This Privacy Policy (this “Privacy Policy”) describes how and why Iraic SME Stock Exchage DC. ("ISSE"), and the ISSE affiliates here: iraic.com/privacy-policy.html (each an "ISSE Affiliate") who post this Privacy Policy on their website (the “Websites”), collect and process information that may be used, directly or indirectly, to identify you (“Personal Information”), how this Personal Information is protected, and your rights in relation to it. Offline collections of your Personal Information are governed by separate privacy policies, including the ISSE Events Privacy Policy.
ISSE Affiliates provide services through www.iraic.com, www.iraicbank.com, www.iraic.trade, www.smestockexchage.com; any other Websites where this Privacy Policy is posted; and any software application made available by ISSE, ISSE Affiliate for use on a computer, tablet, mobile phone or other mobile device (together, the "Digital Services"). The Digital Services are owned and operated by ISSE. Unless this Privacy Policy states otherwise, in this Privacy Policy, the terms "us", "we" or "our" refer collectively to ISSE and the ISSE Affiliates.
This Privacy Policy applies only to the Personal Information collected through the Digital Services. It does not apply to access to ISSE's electronic trading platforms, whether provided through the Internet or by other means. Access to ISSE's electronic trading platforms is limited to members and participants of the relevant market who have entered into off-line agreements with ISSE or an affiliate of ISSE for such access, and is governed by the terms of those off-line agreements. Such agreements also explain how the Personal Information collected by ICE's electronic trading platforms is processed.
Your use of the Digital Services is subject to ISSE's Terms of Use, available from our homepage, including any applicable limitations on damages.
Consumer Notice of Collection
This Privacy Policy is provided to all consumers subject to this Privacy Policy. You may access specific topics in this Privacy Policy by clicking on the relevant links below:
1. Changes to this Privacy Policy
This Privacy Policy is current as of the effective date set forth above. We reserve the right to change this Privacy Policy from time to time. Changes and modifications to this Privacy Policy will be effective immediately upon posting of the changes and modifications on the Digital Services, except where prohibited by law. You should therefore periodically visit this page to review the current Privacy Policy. If we change this Privacy Policy, we will notify you of the changes by updating the effective date at the top of this policy and, if required by applicable laws, by other means, such as email or notice within the Digital Services. If at any time you choose not to accept the terms of this Privacy Policy, you should not use the Digital Services.
2. Collection of Personal Information
Personal Information We Collect Directly from You
We collect, or have collected in the previous 12 months, Personal Information from you when you use the Digital Services. The type of Personal Information that we collect from you depends on your particular interaction with the Digital Services. We collect Personal Information from you directly (such as your registration information), automatically (via technologies such as cookies), and from other sources, including commercially available sources, such as public databases (where permitted by law).
We require you to register with the Digital Services to access certain features. When we do, we may collect the following information from you during the registration process:
Identifiers, such as your name, date of birth, age, address, country of residence, phone number, email address, account login and password, or other identification details;
Commercial information including records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies;
Sensitive Personal Information such as precise geolocation information, biometric data, and data pertaining to race, ethnicity, religious beliefs, sexual orientation data, or military status;
Education information, such as the information included in your curriculum vitae;
Professional information, such as your job title, company, or investor type;
Financial information, such as your credit card information when making a purchase through the Digital Services (a third party service provider processes these transactions on our behalf and will collect from you your contact information (such as your name, address, and e-mail) and financial information (such as credit card number and expiration date));
Audio, electronic, visual, or similar information, such as photographs or voice recordings; and
Your preferences, such as how often you wish to receive marketing or other communications.
Personal Information We Collect Automatically
We and our third party service providers use cookies, web beacons, and other tracking technologies to collect Personal Information about you automatically as you use our Digital Services. Examples of this type of Personal Information include, but are not limited to:
Information about your estimated location as may be determined from the IP Address; and
Information about the device you are using, such as:
Internet Protocol (or IP) address or device ID/UDID, protocol and sequence information;
Browser language and type;
Domain name system requests;
Browsing history, time spent at a domain, time and date of your visit, number of clicks, or location data;
HTTP headers, application client and server banners;
Hardware model, operating system, application version number, device or browser data;
Personal Information that is aggregated, anonymized, or otherwise rendered non-identifiable (collectively “Nonidentifiable Data”) ; and
Internet or other electronic network activity information, such as the dates and times of your use of the Digital Services, the route by which you choose to access them, and your use of any hyperlinks or downloadable content available on the Digital Services.
We may combine this information with other Personal Information that we collect about you. For additional information about our use of these technologies, please see “Cookies & Other Tracking Technologies” below and our Cookie Policy.
