use a trustworthy protection mechanism to prevent malicious attacks on personal information; we will deploy strict data access authority control and multiple identity authentication technologies to protect personal information and avoid illegal access and use of data. In the use of personal information, such as personal information presentation, personal information correlation calculation, we will use a variety of data desensitization techniques including content replacement, SHA256 to enhance personal information security. We strengthen the audit of personal information security by adopting automatic code security check and data access log analysis technology.
2. We have an advanced data security management system, which focuses on data life cycle, to improve the security of the whole system from organization construction, system design, personnel management, product technology and so on. For example, we establish the data classification system, data security management rules and security development rules to regulate the storage and use of personal information. We require all employees to sign a confidentiality agreement. We hold training courses on security and privacy, and strengthens employees' understanding of the importance of protecting personal information and conducts operations in strict accordance with protection requirements by such means as assessment and review as well as including data protection in their daily assessment. We have been certified that we are in conformity with ISO27001/ISO27701/ISO29151/ISO20000 standard, which shows that we are already at the advanced level in the industry in the fields of information security, business continuity and privacy protection.
3. In addition to providing systematic personal data protection, our Security Department - Personal Information Protection Commissioner will act as Data Protection Officer (DPO) to be fully responsible for your data protection.
4. We will take all reasonable and practical measures to avoid collecting unrelated personal information and will retain your personal information only for such periods of time as is necessary to achieve the purposes described in this Policy, unless an extension of the retention period is required or is permitted by law. After the necessary period, we will delete or anonymize your personal information, except as otherwise provided by laws or regulations. When we terminate our service or operation, we will notify you by push notification, announcement and so on.
5. Please understand that the Internet is not an absolutely secure environment. We strongly recommend that you use our Products and Services in a secure manner and with a sophisticated and reliable password to help us secure your account. If you find that your personal information is leaked, especially if your account or password is leaked, please contact us immediately according to the contact information provided in this Policy so that we can take appropriate measures.
6. In the event of a personal information security incident, we will inform you in accordance with the requirements of laws and regulations of the basic situation and possible impact of the incident, the measures we have taken or will take, the recommendations you can take to prevent and mitigate the risks, and the remedial measures you have taken. We will inform you by mail, letter, telephone or push notification. When it is difficult to inform each user one by one, we will take reasonable and effective way to publish announcements. At the same time, we will also report the disposal of information security incidents according to regulatory requirements.
C. Security incident disposal
In the event of a security incident such as the leakage of personal information, we will promptly deal with it in accordance with the regulations to prevent the expansion of the security incident.
Please understand that due to the limitations of technology and risk prevention, even if we have tried to strengthen security measures, we cannot always guarantee 100% security of information. You need to understand that the systems and communication networks you use may incur problems due to circumstances beyond our control, and it cannot be guaranteed that whether communications with other customers through such as e-mail, instant messaging, social networking software or other service software, are fully encrypted, and we recommend that you use complex passwords when using such tools and pay attention to keeping your information secure.
Please make sure you keep your account number, password and other elements of your identity safe. When you use the mobile application, we will use your account number, password and other elements of your identity to identify you. If you disclose the aforementioned information, you and related subjects may suffer losses and you may be adversely affected. If you discover that your account number, password and/or other elements of your identity may be or have been leaked, please contact us immediately so that we can take appropriate measures in time to avoid or mitigate the relevant losses.
V. How to exercise your rights
A. Access, correct and delete your personal information
1. Access and correct your personal information
(1) You have the right to access and correct your personal information, subject to exceptions provided by laws and regulations.
(2) You can manage the binding and unbinding of your account, and access and change information such as your phone number and email address by logging in our app, entering “Me” page and clicking “Settings” in the upper-right corner to “Account Management” and “Security Setting”. You can modify your personal information in “Me” – “Personal Homepage” – “Edit”, including your picture, nickname and profile. You can modify your login passwords under “Me”- “Settings” – “Security Setting”.
