Privacy Policy

1. About Us

Returning AI Pte. Ltd. is a Singapore-based technology company that provides a gamified trader engagement and loyalty platform for retail trading brokers. Our platform helps CFD brokers combat churn and increase customer lifetime value through white-label communities, quests, rewards, and engagement tools.

Registered Address: 11 Collyer Quay, #11-05, Singapore 049317

2. Personal Data We Collect

2.1 Definitions

As used in this Policy:

• "Visitor" means an individual who accesses our website or any of our digital properties;
• "Prospective Customer" means an individual or representative of a business who has contacted us to enquire about our services, requested a demonstration, or expressed interest in our platform;
• "Personal data" means data, whether true or not, about an individual 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.

2.2 Types of Personal Data Collected

Depending on the nature of your interaction with us, we may collect the following types of personal data:

Information you provide directly:

• Name and job title
• Business email address
• Company name and website
• Telephone number
• Country or region
• Enquiry details and messages submitted through contact forms
• Information provided during product demonstrations or meetings

Information collected automatically:

• IP address and approximate geographic location
• Browser type and version
• Operating system
• Device information
• Pages visited and time spent on our website
• Referral source and navigation paths
• Cookies and similar tracking technologies (see Section 8)

3. How We Collect Personal Data

We generally do not collect your personal data unless:

• 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 consent to the collection and usage of your personal data for those purposes; or
• Collection and use of personal data without consent is permitted or required by the PDPA, GDPR, or other applicable laws.

We collect personal data through:

• Our website contact forms and "Book a demo" submissions
• Email correspondence
• Business meetings and video conferences
• Trade shows and industry events
• Third-party business referrals
• Publicly available business information

4. Purposes for Collection, Use, and Disclosure

We may collect, use, and disclose your personal data for any or all of the following purposes:

• Responding to your enquiries, requests, and feedback;
• Scheduling and conducting product demonstrations;
• Providing information about our gamified loyalty platform and services;
• Evaluating and processing business partnership opportunities;
• Negotiating and entering into contracts for our services;
• Sending marketing communications about our products, services, industry insights, and company updates (where you have consented or where permitted by law);
• Improving our website, services, and user experience;
• Analysing website usage and visitor behaviour to enhance our digital presence;
• Complying with 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;
• Protecting our rights, property, or safety, and that of our customers and partners;
• Any other purposes for which you have provided the information;
• Any other incidental business purposes related to or in connection with the above.

5. Disclosure of Personal Data

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 services requested by you;
• To third-party service providers, agents, and other organisations we have engaged to perform any of the functions listed in Section 4, including:
  • Website hosting and maintenance providers
  • Customer relationship management (CRM) platforms
  • Email marketing service providers
  • Analytics and website optimisation tools
  • Cloud computing and data storage providers
  • Video conferencing platforms
• To professional advisers such as lawyers and accountants;
• To regulatory authorities, government agencies, or law enforcement as required by law;
• In connection with any merger, acquisition, or sale of all or a portion of our assets.

All third-party service providers are contractually bound to protect your personal data and use it only for the purposes for which it was disclosed.

6. Legitimate Interests

In compliance with the PDPA and GDPR, we may collect, use, or disclose your personal data without your consent for legitimate business interests where such interests are not overridden by your rights and freedoms. In relying on legitimate interests, we assess the likely adverse effects on the individual and determine that our legitimate interests outweigh any adverse effect.

We rely on legitimate interests for:

• Fraud detection and prevention;
• Network and information security;
• Direct marketing to existing business contacts (with opt-out options);
• Analytics and service improvement;
• Detection and prevention of misuse of our services.

The purposes listed above may continue to apply even after your relationship with us has been terminated, for a reasonable period thereafter.

7. International Data Transfers

Our platform operates globally, and we may transfer your personal data to countries outside Singapore and the European Economic Area ("EEA") where our service providers are located. Where we transfer personal data internationally, we ensure that:

• The recipient country provides an adequate level of data protection; or
• Appropriate safeguards are in place, such as standard contractual clauses approved by relevant authorities; or
• The transfer is necessary for the performance of a contract or other legal bases apply.

We 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 and GDPR.

8. Cookies and Tracking Technologies

8.1 What Are Cookies

Cookies are small text files placed on your device when you visit our website. We use cookies and similar technologies to enhance your browsing experience, analyse website traffic, and understand visitor behaviour.

8.2 Types of Cookies We Use

• Essential Cookies: Required for the website to function properly. These cannot be disabled.
• Analytics Cookies: Help us understand how visitors interact with our website by collecting information anonymously. We use services such as Google Analytics to analyse traffic patterns.
• Marketing Cookies: Used to track visitors across websites to display relevant advertisements and measure campaign effectiveness.
• Functional Cookies: Remember your preferences and settings to provide enhanced functionality.

8.3 Managing Cookies

You can control and manage cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of our website. For more information about cookies and how to manage them, visit www.allaboutcookies.org.

9. 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 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 services to you and we shall, in such circumstances, notify you before completing the processing of your request.

Please note that withdrawing consent does not affect our right to continue to collect, use, and disclose personal data where such collection, use, and disclosure without consent is permitted or required under applicable laws.

10. Access to and Correction of Personal Data

If you wish to:

• Make an access request for 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
• Make 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.

11. Your Rights Under GDPR

If you are located in the European Economic Area, you have additional rights under the GDPR, including:

• Right to erasure: Request deletion of your personal data in certain circumstances;
• Right to restriction: Request restriction of processing of your personal data;
• Right to data portability: Receive your personal data in a structured, commonly used format;
• Right to object: Object to processing of your personal data for direct marketing or based on legitimate interests;
• Right to lodge a complaint: Lodge a complaint with a supervisory authority in your country of residence.

To exercise any of these rights, please contact our Data Protection Officer.

12. 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, including:

• Encryption of data in transit and at rest
• Access controls and authentication measures (including multi-factor authentication)
• Regular security assessments and penetration testing
• Security awareness training for all personnel
• Secure cloud infrastructure with industry-standard certifications
• Data minimisation practices
• Regular security patching and updates
• Incident response procedures

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 in accordance with ISO/IEC 27001:2022 standards.

13. 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.

14. 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.

For website visitors, we typically retain analytics data for up to 26 months. For business contacts and prospective customers, we retain personal data for the duration of our business relationship and for a reasonable period thereafter for legal and audit purposes.

15. Third-Party Links

Our website may contain links to third-party websites, plugins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy practices. We encourage you to read the privacy policy of every website you visit.

16. Children's Privacy

Our website and services are not directed at individuals under the age of 18. We do not knowingly collect personal data from children. If you believe we have inadvertently collected personal data from a child, please contact us immediately, and we will take steps to delete such information.

17. 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:

18. Changes to This Privacy Policy

We may revise this Privacy Policy from time to time without prior notice. You may determine if any such revision has taken place by referring to the date on which this Policy was last updated. Your continued use of our website and services constitutes your acknowledgement and acceptance of such changes.

We encourage you to periodically review this page for the latest information on our privacy practices.