At Aspen Digital, your privacy is very important to us. This Policy applies to the online products and services offered by Aspen Digital (collectively, “Aspen Digital Services”) and shall form part of the User Service Agreement. If you have any questions about this Policy, please feel free to contact us via our website (www.aspendigital.co) or at info@aspendigital.co.

 

Type of Information

 

We offer a service that requires you to register for an account and provide some personal and business information to us. In order for us to provide the Aspen Digital Services, we may collect the following types of information:-

 

Personal and Business information – When you sign up for an Aspen Digital account, we ask you for personal and business information and we may ask for supporting documents and additional information when conducting identity verification. We may also collect personal and business information about you or persons affiliated with your company from third party entities (e.g. identity verification agencies and credit referencing agencies) when we seek to verify your identity as part of our regulatory requirements. The personal and business information may be shared with Aspen Digital’s designated third party service provider for the sole purpose of conducting customer due diligence, anti-money laundering/counter-terrorist financing (“AML/CTF”) screening, suspicious activities/transaction monitoring and any other similar purposes as required by the applicable laws, provided that any such party shall handle have a vigorous privacy policy in place and is compliant with all applicable laws. 

 

Transaction Information - We may collect transaction information as you use Aspen Digital Services, including but not limited to deposit records, account balances, trade history, order activity, and other records relating to transactions you conduct using the Aspen Digital Services. We collect such transaction information to monitor suspicious trading activity for user fraud protection, legal case resolution, and any other purposes disclosed in this Privacy Policy.

 

User communications – Email or other communication sent to Aspen Digital, may be retained in order to process your inquiries, to respond to your requests, and to improve our services. 

 

Use of Information

 

In addition to the purposes of the collection of the information as aforementioned, Aspen Digital may use the information collected to:-

 

• Provide you with the Aspen Digital Services and carry out our obligation to you;

• Communicate and interact with you regarding the Aspen Digital Services;

• Comply with the applicable regulatory and legal obligation, including but not limited to verifying your identity as part of initial and on-going Know-Your-Client due diligence process and fulfil our obligations under the applicable AML/CTF laws and regulations;

• Perform credit check, verification procedures, data verification, due diligence and risk management;

• Protect our platform, users, and other sensitive information from malicious activities, including but not limited to using IP addresses and cookies to protect against automated abuse such as spam, phishing, and DDoS attack; 

• Analyse trading activities with a view to detect suspicious behaviours and prevent potential fraud and loss of funds;

• Assist other financial institutions to conduct credit checks and collect debts as may be permissible or required under the applicable laws;

• Ensure that users maintain a reliable credit and provide up-to-date information for our record;

• Design financial services or related products for client’s use (including the provision of financial advice to clients in appropriate cases);

• Meet the information disclosure requests or requirements put forward by laws or lawfully required by law enforcement agencies;

• Any other purposes allowed or required by laws.

 

In the event that Aspen Digital goes through a business merger, acquisition by another company, or sale of all or a portion of its assets, personal and business information may be among the assets transferred. We will provide notification on Aspen Digital’s website for a minimum of 30 days if any such change in ownership takes place.

 

Handling of Information

 

We take appropriate security measures to protect against unauthorized access to or unauthorized alteration, disclosure, or destruction of data. These security measures include internal reviews of our data collection, storage and processing practices, and security measures, as well as physical security measures to guard against unauthorized access to systems where we store personal data. We restrict access to personal information by Aspen Digital employees and third party service providers who need to know that information in order to operate, develop, or improve our services and ensure compliance with the applicable laws. These individuals and/or entities are bound by confidentiality obligations and may be subject to discipline, including termination and criminal prosecution, if they fail to meet these obligations. 

 

While we shall endeavour to keep your personal information safe by using secured storage systems with industry standard encryption and implement security measures to ensure that your information is not lost, abused, or altered, it is impossible for us to guarantee 100% security of the information. By using the site, you agree to hold harmless and indemnify Aspen Digital from accidental loss or dissemination of information.

 

We may offer links to other websites as part of our services. Personal information that you provide directly to such sites may constitute privacy issues outside the scope of the Aspen Digital Privacy Policies. Aspen Digital does not exercise control over linked sites and does not collect information as a result of your contact with those sites and shall not in any way be responsible for the collection, use, handling or storage of such data.

 

Nothing in this Policy shall prejudice the data protection rights entitled by you in accordance with the applicable laws.

 

Links To Third Party Websites

 

Our websites may contain links to other sites and pages which are operated by third parties. We have no control over the content of such websites or pages  or the way in which the operators of those websites deal with your personal data. You should review the privacy policy for those third party websites to understand the ways in which your personal data may be used by those third parties.

 

Access and Correction of Personal Data

 

Subject to the exceptions provided in laws and regulation, you have the right to access, review and request a physical or electronic copy of information held about you and also to also request deletion, correction or revision of your personal data. You may exercise such right by contacting us at info@aspendigital.co. Any such request should clearly state the details of the personal data in respect of which the request is being made. We may require further proof from you to verify the authenticity and validity of your request before the same can be processed. 

 

Please note that, in certain circumstances, we will not be able to delete your personal data without also deleting your user account. We may be required to retain some of your personal data after you have requested deletion, to satisfy our legal or contractual obligations. 

 

Direct Marketing

 

Aspen Digital may use your personal or business data (including name, contact information, and information about the products and services that you have purchased or subscribed to) to deliver, through various communication channels by using email address, correspondence address, mobile phone number, telephone number, service number and service account number, etc., various promotion materials including Aspen Digital’s latest offers, gifts, discounts, benefits, information relating to the Aspen Digital Services. For the avoidance of doubt, this consent can be withdrawn at any time as per this Privacy Policy without reference to the duration of the services, and will survive the termination or expiration or termination of customer’s engagement of Aspen Digital Services.

 

You may at any time send request to info@aspendigital.co together with your contact details to stop receiving the promotion materials aforesaid or to resume receiving the same if you have unsubscribed from receiving such materials before.

 

Compliance with this Policy

 

Aspen Digital will regularly monitor and review its compliance with this Policy. Please feel free to direct any questions or concerns regarding this Policy or Aspen Digital's use of information by contacting us by email or via our website. Upon receipt of such complaints, it is Aspen Digital's policy to contact the complaining user regarding his or her concerns. We will cooperate with the appropriate regulatory authorities, including data protection authorities, to resolve any complaints regarding the transfer of data that cannot be resolved between Aspen Digital and an individual.

 

Changes to this Policy

 

Please note that Aspen Digital reserves the right to change this Privacy Policy from time to time without notifying you or seeking your specific consent or approval. Any changes will become effective upon being made available on Aspen Digital’s website. By continuing to use Aspen Digital Services after the changes come into effect, you agree to be bound by the policy as revised from time to time.