(3) You have the right to obtain a copy of the personal information kept in Tiger. You can request a copy by calling our customer service and we will send you a copy to the email address tied to your account within the time limit provided by law. Please note that in some cases we have the right to refuse requests for access to copies of personal information (especially information specifically protected by laws and regulations).
(4) If you are unable to access and correct the above information, you can contact the customer service, we will reply to your request within 15 working days.
(5) When you want to change your personal information or you find errors in your personal information that may affect our provision of Services or affect your normal transactions on behalf of the relevant subject, or your personal information should be corrected in time in accordance with relevant laws and regulations, you should correct it yourself or contact us to correct in time, otherwise all adverse consequences caused by this shall be borne by you.
2. Delete your personal information
(1) You can request us to delete your personal information in the following cases. Detailed request of how to delete can be referred to this Policy and we will process your request for deletion as soon as we receive it:
· If we process your personal information in a manner contrary to the provisions of relevant law;
· If we collect and use your personal information without your consent;
· If we process personal information in serious violation of the terms of the agreement with you;
· If you no longer use any of our Products or Services, or you take the initiative to close an account;
· If we no longer provide any Product or Service to you.
(2) If we decide to respond to your request for deletion, we will also notify the entities that receive your personal information from us of the request to delete it in a timely manner, unless otherwise required by relevant law or regulation, or if they receive your separate authorization. When you remove information from our Services, we may not immediately remove that information from the backup system, but we will remove it when we back up updates.
B. Change the scope of your authorized consent or revoke your authorization
1. You may change the scope of our continuous collection of personal information or revoke your authorization by deleting information, turning off the functions of the device or otherwise. You may also revoke our full authorization to continue to collect your personal information by canceling your account.
2. Please understand that each business function requires some basic personal information to complete. After you withdraw your consent or authorization, we cannot continue to provide you with the service for which you withdraw your consent or authorization, and we will no longer process your personal information. However, your decision to withdraw your consent or authorization will not affect the processing of personal information previously conducted based on your authorization. Due to technical limitations, laws, regulations or regulatory requirements, we may not be able to meet all of your requests immediately. We will store your personal information securely and restrict any further processing of it until backups can be erased or anonymization is achieved.
3. If you no longer want to receive marketing-related emails from us on a going-forward basis or related matters, you may opt-out by using the "Unsubscribe" link that would always be contained in the marketing email or contact us by email (support@itiger.com) or through the contact information provided in the "How to Contact Us" section of this Policy.
C. Management of notifications and personalized pushes and system permission
1．Management of notifications
(1) We provide you with alerts and notifications for news announcements, hot posts and related content so that you are kept up to date with the latest information on the content you are interested in.
(2) You can manage on alerts and notifications in the following scenarios:
· APP message push: You can reject our notifications on the interface of "Me" - "Settings" - "Notification Settings " - "App Push" and you can also turn off pop-up ads by clicking the "Skip" or "Close" button on the pop-up ads.
· SMS and email notifications: You can reject our notifications on the interface of "Me" - "Settings" - " Notification Settings " - "SMS, email notifications" to refuse us sending you SMS and emails.
· WeChat Service Account notifications: If you follow our WeChat Service Account in WeChat, you can reject our notifications on the interface of "Me" - "Settings" - "Notification Settings " - "WeChat Service Account" to refuse us sending you SMS and emails.
(3) If you do not wish to receive promotional SMS or call-backs from us, you can also unsubscribe via the corresponding unsubscribe function in the message or explicitly decline them in the call-back.
2．Management of personalized push
(1) About personalized recommendation service
· We will inform you of the user information collected for personalized recommendation, the way of user feedback and to control information recommendation through this Policy, instant notification (such as pop-ups, prompts, etc.), etc.
· We will collect your browsing behavior, browsing time and device information such as clicking, following, favoriting, searching, browsing, sharing, commenting, liking and feedback during your use of the Service, in order to analyze and calculate personalized recommendations, and select content you may be more interested in according to the calculation results. We will provide real-time feedback to the recommendation model based on your browsing behavior during the use of the Product, and constantly adjust and optimize the recommendation results.
