Privacy Policy

We are committed to being transparent about how we collect and process your personal information.

We want you to have the information needed to make informed choices about how your Personal Data is used and processed. To support this, we use various methods to keep you informed about our data practices.
Where specific details are required, we will provide them at the relevant time.
If you have any questions or need clarification on any legally imposed limitations, we're happy to help. You can reach us by email at: info@stewardcomptorine.com

Your personal data will only be used for the purposes set out in this Policy.

We process your personal data for a range of purposes: to provide the website and connect you with third-party trading platforms (the "Services"); to improve the site; to protect our rights and interests; to support the maintenance and delivery of the Services; to meet regulatory and legal obligations; and to carry out administrative and business activities necessary for the Services to function.
We also process your personal data to better understand your preferences and needs.

To exercise your rights in relation to your Personal Data:

To exercise your rights, contact us at any time. You may request access to your personal data, ask us to modify or delete it, restrict its use for specific or general purposes, or arrange for it to be transferred to you or a third party. We will accommodate your request accordingly.

Protect Your Personal Data: Withholding your personal data may prevent us from delivering our Services or granting you access to the website.

While we cannot guarantee the absolute security of your Personal Data, we are committed to employing a range of methods and techniques to keep it protected.
This Privacy and Security Policy is complete.

1. The Scope?

This Policy describes the types of personal data the Company collects about natural persons, and how that data is processed, shared with third parties, and secured. This Policy applies to information relating to an identified or identifiable natural person. A person is considered identifiable if they can be identified directly or through a combination of information the Company holds or can reasonably access. "Processing" refers to any operation involving the use or collection of personal data, including its management, organisation, and storage. Our services are intended for users aged 18 and above. We do not knowingly collect personal data from anyone under 18, and we do not permit such individuals to use our services. If we become aware that personal data has been collected from a person under 18, we will delete it promptly.

2. What Personal Data Do We Hold About You?

When you access our Services, service channels, or website, we collect personal data. This may occur directly — when you provide it to us — or indirectly, through analysis of how you use our Services or by receiving your information from third-party partners.

You are not required to provide personal information to us. However, declining to do so may limit our ability to deliver our Services or grant you access to the website.

You are not required to provide us with personal data. However, withholding it may prevent us from delivering our Services or granting you access to the website.

4. What Personal Data Do We Collect? When you visit our website, we collect the following personal data:

This includes information about your online activity log, traffic data (such as IP address, access dates and times), language settings, software crash logs, browser type, and device information. This data is non-personal and cannot be used to identify you.
Personal Data We receive from you: any personal data you voluntarily provide when connecting to a third-party online trading platform through Us.
Personal information you provide directly to third-party platforms to facilitate trade: this includes your full name, address, phone number, and email address.

5. Legal Basis and Reasons for Processing Personal Data We process your personal data only where we have a lawful basis to do so. The specific legal basis depends on the type of personal data involved and the context in which it is collected. We process personal data where: — it is necessary to perform a contract with you, or to take steps at your request before entering into a contract; — we have a legitimate interest in doing so, provided that interest is not overridden by your rights and interests; — we are required to comply with a legal obligation; or — you have given your consent, where consent is the applicable basis. Where we rely on your consent, you may withdraw it at any time. Withdrawal does not affect the lawfulness of processing carried out before the withdrawal. Where processing is required to deliver our Services, failure to provide the relevant personal data may prevent us from performing those Services or granting you access to the website. We will inform you at the point of data collection whether providing personal data is a contractual or statutory requirement, and whether you are obliged to provide it.

6. Transfer of Personal Data to Third Parties We may share your personal data with third parties in the following circumstances: - With service providers and business partners who assist us in operating our platform and delivering our services. These third parties are contractually obligated to handle your personal data securely and only for the purposes for which it was disclosed. - With our subsidiaries, affiliates, and group companies, where necessary to provide our services or for internal administrative purposes. - With regulators, law enforcement agencies, courts, or other government authorities where disclosure is required by applicable law or legal process. - With professional advisers such as lawyers, auditors, and insurers in connection with the services they provide to us. - With a prospective or actual buyer, seller, or other party in connection with a merger, acquisition, restructuring, or sale of assets, where personal data is among the transferred assets. - With any other third party where you have given your consent to such disclosure. Where personal data is transferred to third parties outside Singapore, we will ensure that appropriate safeguards are in place to protect your personal data to a standard comparable to that required under applicable Singapore data protection law. We require all third parties to implement appropriate technical and organisational measures to protect your personal data against unauthorised access, loss, or misuse.

