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GLX PRIVACY POLICY

In this Privacy Policy, “GLX”, “we” or “us” refers to GLX Pte. Ltd (a company registered in Singapore), and GLX Digital Limited (a company registered in Australia) and their related bodies corporate.

GLX is committed to protecting your privacy. We understand your concerns regarding how information about you is collected, used, disclosed and protected. This notice (this Privacy Policy) describes what information we collect about you, how we collect it, how we use it, with whom we may share it, and what choices you have regarding it.

This Privacy Policy is incorporated into and forms part of the Terms of Use and the Privacy Collection Statement found at www.glxdigital.com (Site). We encourage you to become familiar with the terms and conditions of this Privacy Policy, the Privacy Collection Statement and the Terms of Use. By accessing and using the Site, you agree that you have read and understand this Privacy Policy and you accept and consent to the privacy practices (and any uses and disclosures of information about you) that are described in this Privacy Policy.

We comply with the Australian Privacy Principles (APPs) under the Privacy Act 1988 (Cth), the Singapore Personal Data Protection Act (PDPA) and the European Union General Data Protection Regulation (GDPR), which regulate how we handle the information you supply when subscribing to a software licence agreement to use any of our trade management software or other services (Services).

Type of personal information that may be collected

We may collect certain personal information as defined under applicable privacy laws including, but not limited to, (a) identification data (for example your name, e-mail address, mailing address, contact number, company details, position within company); (b) information about your connection and device capability in connection and interaction with our Site; (c) electronic identification data (for example internet protocol address and cookies); (d) your user profile (e) user subscription data (including company incorporation number and registered business address (with (a) to (e) collectively being, Personal Information) via our Site. The provision of such Personal Information by you is not mandatory, but may be required in order to use or access certain web pages and/or sections of our Site or our Services.

We do not intentionally collect special categories of personal data (sensitive information) unless required by law or provided with explicit consent.

Use of personal information

The main purposes for which we collect, hold and use Personal Information are:

For subscription of our Customers to use the Services;

To provide our Services;

To respond to an individual’s request;

To operate, evaluate and improve our business;

To maintain contact with our users;

To keep subscribers and other users informed of the Services, updates to the Services, industry developments, and to notify them of relevant Service offerings;

For general management and reporting purposes, such as invoicing and account management as necessary; and

Other purposes related to our business.

If you choose not to provide us with Personal Information, we may be unable to do the above functions.

We may collect, hold and use Personal Information about individuals to market our Services, including by email. However, individuals can elect not to receive further marketing information from us by writing to GLX at privacy@glxdigital.com.

If we collect, hold or use Personal Information in ways other than as stated in this policy, we will ensure we do so pursuant to the requirements of the applicable privacy regulations.

Legal bases for processing GDPR/UK GDPR

Where the GDPR or UK GDPR applies, we process Personal Information on the following lawful basis:

Performance of a contract (eg. providing the Services);

Our legitimate interests (eg. improving the Site and Services, maintaining security);

Compliance with legal obligations;

Consent (eg. for direct marketing where required).

Data controller

For individuals located in the European Union (EU), European Economic Area (EEA) or the United Kingdom (UK), the data controller responsible for processing of your Personal Information in connection with the Site and the Services is GLX Digital Ltd and GLX Pte Ltd, acting jointly as data controllers.

Where required under applicable law, each entity is responsible for ensuring that your Personal Information is processed in accordance with this Privacy Policy and applicable data privacy legislation. You may contact either entity using the contact details provided in this Privacy Policy for any queries relating to the processing of Personal Information.

Disclosing of personal information

We are committed to protecting your privacy. We do not sell, rent, distribute or otherwise make Personal Information commercially available to any third party, except as described in this Privacy Policy. We will not disclose your Personal Information to third parties unless you consent to such disclosure or in circumstances where such disclosure is required or authorised by law or to enforce our Terms of Use, to respond to claims from third parties, to protect the safety, interests, rights or property of ours or others or as permitted under this Privacy Policy.

You agree that we may disclose your Personal Information to third parties under any of the following circumstances:

When we have your consent to disclose the Personal Information;

When we disclose your Personal Information in accordance with this Privacy Policy;

We need to disclose your Personal Information to provide the Services that you have requested;

We need to disclose the Personal Information to third parties who on behalf of us provide Services to you or assist us in maintaining the quality and efficiency of our Services and our business operations (we require such third parties to process Personal Information only on our instructions and subject to confidentiality and security obligations); or

Such disclosure is otherwise required or permitted by law.