· The personalized recommendation service we provide mainly includes information recommendation, community content recommendation and advertisement recommendation, etc.
(2) Control and management of personalized recommendation
· When you are not interested in the recommended ads, you can click "Skip" or "Close". We also provide a "Feedback" portal to collect your comments and suggestions.
· Subscribe to the content you need autonomously: the following channel will show you the accounts you actively choose to follow and you can choose to follow or unfollow the accounts.
· When there is no content you are interested in, you can also enter the keywords you like in the search bar, click and read the search results.
3. Management of system permission
(1) You can manage and withdraw the system authorization set by you in the App through [My] - [Settings] - [Privacy Management] - [System Permission Management].
(2) Please understand that after you have performed the above actions, we will no longer be able to provide you with the services corresponding to the withdrawal of consent or authorization, but it will not affect the personal information processing already carried out based on your previous authorization.
D. Cancel your account
1. You may apply for the cancellation of your account by:
(1) You can submit your account cancellation request in the " Settings" - " Account Management" - "Account Cancellation" on the "Me" page；
(2) Contact our customer service staff for assistance in applying to cancel your account.
2. After Customer Service has verified your identity and your account cancellation request, and has confirmed that there are no outstanding disputes on your account, your cancellation request will be processed and your account will be cancelled in accordance with your request within fifteen business days. After your account has been cancelled, we will cease to provide you with products or services. Unless otherwise required by law or regulation, we will delete or anonymize your personal information at your request.
3. We would like to remind you that your registered information and benefits will be lost after account cancellation and your account cannot be restored, nor can you retrieve any content or information related to your account; The cancellation of your account may cause inconvenience to you in terms of after-sales service or maintenance, so please back up all information related to your account and all kinds of bills and documents before you do so.
E. Respond to your request above
For security, you may be required to provide a written request or otherwise certify your identity. We will respond to your request within fifteen working days after receiving your feedback on identity verification and completing the verification. If you are not satisfied, you can additionally seek an external resolution mechanism by using the means provided in Section X below.
For your reasonable request, we do not charge fees in principle, but for repeated, beyond the reasonable limit of the request, we may refuse or as appropriate charge a certain cost. We may reject requests that are repetitive, require excessive technical means (for example, requiring the development of new systems or fundamentally change existing practices), pose a risk to the legal rights of others or are highly impractical (for example, in relation to information stored on backup tapes).
We shall have the right to reject your request in accordance with relevant laws and regulations in the following circumstances:
1. those related to the fulfillment of laws, regulations and supervisory rules;
2. those directly related to national security and national defense security;
3. those directly related to public safety, public health and significant public interests;
4. those directly related to criminal investigation, prosecution, trial and execution of judgments;
5. where there is sufficient evidence of subjective malice or abuse of your rights;
6. those directly related to the protection of your own life, property and other significant legitimate rights and interests or those of other individuals but for which it is difficult to obtain your consent;
7. those responding to your request would result in serious harm to the legitimate rights and interests of you or other individuals or organizations
8. those commercial secrets are involved.
VI. Third party websites and services
Our mobile applications may link to the links or other services provided by third parties (including websites or other forms of services).
A. You may use your Tiger account to log into third party platforms. With your consent, the third party may collect your personal information (including your avatar, nickname and your log information) and may install automatic data collection tools on your computer in order to function properly as described above.
B. Other situations in which we access to third party services. For example, for the purposes stated in this Policy, we may access third party software and share some of your personal information with such third parties in order to provide a better service and experience.For the SDKs we access, please read the Statement for using third-party SDK.
The third party services mentioned above are operated by the relevant third parties. This Policy applies only to the personal information we collect and does not apply to services provided by any third parties or their rules governing the use of information. Your use of such third party services and any information you provide to such third parties will be subject to the third parties' terms of service and their personal information protection rules (and not this Policy), and you should read their terms and conditions carefully, judge the risks and make your own decisions about whether to accept, use the third parties’ services or provide information to third parties. If you find that there are risks associated with these third party services, you are advised to terminate the operation to protect your legitimate interests.