Personal Information We Collect From Third Parties
We also collect information about you from third party sources, including suppliers that help us prevent money laundering and fraud; marketing agencies; identity verification services; and analytics providers. The categories of Personal Information we collect from these sources are:
Identifiers, such as your name or date of birth;
Commercial information;
Audio, electronic, visual, or similar information, such as photographs or voice recordings;
Financial information;
Professional Information, such as your employer name;
Education information;
Internet or other electronic network activity information; and
Inferences derived from the Personal Information listed above.
Please note that we may be required by law to collect and use certain Personal Information about you. And we may need to collect and use Personal Information to enter into or fulfil a contractual obligation with you. Failure to provide this information may prevent or delay the fulfilment of our obligations in these circumstances.
Where you provide Personal Information to ISSE for purposes of providing services (“Customer’s Personal Information”), ISSE acts as a Service Provider with respect to such Customer’s Personal Information. Our customers are responsible for providing notice and obtaining appropriate consents to collect Customer Personal Information and to disclose it to us as their service provider. If you are a borrower, you should refer to our customers’ privacy notices and/or contact them directly to understand how your Personal Information will be collected, used, and disclosed.
3. Use of Your Personal Information
We primarily use your Personal Information to provide our services to you and to respond to your inquiries. We also may use your Personal Information as follows:
To communicate with you, including to respond to your comments or requests for information, to request feedback on our products and services, and to notify you about changes to your subscriptions or to the services and products you use;
To help us understand our customers, to tailor and enhance our product and service offerings, anticipate and resolve problems with any products or services supplied to you, create products or services that may meet your needs;
To provide access to restricted pages or contents of the Digital Services (e.g., password protected webpages);
To comply with legal and/or regulatory requirements and cooperate with regulators and law enforcement bodies;
To facilitate your activity and to identify you when you log into your account on our Digital Services;
To send you marketing communications and advertising in line with your communications preferences and where permitted by applicable law about products and services that we believe would be of interest to you, including products and services offered by third parties;
To evaluate the success of our advertising campaigns, to improve our products and services, to assess patterns of use, and to plan and evaluate our marketing and business development programs; and
To protect our rights, your rights, and the rights of others, and to meet our own high standards of business practice.
Information For European Users
Some of the processing we conduct may involve making decisions about you based on automated processing of your Personal Information. If you are in the European Economic Area or the United Kingdom, where these decisions are based solely on our automated processing of your Personal Information (e.g., not subject to human review), these types of decisions will not have legal or similar effects on you, but you can still contact us for further information and to object to this use of your Personal Information.
Under European privacy law, we must have a legal basis to process Personal Information. In most cases the legal bases for our processing, under European privacy law, will be one of the following:
To fulfill our contractual obligations to you, for example to provide the Digital Services or to ensure that invoices are paid correctly for services provided pursuant to a contract;
To comply with our legal and/or regulatory obligations, for example to: obtain proof of your identity to enable us to meet our anti-money laundering obligations; comply with legal and/or regulatory requirements and cooperate with regulators and law enforcement bodies; and protect our rights, your rights, and the rights of others, and to meet our own high standards of business practice; and/or
To meet our legitimate interests, for example to: understand how you use the Digital Services and to enable us to use this knowledge to improve our products and services and to develop new ones; to communicate with you about the products and services that you use or we offer; maintain our accounts and records; to assess patterns of use; and to plan and evaluate our marketing and business development programs. When we process Personal Information to meet our legitimate interests, we put in place, when needed, safeguards designed to protect your privacy interests, freedoms, and rights under applicable laws.
We may obtain your consent to collect and use certain types of Personal Information when we are required to do so by law (for example, in relation to some direct marketing activities, our use of cookies and tracking technologies or when we process Sensitive Personal Information). If we ask for your consent to process your Personal Information, you may withdraw your consent at any time by contacting us using the details at the end of this Privacy Policy.
We may anonymize your Personal Information and use it for other purposes. For example, we may prepare aggregated reports about how users interact with the Digital Services for research. Once anonymized, the data is generally no longer treated as Personal Information under applicable law.
4. Cookies & Other Tracking Technologies
We use cookies and other technologies to automatically collect information when you access the Digital Services. For more information, please see our Cookie Policy.
Our systems generally recognize commercially reasonable opt-out preference signals (e.g., Global Privacy Controls). Recognition of this signal will only occur with respect to the device and/or browser that communicates the signal such that you may need to update your preferences on every device or browser you use to access our services.
5. Disclosures & Onward Transfers
We disclose, or have disclosed in the prior 12 months, the categories of Personal Information described above for our business purposes to the following persons/entities. In some instances, the Personal Information disclosed to these third parties may include Sensitive Personal Information.