Categories of recipients may include hosting providers, analytics providers, customer support providers and other service providers necessary for the operation of our Services.

Transfer of personal information

Where we transfer Personal Information outside Australia, Singapore, the UK or the European Economic Area (EEA), we will ensure that appropriate safeguards are in place, including (where applicable) the European Commission’s Standard Contractual Clauses (2021) (SCCs), the UK Addendum to the EU SCCs, reliance on countries that have been recognised as providing an adequate level of protection or other legally recognised transfer mechanisms.

We remain responsible for the processing of your Personal Information by our overseas service providers and assess the risks associated with international transfers, through Transfer Impact Assessments, where required.

A copy of the relevant safeguards is available upon request.

We may sell or buy subsidiaries or business units. In such transactions as well as in the event that all or substantially all of our assets are acquired by a third party, your Personal Information will generally be one of the transferred business assets. We reserve the right to include your Personal Information, collected as an asset, in any such transfer to a third party.

Managing personal information & security

GLX takes reasonable steps to protect Personal Information it holds from misuse, interference and loss and from unauthorised access, modification or disclosure.

These measures include access controls, encryption, secure storage, network and application security measures, secure development practices, and internal policies governing data handling.

The time period for which we keep Personal Information depends on the purpose for which we collected it. We retain Personal Information only for as long as necessary to fulfil the purposes for which it was collected or to comply with legal obligations.

We do not use automated decision‑making or profiling that produces legal or similarly significant effects on individuals. If this changes in the future, we will update this Privacy Policy and provide any notices required under applicable law.

Your rights

You are entitled to request details of the information we hold about you, except in certain circumstances set out in the applicable data protection law and regulations, and to have it rectified or deleted as required by applicable data protection legislation.

Additional rights under GDPR/UK GDPR include:

The right to restrict processing;

The right to data portability;

The right to withdraw consent at any time;

The right to lodge a complaint with a supervisory authority;

The right to object to processing based on legitimate interests;

to object to direct marketing (including any profiling) at any time;

to ask us to delete personal data that we no longer have lawful grounds to process; and

to object to the use of automated decision making.

APP Complaints:

If you have a complaint about how we handle your Personal Information under the Australian Privacy Act 1988 (Cth), you may contact us at the address provided below. We will acknowledge your complaint within 5 business days and aim to resolve it within 30 days. If you are not satisfied with our response, you may lodge a complaint with the Office of the Australian Information Commissioner (OAIC).

PDPA Consent:

If you are located in Singapore, you may withdraw your consent to our collection, use or disclosure of your personal data at any time by contacting us at the address provided below. We will process your request within a reasonable time and inform you of any consequences of withdrawal, which may include our inability to continue providing certain Services.

If you wish to have your Personal Information deleted or would like to exercise any of the above rights (to the extent applicable to you), please contact GLX at privacy@glxdigital.com; or

Post: Attention
The Privacy Officer
GLX Digital Ltd
PO Box 131

SUBIACO WA 6904

Cookies

We use cookies and similar technologies to operate and improve our Site, analyse usage, and personalise content. Where required by law (including under the Eu ePrivacy Directive), we will obtain your consent before placing non-essential cookies.

We allow certain third party companies to collect certain anonymous information when you visit our Site. These companies may use non-personally identifiable information during your visits to our Site and other websites in order to provide advertisements about goods and services likely to be of greater interest to you. These companies typically use a cookie or a third party web beacon to collect this information.

Links to other sites

GLX is not responsible for the privacy practices or the content of web sites that are linked on the GLX Site. Please refer to the Terms of Use.

Changes to Privacy Policy

GLX operates in a dynamic business environment. We may update this Privacy Policy from time to time and notify you by posting an updated version of the Privacy Policy on the Site.

Acknowledgement

BY ACCESSING OR USING THE SITE, YOU ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTAND, AND CONSENT TO THE PRIVACY PRACTICES, AND TO THE USES AND DISCLOSURES OF INFORMATION WE OBTAIN ABOUT YOU, THAT ARE DESCRIBED IN THIS PRIVACY POLICY, AND YOU AGREE TO BE BOUND BY THE TERMS OF USE REFERENCED ABOVE.

This Privacy Policy was last updated on 19 February 2026.

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