We may share your Personal Data with third-party service providers — including hosting and storage providers — for purposes such as infrastructure support and user experience analysis.
At your request, we may also share specific Personal Data with third-party trading platforms. In such cases, your Personal Data will be provided to those platforms as directed, and its subsequent use will be governed by their respective privacy policies. Your Personal Data may be shared with more than one trading platform.
We may share Personal Data with related entities or business partners where this supports the development and improvement of our products and services.
Where necessary to protect the rights or assets of third parties, we may disclose Personal Data to regulatory, local, or other competent authorities.
We may also share your Personal Data with prospective investors, buyers, or lenders — whether in relation to the Company or any other entity within the group — in connection with a potential transaction, including the sale or transfer of assets, or any merger, restructuring, consolidation, or insolvency proceedings involving the Company or any group entity.

7. Cookies and Third-Party Services We use cookies and third-party services on our website to improve functionality, analyse usage, and deliver a better user experience. Some of these third-party services may collect and process your personal data in accordance with their own privacy policies. By using our website, you consent to the use of cookies as described in this section. You may manage or withdraw your cookie preferences at any time through your browser settings or our cookie management tool. Please note that disabling certain cookies may affect the functionality of our website. Third-party service providers integrated into our platform may include analytics tools, payment processors, and customer support services. Each third party operates independently and is responsible for its own data handling practices. We recommend reviewing their respective privacy policies to understand how your personal data is used. We do not sell your personal data to third parties. Where third-party access to your data is necessary for service delivery, we ensure appropriate safeguards are in place.

We may work with third-party service providers, including advertising networks and analytics companies, which may also place cookies or similar technologies on your device.
Cookies are small text files stored on your device when you visit the website. They are used to recognise your preferences and browsing habits, personalise your experience, and support statistics and analytics.
Some cookies we use are session cookies — temporary files that are deleted when you close your browser. Others are persistent cookies, which remain on your device after your browser is closed. Persistent cookies allow the website to recognise you as a returning user and help you resume your session seamlessly.

Types of Cookies:

We may use them based on their purpose:

ONLINE TRACKING NOTICE
This service does not currently support do-not-track signals.
8. Retention of Your Personal Data

We retain your personal data for as long as necessary to fulfil the purposes described in this Policy, or for longer periods as permitted by applicable laws, regulations, or orders.
We share your information with third-party trading platforms for 12 months. Where you consent to continued sharing, we will do so for a further 12 months.
We review the personal data we hold on a regular basis to confirm it is no longer required.

9. Transfers of Personal Data to a Third-Party Country or International Organisation Where we transfer your personal data outside Singapore to a third-party country or international organisation, we ensure appropriate safeguards are in place to protect that data in accordance with applicable requirements. Such transfers occur only where necessary to deliver our services or fulfil our obligations to you. If you would like further information about the safeguards applied to international transfers of your personal data, please contact us using the details provided in this policy.

10. Security of Personal Data We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. Access to your personal data is restricted to personnel who require it to perform their duties. Where we engage third-party service providers to process personal data on our behalf, we require them to maintain equivalent security standards and to process that data only on our documented instructions. No method of transmission over the internet or electronic storage is entirely secure. While we take reasonable steps to protect your personal data, we cannot guarantee absolute security. In the event of a data breach that is likely to affect your rights or interests, we will notify you in accordance with applicable requirements. You are responsible for maintaining the confidentiality of any credentials used to access your account. Please notify us immediately if you suspect any unauthorised access or use of your account.

We have implemented appropriate organisational and technical measures to protect Personal Data, including safeguards against accidental or unlawful destruction, loss, or alteration. We cannot guarantee that the security of your Personal Data will be maintained without error, nor can we accept liability for any intangible, incidental, or consequential damages arising from the use or disclosure of Personal Data. This includes, without limitation, Personal Data disclosed due to transmission errors, unauthorised third-party access, or other causes beyond our control.
Where required by legal or other obligations beyond our control, we may be required to disclose Personal Data to third parties, including public authorities. We do not control the security measures applied by such third parties to your Personal Data.
Personal Data cannot be transmitted over the internet with complete security. We cannot guarantee the security of Personal Data you transmit to us online.

11. Links to Third-Party Websites

Our website may contain links to third-party websites and applications. These sites and apps are not under the Company's supervision, and we are not responsible for how they collect or process Personal Data. This Policy does not apply to any actions taken through third-party sites or apps.
Before accessing or using any linked third-party website or app, we recommend reading its privacy policy carefully. We also advise caution when providing Personal Data to any third party.

12. Modifications to this Policy We may update this Policy from time to time. Any changes will be posted on this page with a revised effective date. Continued use of our services after changes are posted constitutes your acceptance of the updated Policy. We encourage you to review this page periodically to stay informed of how we handle your information.