In addition, we use third-party advertising companies to serve advertisements regarding goods and services that may be of interest to you when you access and use the Services and other websites or online services, as well as to provide advertising-related services such as reporting, attribution, analytics, and market research. You may receive advertisements based on information relating to your access to and use of the Services and other websites or online services on any of your devices, as well as on information received from third parties. These companies place or recognize a unique cookie on your browser (including through the use of pixel tags) that collects information about your use of the Services over time. They also use these technologies, along with information they collect about your online use, to recognize you across the devices you use, such as a mobile phone and a laptop. For advertising, we may share a common account identifier (such as an email address or user ID) or data in a hashed format with our third-party advertising partners to help identify you across devices.
VII. Cross-border transmission of personal information
A. Your Personal Information may be stored and processed in the country where we have facilities or in which we engage service providers, and by using the Services you understand that your information will be transferred to countries outside of your country of residence, which may have data protection rules that are different from those of your country. To the extent that we need to transfer your personal information collected and processed under this Policy to other countries for business or administrative purposes (including making your personal information accessible to other jurisdictions), we will meet the necessary pre-requisites and fulfill the corresponding legal obligations in strict compliance with laws and regulations and requirements of regulatory authorities before such transfer, including informing you of the name and contact details of the foreign recipient, the purpose and manner of the transfer, the type of personal information to be transferred, the manner and procedure by which you can exercise your rights with the foreign recipient and obtaining your separate consent. Although other countries have different data protection laws, we will ensure that your personal information is protected in other countries in the same way as it is in your country of residence.
If you visit the service platforms and pages of international brokers or third parties to obtain their products or services, the international brokers or third parties may provide their products or services through resources and servers around the world. If you wish to obtain such products or services, you may need to provide the relevant information directly to the international brokers or third parties according to the demand for the relevant products or services. Please refer to the relevant parts of this Policy to determine your own risk and decide whether to accept, use or provide information to international brokers or third parties in relation to such products or services.
VIII. Special protection for minors
Minors should not have access to our services and we do not collect personal information from minors; if you believe that we may have unknowingly collected information from your child or ward under the age of eighteen, please contact us in accordance with Section X of this Policy and we will delete such information.
IX. Notices and Amendments
We may amend this Policy from time to time in light of developments in our products or services and relevant requirements of law and regulation.
After the amendment of this Policy, you have the right to choose to accept the updated personal information protection policy or to stop using the Mobile Apps. If you continue to use it, you are deemed to have fully read, understood and accepted the revised personal information protection policy.
In order to fully protect your legal rights and keep you informed of our latest information on personal information protection, we will post an updated version of this Policy on the mobile application ("Me→ Settings → Privacy Policy") page. We will also provide more prominent notice of material changes (including through public announcements or pop-ups). Please also visit our Policy page from time to time to keep up with our latest privacy policy.
Material changes referred to in this Policy include but are not limited to:
1. Our service model has changed significantly. For example, the purpose of processing personal information, the type of personal information processed, the way to use personal information, etc.;
2. We have a significant change in control and other aspects, such as mergers and acquisitions caused by the information controller change;
3. Changes to the main objects of sharing, transfer or public disclosure of personal information;
4. There are significant changes in your right to participate in personal information processing and the way in which you exercise such right;
5. Changes in the department, contact information and complaint channel responsible for handling personal information security;
6. Personal information security impact assessment report shows that there is a high risk.
X. How to contact us
A. 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:
Tiger Fintech (Singapore) Pte. Ltd:dpo@tigerbrokers.com.sg
TTMF Limited:dpo@tigertrade.app
B. We have also the Security Department, which you can contact by sending an email to security@itiger.com.
C. We will generally respond to your request within 15 working days after receiving your comments. If you are not satisfied with our response, especially if you believe that our personal information handling practices have harmed your legitimate rights and interests, you may also file a complaint or report to the regulatory authorities of your country of residence.