Third Party Service Providers: To enable us to more efficiently provide the products and services you have requested from us, we may disclose your Personal Information to selected entities that act on our behalf as our agents, suppliers, or providers, or these entities may collect your Personal Information on our behalf. These service providers may provide services such as marketing support, technical assistance, data hosting, payment processing and customer service support. We also engage third-party analytics providers to help us understand how users engage with the Digital Services. These analytics providers may use cookies and similar technologies to collect information about your use of the Digital Services as well as information about your use of other websites over time.
Subsidiaries and ISSE Affiliates: We disclose Personal Information to subsidiaries and the ISSE Affiliates for the purposes of providing the services you have requested and to fulfil our contractual obligations to you, and to fulfil legal and regulatory obligations. We may also disclose Personal Information to subsidiaries and affiliates for their marketing use and so that they may develop and improve products and services, and subject to applicable law send you promotional and informational communications.
Legal Compliance and the Protection of Our Rights: We will disclose Personal Information to regulators, government authorities, and third parties where we believe it is necessary to comply with a court order, subpoena, or regulatory request. We may also disclose your Personal Information to law enforcement upon request. We may disclose Personal Information when we believe in good faith that such disclosures will: help protect our rights or enforce our Terms of Use; support our detection of, prevention of, or response to fraud or intellectual property infringement; help protect your safety or security; or protect the safety and security of the Digital Services, our services, or any individual.
Transfer of Business Assets: As we continue to develop our business, we might acquire or buy other businesses or assets. In such transactions, Personal Information generally is one of the transferred business assets. Also, we may transfer any information we have about you as an asset to third parties in connection with the consideration, negotiation, or completion of a merger or sale (including transfers made as part of insolvency or bankruptcy proceedings) involving all or part of ISSE or the ISSE Affiliates, or as part of a corporate reorganization or stock sale or other change in corporate control, for the purposes of such third parties carrying on our business in relation to the continued provision of our services to you as described in this Privacy Policy.
Disclosures Made with Consent: We may disclose your Personal Information with other third parties for whom you have given us written authorization to disclose your Personal Information, or as otherwise allowed or required by applicable law.
Additional Disclosures: From time to time we disclose your Personal Information to our attorneys, banks, auditors, securities brokers and other professional service providers and advisors in connection with the purposes described above.
Because we operate as part of a global business, the recipients referred to above may be located outside the jurisdiction in which you are located (or in which we provide the Digital Services). See the section on "International Transfers of Personal Information" below for more information.
6. Your Choices
If you wish to stop receiving marketing information concerning our services or products, or if you wish to withdraw any consent that you have provided, please contact us by email or submit a request at Privacy Web Form to notify us of your wishes.
7. International Transfers of Personal Information
We may transfer, process, and store your Personal Information outside of your home country, including in the United States and Canada. For the avoidance of doubt, if you are resident in the European Economic Area ("EEA") or the United Kingdom (“UK”) this may include the transfer of your Personal Information from within the EEA or UK to a country outside of the EEA or UK. We have put in place appropriate safeguards for international transfers, such as Standard Contractual Clauses approved by the European Commission and the UK Addendum to the Standard Contractual Clauses, as well as technical safeguards in accordance with legal requirements and the recommendations of the European Data Protection Board.
8. Your Rights in Relation to Your Personal Information
Subject to local law, you may have certain rights regarding your Personal Information. These may include, depending on the circumstances, the following rights to:
Access your Personal Information;
Rectify the Personal Information we hold about you;
Erase/Delete your Personal Information;
Restrict our use of your Personal Information;
Object to our processing of your Personal Information;
Receive your Personal Information in a usable electronic format and transmit it to a third party (also known as the right of data portability);
Receive additional information regarding the sources from which we collect information, the purposes for which we collect and disclose Personal Information, the information of yours we hold, and the categories of parties with whom we disclose your information;
Limit the processing of your Sensitive Personal Information;
Opt-out of profiling in furtherance of a legal or similarly significant decision;
Opt-out of targeted advertising;
Opt-out of the “sale” or “sharing” of Personal Information (as those terms are defined by applicable law);
Opt-out of automated decision-making that produces a legal or similarly significant decision;
Lodge a complaint with your local data protection authority; and
Withdraw any consent you have given to uses of your Personal Information.
New York, Manama, Dubai, London law requires that we describe certain disclosures of Personal Information that involve monetary or other consideration. Law treats such disclosures as “sales” or “sharing” even if no money is exchanged. As disclosed in Section 5, above, we may disclose the Personal Information described in this Privacy Policy with subsidiaries, affiliates, and business partners for their marketing use and so that they may develop and improve products and services, and subject to applicable law send you promotional and informational communications. Some such disclosures may constitute “sales” or “sharing” under law.