Before visiting any third-party website or app, read its privacy policy carefully. Only share your personal data with third parties once you are comfortable with how it will be handled.

13. Your rights with respect to your personal information Depending on your location, you may have certain rights regarding your personal information under applicable data protection laws. These rights may include: The right to access the personal information we hold about you and to request details of how it is used and shared. The right to request correction of any inaccurate or incomplete personal information. The right to request deletion of your personal information, subject to our legal obligations to retain certain data. The right to object to or restrict our processing of your personal information in certain circumstances. The right to data portability, where applicable, allowing you to receive your personal information in a structured, commonly used format. The right to withdraw consent at any time where processing is based on consent, without affecting the lawfulness of processing carried out prior to withdrawal. To exercise any of these rights, please contact us using the details provided in this policy. We will respond to your request within the timeframe required by applicable law. We may need to verify your identity before processing your request. Please note that these rights are not absolute. In some circumstances, we may be unable to fulfil a request — for example, where doing so would conflict with our legal obligations or adversely affect the rights of others. Where we are unable to act on a request, we will inform you of the reasons. If you are dissatisfied with how we handle your personal information or respond to your rights request, you have the right to lodge a complaint with the relevant data protection authority in your jurisdiction.

You have the right to request that we verify the accuracy of Personal Data we hold about you, correct any inaccuracies, and delete any Personal Data we are not required to retain. You may also request restrictions on how your Personal Data is processed.
If you are a resident of the EEA, please refer to this page:
These rights apply to the Personal Data you have provided to us. To exercise any of these rights, please contact us by email at the address below.
Access rights
Where we confirm that your Personal Data is being processed, you may request access to that data.
We will provide an electronic copy of the Personal Data being processed. A reasonable fee may be charged for additional copies. Data will be provided electronically upon request.
The right of access must not conflict with the rights and freedoms of others. Where fulfilling a request would be detrimental to another person's rights or freedoms, we may refuse or limit our response accordingly.
Right to rectification
You have the right to request correction of any inaccurate Personal Data we hold about you. Where Personal Data is incomplete, you may request that it be completed, taking into account the purpose for which it is processed.
Right to erasure
This right applies where: (a) the Personal Data is no longer necessary for the purpose for which it was collected or processed; (b) you withdraw consent and there is no other legal basis for processing; (c) you object to processing based on legitimate interests pursued by us or a third party; (e) the Personal Data has been unlawfully processed; or (f) erasure is required to comply with a legal obligation.
This right does not apply where processing is necessary: (a) to comply with a legal obligation under European Union or Member State law; or (b) to establish, exercise, or defend legal rights.
Processing restrictions
If you dispute the accuracy of your Personal Data, you may request that we restrict its processing while accuracy is verified.
Where processing is restricted, Personal Data may only be retained with your consent, or for the establishment, exercise, or defence of legal rights, for the protection of another person's rights, or for reasons of substantial public interest within the European Union or a Member State.
Right to data portability
Where processing is carried out by automated means and is based on your consent or a contract to which you are a party, you have the right to receive the Personal Data you have provided to us in a structured, commonly used format.
You may request that your Personal Data be transferred directly to another controller where technically feasible. Exercising this right does not affect your right to erasure. The right to data portability does not override the rights or freedoms of others.
Right to object
You have the right to object at any time to the processing of Personal Data concerning you where such processing is based on legitimate interests pursued by us or a third party, including profiling based on those interests. Where we cannot demonstrate compelling legitimate grounds for processing that override your rights, interests, or freedoms, or where processing is not necessary for the establishment, exercise, or defence of legal rights, we will cease processing.
You have the right to object at any time to the processing of your Personal Data for direct marketing purposes.
Right to withdraw consent
You may withdraw your consent to our processing of your Personal Data at any time. Withdrawal does not affect the lawfulness of any processing carried out prior to withdrawal.
You have the right to lodge a complaint with a supervisory authority.
You may lodge a complaint with a supervisory authority established by a Member State to protect individuals' fundamental rights in relation to the processing of Personal Data within the European Union.
European Union and Member State law may limit certain rights in relation to your Personal Data as described in this section 13.
We will respond to requests made under section 13 within one month of receipt. Where necessary, given the complexity or volume of requests, this period may be extended by up to two months. We will notify you of any extension within one month of receiving your request, along with the reasons for the delay.
Subject to the provisions of section 13, information provided in response to your rights under section 13 will be provided free of charge. Where requests are manifestly unfounded or excessive, particularly where they are repetitive, we may charge a reasonable administrative fee or decline to act.
Where we have reasonable doubt as to the identity of the person submitting a request, we may request additional information to verify identity.