You have the right to opt-out of the sale or sharing (as described above) of your Personal Information. You may exercise that right by submitting a request through the link entitled “Your Privacy Choices” in the footer of the Websites.
If you would like to discuss or exercise the rights you may have, you may contact us as described below in the “Contact Us” section. Note that, as required by law, we will require you to prove your identity. We may verify your identity by phone call or email. Depending on your request, we will ask for information such as your name or the date of your last transaction with us. We may also ask you to provide a signed declaration confirming your identity.
In some circumstances, you may designate an authorized agent to submit requests to exercise certain privacy rights on your behalf. We will require verification that you provided the authorized agent permission to make a request on your behalf, and we may require you to verify your own identity directly with us.
Depending on where you are located, you may also have the right to appeal a decision that we make relating to your request to exercise a right related to your Personal Information. If you are a registered user of the Digital Services, you may access your personal account information online and make changes by logging into your account.
You may exercise your rights without fear of discrimination or of being denied goods or services. We may, however, provide a different level of service or charge a different rate as permitted by applicable law.
9. Security & Retention
We have put in place certain safeguards to help prevent unauthorized access and maintain data security with respect to your Personal Information. Despite these protections, however, we cannot guarantee that your data will be 100% secure. You should take measures to protect your Personal Information. In case there is unauthorized access to or use of your Personal Information, we may notify you of such access or use, including by electronic means if permitted by law.
We retain your Personal Information for as long as we have a relationship with you and for a period after the relationship has ended. When determining how long to keep your Personal Information after our relationship with you has ended, we take into account how long we need to retain the information to fulfil the purposes described above and to comply with our legal obligations, including regulatory obligations. We may also retain Personal Information to investigate or defend against potential legal claims in accordance with the limitation periods of countries where legal action may be brought.
10. Your Security Obligations
Your online access to certain of your Personal Information may be protected with a password you select. We will never ask you for your password in any unsolicited communication (such as letters, phone calls or email messages). You have an obligation to keep your user ID, password and Personal Information secure. As part of maintaining this obligation we recommend that you do the following:
Keep your user ID and password confidential;
Utilize a unique password and change it frequently;
Make sure others are not watching you enter your user ID and/or password on your keyboard when using protected elements of the Digital Services; and
Do not leave your computer unattended while logged onto protected elements of the Digital Services. After you finished accessing your information, exit the protected area.
11. Children
The Digital Services are not intended for use by minors (persons under the age of 18 and, in those Canadian provinces where the age of majority is 19, persons under the age of 19). We do not knowingly sell the Personal Information of minors under 16. If you are a minor, do not use the Digital Services. If parents or guardians believe their minor children have accessed the Digital Services and provided their Personal Information, please contact us using the information provided in the “Contact Us” section of this Privacy Policy so that we may delete the information.
12. Other Sites
Our Digital Services may contain links to other websites or products that we do not own or operate. Also, links to the Digital Services may be featured on third-party websites on which we advertise. Except as provided herein, we will not provide any of your Personal Information to these third parties without your consent. We provide links to third-party websites as a convenience to the user. These links are not intended as an endorsement of or referral to the linked websites. We recommend you read carefully the privacy statements, notices and terms of use of any linked websites. We do not have any control over such websites, and therefore we have no responsibility or liability for the manner in which the organizations that operate such linked websites may collect, use or disclose, secure and otherwise treat your Personal Information.
13. Shine the Light
Under "Shine the Light” law, esidents who provide Personal Information in obtaining products or services for personal, family or household use are entitled to request and obtain from us once a calendar year information about the customer information we shared, if any, with other businesses for their own direct marketing uses. If applicable, this information would include the categories of Personal Information and the names and addresses of those businesses with which we shared customer information for the immediately prior calendar year (e.g., requests made in 2024 will receive information regarding 2023 sharing activities).
To obtain this information, please submit a request through our Privacy Web Form.
If we are unable to authenticate your request we will reply as such to the email address from which your request originated. We will provide the requested information, along with any details of actions we’ve taken, to you at the email address you specify in your request.
Please be aware that not all information sharing is covered by the "Shine the Light" requirements and only information on covered sharing will be included in our response.
14. Additional Terms
If you are a resident of Singapore, please email to webmaster@iraic.group
15. Contact Us
We take your privacy concerns seriously. If you have any questions about this Policy or if you believe that we have not complied with this Privacy Policy with respect to your Personal Information, you may write to the following:
